The Glynn Environmental Coalition (GEC) is providing the following
information for your use when discussing the issues surrounding the testing
of Altama Elementary School.
The EPA Region 4 presentation to the Board of Education on January 29, 2007,
is a continuation of a decision made in 1991 to NOT report all chemicals
present by development of an analytical method for toxaphene that is only
used in Glynn County, which was found inappropriate by the EPA Office of
Inspector General (OIG). The GEC trusts the following information will
provide a firm basis for our concerns, which resulted in the EPA OIG
agreeing that all chemicals present should be reported.
Summary of the issues:
In 1991, the EPA, Georgia EPD, and Hercules had a meeting in which they
agreed to change the analytical method for toxaphene to report toxaphene and
"some other product". The new method only reported toxaphene chemicals
from the back half of the chromatogram. When toxaphene enters the
environment as a mixture of over 670 chemicals, shifts in ratios of
chemicals occurs by the most chlorinated loosing a chlorine atom or two and
becoming the persistent form that appears in large quantities in the front
half of the chromatogram. In 1997, the analytical method was changed
further by eliminating any toxaphene chemicals not present in the same ratio
as the calibration standard, further excluding toxaphene chemicals from
quantification and reporting. The EPA OIG found these analytical method
changes made by EPA Region 4 inappropriate. EPA Region 4 responded by
developing another method that only measures 3 toxaphene chemicals (only
found after people or fish metabolize the chemicals). This method would
report none or ~3% of the toxaphene present. The EPA OIG said not to use
the method and further stated that the Hp-Sed and Hx-Sed (toxaphene with 6
and 7 chlorines, which are the ones present in large amounts) should be
reported. EPA Region 4 has steadfastly refused to report these toxaphene
chemicals that are present in the largest amounts in defiance of the EPA OIG.
(Under the Hercules Patent, toxaphene includes all chlorinated camphene with
3 to 10 chlorines attached)
At the Hercules 009 Landfill Superfund Site, a toxaphene cleanup level
was set based upon the assumption that the other toxaphene manufacturing
waste chemicals such as dioxin would be cleaned up to safe level. By not
reporting all toxaphene present, other chemicals will not be cleaned up.
The EPA OIG use the example from our community where 56 fish samples
from Terry Creek were analyzed by the inappropriate method and no toxaphene
was reported in any sample. When re-analyzed by Negative Ion Mass
Spectroscopy (NIMS), the fish had up to 26 ppm, or 56 times the EPA "Do Not
Eat" level. Obviously, the inappropriate method is a health threat to all
in our community and re-testing is needed. A similar situation could be
occurring at Altama Elementary School, but like Terry Creek we will only
know after appropriate testing is conducted.
EPA Region 4, Georgia EPD, and Hercules are united in their
effort to keep all toxaphene chemicals being from being reported. The EPA's
presentation to the Board of Education went one step further and declared,
"...toxaphene breakdown products in soil do not pose a human health risk."
The EPA did not produce any studies or data to support their contention that
a poison and carcinogen do not pose a human health risk, but there are
numerous studies to the contrary that are discussed in the Agency for Toxic
Substance and Disease Registry (ATSDR) Toxicological Profile for Toxaphene.
Furthermore, the EPA OIG interviewed the ATSDR toxicologist whom estimated
only 10% of the toxaphene present was being reported.
Toxaphene is present in our community up to 8% in soils (yes,
that is percent, or 88,000 ppm). Around 2-3 million pounds of toxaphene
were released into our estuary. Four toxic sites have not been investigated
or cleaned up that contain toxaphene.
EPA Region 4 has made a decision to continue to NOT report all
chemicals present and declare toxaphene does not pose a health risk, even
when all the chemicals present has not been determined. The GEC would like
to resolve this situation in cooperation with the Glynn County BOE in a
manner that does not alarm parents or children.
The Glynn County BOE needs to be satisfied that:
- Chemicals have not been left on school property;
- Sufficient information is available to conduct drainage ditch
maintenance activities without recontamination; and,
- School property is not encumbered by chemical contamination.
The GEC is providing the following information in the form of a
rebuttal to the EPA's presentation to the BOE. Please do not hesitate to
ask if you need clarification or documents cited.
