Cleanup of the contaminated LCP marsh may begin – and end - this autumn. Remedial plans provide for cleanup of the contaminated areas immediately offshore from the site. According to the plan submitted to the EPA, after removal of some soils the area will not receive further treatment. There are provisions for long-term monitoring, and indications that the ban on seafood harvesting will continue indefinitely. Overall, the plan fails to provide any short-term relief to biota inhabiting the marsh. The plan also fails to provide an adequate model for predicting long-term fate of chemicals left behind after "cleanup." It is still unclear when the marsh could again be used for commerce or recreation.

The Glynn Environmental Coalition (GEC) has received for review several documents related to the Marsh cleanup including: the Feasibility Study Report for the Mash Estuarine Area of Operable Unit 1 of the LCP Site in Brunswick Georgia (June 1997); Volumes I and II of the Ecological Risk Assessment of the Marsh Area of the LCP Chemical Site in Brunswick, Georgia (June 1997, the "AlliedSignal Report"); and the final report of the Ecological Assessment/Ecological Risk Assessment of the Salt Marsh and Adjacent Areas at he LCP Superfund Site (1997, the "Sprenger Report").

In essence, AlliedSignal and EPA each conducted risk assessments for the marsh. The EPA risk assessment used data on chemical distribution and animal "body burdens" (chemicals found in tissues) to provide a view of marsh contamination as it exists today. The AlliedSignal risk assessment is very different, using projected values for the chemical levels after a removal action during the fall of 1997. In other words, the AlliedSignal report uses "data" that does not yet exist. At this time the GEC has yet to receive a complete plan for the fall removal action. Consequently, it is impossible to provide a complete review of the AlliedSignal Assessment and Feasibility Study since it is based on speculation, not observations.

The Sprenger Risk Assessment found clear evidence of stress in marsh animals. High levels of site contaminants were routinely found in marsh animals and plants. Generational effects were documented for marsh turtles. Ample evidence of widespread food chain contamination was observed. The studies were not exhaustive in scope and there are still many questions about the health of the marsh. Some of the studies were incomplete or lacked reliable scientific literature foundation.

The apparent lack of a true control group was of particular concern. The "control" or reference area provides a basis for determining the difference between a natural area and an area injured by pollution. The goal of risk assessment studies on individual animals and populations is to determine if there is either no effect from pollution or a direct impact from site chemicals. One of the best ways is to compare the area directly affected by the pollution with a control site that has the same types of animals and plants and same general natural characteristics (water chemistry, geology, weather), but lacking site chemicals. Injury to animals can then be viewed as the relative differences in the two areas. For this to work, it is critical for the control site to have no influence from the study area, or influences that mimic the study area.

Unfortunately, in many of the studies for LCP the selected control sites were poor references. For example, site contaminants were found in birds from the control area, obviously the birds were feeding in both areas and no conclusions on health or stress are practical. In trayed oyster experiments animals from clean areas were brought to the area and placed in both the control and LCP marshes. The idea was to see if there was greater survivability in the control area. However, oysters died in high numbers at both the control and marsh study areas. Again, no conclusions may be drawn regarding site chemicals.

Likewise, in laboratory sediment toxicity tests serious differences in the control sediments make comparisons impractical. In these studies, marsh sediment from LCP and the control site were studied in the laboratory. Control treatments should be completely negative, but instead showed inconsistent survivorship data, thus preventing any meaningful interpretation of the study results.

In some cases important field observations were ignored. For example, there is a significant lack of nest sites for some birds and reptiles in the marsh. The study’s authors cite the lack of nests as a reason for not performing studies, rather than an effect of marsh pollution.

The only "hard" lines of evidence are from body burdens found in site animals; and these are extremely high. Chemical levels in tissues of aquatic animals were higher than the surrounding water and sediment, indicating "bioaccumulation" through the food chain. There is no strong scientific literature base for translating body burdens into environmental stress. Also, there are no strong data relating chemical levels in water, diet and sediment to the body burden. So it is very difficult to gauge the long-term recovery of the marsh using tissue levels alone.

The GEC has yet to review final plans for the autumn marsh remediation. Based on information provided in the Sprenger Report it is expected that marsh sediments containing mercury above 30 mg/kg, or PCB contaminated sediments above 50 mg/kg, will be removed for redisposal. This will primarily affect the marsh immediately offshore of the areas near the former plant drains.

Undoubtedly, this action will remove from the marsh system the greatest long-term threat of mercury and PCB coming from the LCP site. Removal will allow natural attenuation to begin. However, the marsh and Turtle River drainages will not be clean of chemicals. Based on the available studies, there are no good predictions for when the marsh animals and plants will be free of contaminants.

Despite the near complete lack of a scientific foundation for understanding the chemical dynamics of the marsh, the Risk Evaluation submitted by AlliedSignal predicts no further remedial actions and only a minimum of monitoring. There is not a clear technical basis for predicting a fast and complete reduction in body burdens at the site based solely on removal of Mercury and PCB to 30 and 50 mg/kgs. It is conceivable the bioaccumulation effects of food chain contamination could still result in additional increases in body burdens for the top food-web species. The Feasibility Plan should include realistic goals for body burden reduction that, if not met in a reasonable time period, would require additional removal or alternative strategies for accelerating attenuation. The Feasibility Study submitted to the EPA predicts monitoring would cease in 5-10 years. This is highly optimistic given the severity of contamination and the poor factual basis used to set cleanup goals.

"Institutional controls" is an awkward term to apply to a marsh. It is relatively easy to fence off the uplands area and impose access and usage limitations. But, the marsh cannot be as easily controlled. A plan should be developed for controlling access to the marsh, policing the existing ban on fin and shellfish, and continuing public education regarding restriction on the marsh for food and recreation.

The proposed cleanup should benefit the marsh and the Turtle River drainage by removing a major reservoir of mercury and PCB contamination. The long-term prospects for the marsh will be much improved by this action. In the short-term the action will have little effect on the health of marsh animals. There is not enough information to guess how long it will take to lower the levels of chemicals in the tissues of site animals.

For all practical purposes, the Feasibility Plan submitted to EPA abandons the marsh after the autumn removal action. Only minimal monitoring is planned, and only for a few two-year cycles. The Feasibility Plan is based on conditions that have not yet occurred. There is not enough scientific support to assure residents that the optimistic forecast will be achieved.

Better long term planning is needed, and a contingency plan based on an actual reduction of mercury and PCB in the tissues of site animals is essential. Finally, the Feasibility Plan needs to incorporate long-term enforcement and education of the fishing ban until the area is again safe for recreation and commercial interests.

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