TAG reports: Volume1, Number 1;
September, 1992
009 Superfund Site: Questions and Answers from the public meeting on September 1, 1992 at the Altama Elementary School
Overview
On September first, The Glynn Environmental Coalition held a public meeting at the Altama
Elementary School to coordinate local response to the EPA Feasibility Plan for the
Hercules 009 Superfund site. The site is adjacent to the school. At the meeting residents
asked questions about testing at the site and expressed concerns over health risks to the
community.
The EPA provided the Coalition with a Technical Assistance Grant (TAG) in order to hire an
advisor. Coalition President Daniel Parshley introduced the Technical Advisor, Dr. R.
Kevin Pegg, to the residents for questioning. The following is a summary of the questions,
answers and comments made at the meeting.
What is Toxaphene? Is it the only chemical at the site?
The main contaminant at the landfill is Toxaphene sludge, a byproduct of the manufacture
of Toxaphene at Hercules. The pesticide Toxaphene was widely used in the south to control
boll weevil infestations. Toxaphene was banned primarily because of its long
"half-life." Chemists measure where chemicals go in the environment by a
chemicals ability to be transported by air or water movements and its ability to be
degraded to harmless forms. "Half-life" refers to the length of time it takes to
degrade to one-half of the original amount. Toxaphene is a danger at the site because it
is present in a large volume and it degrades very slowly. During the Remedial
Investigation (RI) trace amounts of Dioxins were detected, but not in concentrations that
threaten the public. Neither Toxaphene or Dioxin vaporize into the air easily, however,
the public should be concerned over the volatile organic chemicals detected in some well
water samples. "BTEX" chemicals, usually found in areas contaminated with
petroleum products, were found from an undetermined source.
Is the landfill leaking Toxaphene?
Some of the test wells were positive on the site. The consulting company argues that the
contamination was an "artifact" or accident of well drilling. However, new wells
drilled near the contaminated wells repeatedly tested positive. Core samples taken through
the center of one of the containment cells showed toxaphene migration into the undisturbed
soils beneath the dump, clearly below the water table. At this time it does not appear
that large amounts of Toxaphene waste are leaking out of the dump, but some movement is
occurring.
How was the dump constructed?
The Hercules 009 Superfund site was originally a "borrow pit" where soil was dug
to build Georgia State Highway 25 (Spur 25). A filler of "stumpdirt," material
washed off of stumps brought to the plant for processing, was placed (landfilled) into the
old borrow pit. After building up the base with stumpdirt the pit was divided into six
"containment cells." The cells are separated from each other with berms (walls)
of stumpdirt, and each cell has a bottom layer of bentonite clay to reduce the flow of
water into and out of the cells. Toxaphene sludge was dumped in each cell, and a layer of
dirt added on top when the cell filled.
There are two reports of construction problems. The RI mentions that heavy rains caused a
breach of one of the containment berms releasing an undetermined amount of sludge from the
cell. Also, workers at the site say that a heavy equipment accident breached the clay
liner in one cell, which was not repaired. Residents should also note that Toxaphene was
dumped in uncontained "staging" areas outside of the cells.
How much sampling was done at the site? Is the extent of contamination known?
The borders of the sludge layer in the landfill were determined by discussions with
Hercules personnel and through the use of seismic sampling. Basically, echo soundings were
taken and compared to core samples. The echo patterns corresponding to the sludge layer
were used to locate the extent of contamination. This technique is unusual and
experimental. Generally a grid is laid out and samples are taken every few feet until no
positive samples are found. The grid technique definitely should be used in the
contaminated neighborhood next to the site.
What does the RI report say about the clay liner? Will it hold and stop the movement of
Toxaphene out of the dump?
A clay bentonite layer was confirmed by core sampling. Although reports place its
thickness as anywhere from a few inches to more than a foot in depth, the techniques used
in the RI do not give accurate information on whether or not the clay layer covers the
bottom of the dump completely. The purpose of the clay layer is to inhibit Toxaphene
movement into the ground water. At least three of the proposed remediation techniques are
dependent on the long term stability of the layer. More information on the clay liner is
needed to prove there are no gaps in this layer.
Has the One-Hundred Year Flood Plan been done?
There appears to be no mention in the RI of the local flood plains. Since four of the
proposed options involve leaving the toxic waste at the site for at least 30 years, it
would make sense to do worse-case planning. Glynn county is also in a hurricane prone area
of the coast. Remedial Investigations at other sites have taken floods, hurricanes and
earthquakes into consideration when long term storage at the site is the preferred option.
What does the Remedial Investigation report say about underground water flow at the
landfill?
There are two aquifers (underground water storage zones) beneath the site. The RI
concludes that the flow is generally to the east in the upper (surficial) aquifer, and to
the southeast in the lower aquifer. Toxaphene has been found in the upper aquifer, and the
water table (the top of the upper aquifer) is in contact with the sludge layer. Drilling
studies have not detected any toxaphene "plumes." A plume occurs when chemicals
are carried in moving fluid. One problem with the studies at the site is that flow of
water is based on a model of laminar flow. Laminar flow occurs when a fluid moves in
"straight lines" through an area. A plume under laminar flow conditions can be
visualized by thinking of a smokestack on a day when the wind is blowing steadily. The
smoke plume moves with the fluid and spreads out like a cone turned on its side. There is
insufficient data to conclude that the flow at the site is laminar. The borrow pits across
the Spur from the site can influence underground flow, the stream or pond can effect local
flow, pumping from the aquifer may change the flow. The actual flow patterns can differ
substantially from the laminar model used.
The study did not consider models for chemical transport other than laminar flow.