- Slide: Removal and Testing… There were two removal actions on
school property. The one that extended along the ditch and to the playground
was not included by EPA Region 4. Contrary to the contentions of the EPA,
toxaphene contamination was found in 1995 up to and abutting the school
playground, which the GEC is cognoscente and a factor in our request for
retesting the school (See Attachment A). School property was tested after
the removal action and levels up to 84 ppm remained. Notable is that the
EPA presentation excluded this area that extends to the playground from the
removal action presented to the BOE, which further emphasizes the need for
retesting the school. It is unknown why EPA Region 4 would withhold
information about the removal action and the extent of contamination on
- Slide: Sampling and Analysis… 1.) EPA claims sampling of the
school yard is not part of Superfund or the Superfund Site, but the EPA has
this data as part of the Site record, as indicated by being part of the
presentation, and the EPA actually tested the soil (See Attachment B).
2.) The EPA contends that in 1993, there was no method for
weathered toxaphene, which is incorrect. EPA Method 8080 at the time
provided for reporting “total toxaphene” or "apparent toxaphene". EPA
Region 4, Georgia EPD, and Hercules changed this analytical method through
an agreement in 1991 to reporting toxaphene and "some other product". The
analytical method developed was called the "Toxaphene Task Force" (TTF)
method, and after further changes in 1997 called the "Hercules Protocol".
The OIG called the method EPA (Region 4) Method 8081. At the meeting in
1991 where the agreement was struck between EPA Region 4, Georgia EPD, and
Hercules, all parties agreed that they had previously tested for apparent
toxaphene that reports all chlorinated camphene present, including what is
now called "degraded" toxaphene, which is the same as toxaphene manufactured
but now present in different amounts of the individual chemical components.
The EPA OIG discussed the changes made to EPA Method 8081 by EPA
Region 4 and how toxaphene in soil was underestimated, and out rightly not
reported when known to be present.
"However, EPA (Region 4) Method 8081 is not effective for detecting
degraded toxaphene (i.e., “weathered” toxaphene) in environmental samples
(e.g., soil, water, fish). For demonstration purposes, chromatogram 3A below
is a known chromatogram of toxaphene degradation products in soils. When
chromatogram 3A is compared by EPA Method 8081's identification criteria for
technical toxaphene, chromatogram 3A obviously does not have the 22 same
late eluding peak profile (i.e., the peaks after 29 minutes) as the
technical toxaphene standard. Therefore, a match is not made and the
presence of toxaphene is not reported by the laboratory, even though
specific toxaphene congeners (e.g., Hx-Sed and Hp-Sed) are known to be
present. This example demonstrates the manner in which EPA (Region
4) Method 8081 fails to detect toxaphene degradation products (i.e.,”weathered”
toxaphene or individual toxaphene congeners) in environmental samples."
The OIG’s observation that toxaphene was present when none was
reported by the TTF and Hercules Protocol methods is the same conclusion
other studies have reached and confirmed though analysis. The OIG suggested
that the observed compounds might be “toxaphene breakdown products", but
many of the prominent chlorinated camphene (PCC) found in the front half of
the chromatogram are associated with unmodified toxaphene or PCC as
manufactured by Hercules.
The EPA Region 4 chemist, who also participated in the
development of the TTF method, noted that the "latter peaks" in samples were
decreased and the "early peaks" were increased in environmental samples from
Brunswick, and that the TTF method may seriously underestimate the true
concentration of toxaphene.
The Georgia Environmental Protection Division chemist that participated in
development of the TTF method noted that unknown peaks not quantified may
have been toxaphene related and the total area method was not used when the
TTF method was applied.
EPA Method 8081 requires that results report total toxaphene present,
which was not done at Altama Elementary School. It is very unusual that
analysis is conducted and chemical compounds present are not reported, as
with the TTF method. Appropriate analytical methods, intended to protect
human health and the environment, include the reporting of unidentified
compounds when they are encountered.
Dr. R. Kevin Pegg, the community's Technical Advisor provided by
an EPA Grant, summarized the analytical methods used in Glynn County,
Georgia as follows:
Total Area Method
This is the basic method required by the US EPA for chemicals
with multiple congeners. It detects technical, weathered and biological
grades of toxaphene, as well as the off-grade product and manufacturing
residue forms. Basically, all of the possible toxaphene chemicals are
detected and added together to quantify total toxaphene. This method was not
used by the EPA in Brunswick, Georgia, but is used at other EPA sites in the
United States and by other governments and researchers around the world.