Chemicals can move by "lens effects." A lens occurs when a dry spell is followed
by rains. Water moves downward through the soil carrying material with it as it travels.
Residents with drinking wells in the upper aquifer report that after a rain their water is
cloudy and tastes of tannic acids. This is a classical lens effect. Another way that
chemicals can move is by "bolus" effects. When flow is not laminar water moves
at different speeds in different directions. Contact with chemicals is unequal and
contaminated water can occur in a bolus, a sort of "lump" of polluted water in
an otherwise clean area. Lens and bolus effects could explain the tendency of wells to
only occasionally show contamination.
The site is often mowed. Does this pose a threat to the community?
The RI does not indicate air sampling studies at the site during mowing operations. At the
north end of the landfill mower score marks are observed on the ground in an area where
contaminated surface soil is reported.
Does the site pose a threat to the environment?
Studies reported in the RI have several flaws in experimental design which make it
difficult to interpret the long term effects on the environment. There are four basic
parts to the environmental section: a biodiversity study, a plant stress study, a
bioaccumulation study, and toxicity testing.
Biodiversity is a measure of the health of an area by counting the number of different
species of plants, insects and animals in the area. Generally, the more different types of
life found in an area, the more healthy it is. The study compared two parts of the stream
to test for ecology damage from the landfill. Bio-1 station was in the stream north of the
landfill, Bio-2 was south of the landfill. For a Biodiversity index to work properly the
Bio-1 station would have to be a "control," meaning that it is identical in
every way to Bio-2 except for being upstream and not under the influence of the landfill.
In fact, Bio-1 is not a valid control for these studies. During rains, water flows from
the landfill north through the Bio-1 station until sufficient water pressure builds at the
streamhead to begin flowing south again. Also, Bio-1 is often dredged by the County, which
lowers its diversity.
The plant stress study consisted of looking at pictures and video of the site. No actual
attempts were made to measure plant stress in the field. The study was independently
reviewed by Dr. M. S. Saunders, a former Professor of Phytochemistry, who has researched
and published in the area of plant stress disease. Dr. Saunders concluded that it would be
impossible for any conclusions to be made on plant stress based on the studies described.
Bioaccumulation occurs when animals absorb chemicals by contact or ingestion. Often when
the soil and water levels are below detection the toxins will be found in very high levels
in the body tissues of animals at the site. The bioaccumulation studies were done on
animals caught far downstream, although guidelines call for studies to examine animals at
the site. Investigations at other sites have used local fish and terrestrial animals such
as worms and grubs in studying bioaccumulation. No reason was given for only studying
animals far from the area. Toxaphene is known to bioaccumulate in animals.
Toxicity tests are performed by collecting water from the area and exposing test animals
and plants under laboratory conditions to see if the water causes sickness or injury.
Guidelines for toxicity tests includes three different test systems: fish, water fleas,
and algae. No toxic effects were observed using water from the stream, however, only one
test system was used-- water fleas.
Throughout the environmental testing only a minimum effort was made. Only one test for
biodiversity, no actual test for plant stress, minimal bioaccumulation data, and a single
attempt at toxicity testing using one test system. The environmental testing is very
biased and is not a scientific study. No conclusions can be made about the long term
effects the site will have on the environment.
In the past the area was home to many types of birds, raccoons, even deer which are now
rare. Has the site affected them?
More likely the animals have been driven away by urbanization near the site. The area has
become developed and commercialized over the past decade with considerable loss of
habitat.
What do the chemical measurements really mean?
For Toxaphene contaminated ground water, the limit is set at 3 parts-per-billion (3 ppb).
The "ppb" measurement is a convenient way of expressing an amount of a chemical
present in a specific volume. A "ppb" is a very small amount. A few grains of
salt in a quart of water is in the ppb range. For instance, one part-per-million (1 ppm)
is equal to 0.0001%. One part-per-billion (1 ppb) would be a thousand times less than 1
ppm.
The EPA has proposed in situ stabilization. Has this been used at similar sites before?
Apparently not. The technique appears to be still in the experimental stage at this time.
Is Bioremediation a possibility?
Probably not. Chemicals like Toxaphene are not readily digested by the bacteria and fungus
strains used in Bioremediation. Also, the process involves considerable mixing to
distribute the media and microorganisms. This is not very practical with this much waste
material.
What has testing indicated about the Altama Elementary School near the site?
The RI sampling plan shows a sample site near the school, however, data from that site
could not be found in the results section.
How are Action Limits set?
The idea behind an action level is to find a concentration of chemical at which no effect
will be felt no matter how much is consumed. Unfortunately, for Toxaphene most health data
is based on workers exposed at manufacturing plants or spray operations-- essentially
healthy males of about 30 years of age. Not much is known about the effects on children or
the elderly.
What are the health effects of Toxaphene?
Toxaphene is a class B2 carcinogen. It causes cancer in animals but insufficient
information is available on humans. Other effects may include damage to the kidney, liver,
nervous and immune systems. Toxaphene is reported as a mutagen since it causes chromosome
damage in animals. Effects on juvenile development, including underdeveloped organs and
limbs, has been reported.
Are health problems occurring in the community? Does the RI address community health?
The remedial investigation involves long term modeling using the chemical concentrations
reported from the sampling plan. It does not take into consideration the residents current
medical problems. The only formal study on exposed humans at the site was done by the
Toxic Communications and Assistance Project, Albany State College. Based on survey data
the study reported that about half of the respondents had health problems possibly related
to environmental exposure.
A formal report to the Glynn Environmental Coalition on the Remedial Investigation will
be made available.
This report will be made available here for downloading by FTP in November, 1995.
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