Toxaphene Task Force Method
This method was developed by EPA Region 4 in Atlanta, Georgia,
with Hercules Inc., and the State of Georgia. While gas chromatography is
still used, only a few of the chemicals specific for technical toxaphene are
used in the analysis. Even if other toxaphene chemical congeners are
present, they are ignored. The toxaphene task force method (referred to as
EPA Method 8081) detects technical grade toxaphene as well as the total area
method; however 8081 does not detect all off-grade products, does not detect
some forms of manufacturing residue toxaphene, and can only detect weathered
toxaphene in the first few years after placing in the environment. The TTF
method does not detect toxaphene after it has been in the environment for
several years, and it does not detect biological toxaphene. The TTF method
is apparently used only in Glynn County Georgia and nowhere else in the
world. The method is not recognized by other governments or by researchers
as a useful method because it under-reports the actual toxaphene
GC negative ion mass spectroscopy
This technique, called the NIMS method, can detect all forms of
toxaphene and is a widely respected method with a high degree of scientific
merit regarding the interpretation of results. It is especially useful for
detecting biological forms of toxaphene accumulation.
- Slide: Altama Elementary Sampling Results... The three congener
method the OIG warned not to use is presented under Simon/Manning. The EPA
"The other toxaphene degradation congeners of principal concern for the
human health evaluation (e-g., p26, p50, and p62) would only become the
dominant congeners upon the subsequent metabolism of this microbially
degraded toxaphene (e.g., Hx-Sed and Hp-Sed) by higher organisms (e.g., fish
or humans). Therefore, if the EPA or PRP (Potentially Responsible Parties)
test a site for only the p26, p50, and p62 congeners, the EPA or PRP will
significantly under estimate the amount of contamination by toxaphene
degradation products at the site."
It is notable that EPA Region 4 continues to advocate for
toxaphene analytical methods that will underestimate or fail to detect the
chemicals of concern present. Obviously, the toxaphene on school property
and in the water has not been degraded by the metabolism of fish or humans.
EPA Region 4's introduction of Simon and Manning PRGs is meaningless to the
discussion and meant to confuse the BOE. This is EPA Region 4 implementing a
method the OIG specifically said not to because it would under estimate the
- Slide: Drainage Ditch … The EPA has never explained how toxaphene
crossed a 6 foot deep ditch and went hundreds of feet onto school property.
As noted previously, there were two removal actions on school property. The
one that extended along the ditch and to the playground was not included by
the EPA. Contrary to the contentions of the EPA, toxaphene contamination
was found in 1995 up to and abutting the school playground, which the GEC is
cognoscente and a factor in our request for retesting the school (See
Attachment A). School property was tested after the removal action and
levels up to 84 ppm remained. Notable is that the EPA presentation excluded
this area from the removal action presented to the BOE, which further
emphasizes the need for retesting the school. It is unknown why EPA Region
4 would withhold information about the removal action and the extent of
contamination on school property. The OIG interviewed two experts that
independently estimated the inappropriate method used on school property
would report around 10% of the toxaphene present, which leaves doubt about
the protectiveness of the cleanup.
- Slide: 2005 Office of Inspector… EPA Region 4 made a gross
misrepresentation of the OIG findings, and attempted to re-write history the
way EPA Region 4 wants it to read. The GEC presented 128 concerns about the
remediation of the Hercules 009 Landfill Superfund Site. The OIG addressed
only 3 of the concerns. One of the 128 the GEC did raise concerns about was
retesting areas previously tested by the inappropriate method. As noted
previously, the EPA OIG advocated for testing soil when there were doubts
about the testing conducted previously. As EPA Region 4 noted, risks were
to be evaluated, which cannot be completed without identifying chemicals of
The EPA OIG noted:
"When toxaphene contamination is suspected, the groundwater and soil
analyses should test for Hx-Sed and Hp-Sed because they would be the
dominant toxaphene degradation products."
"In my opinion, the published science is clear that the dominant congeners
generated by the microbial breakdown of technical toxaphene in soil
are Hx-Sed and Hp-Sed with the other toxaphene congeners being present at
much lower levels. Therefore, if the EPA or the potentially responsible
party (PRP) are testing to determine the nature and extent of the
contamination at a site by toxaphene degradation products, the dominant
toxaphene congeners in the soil or groundwater samples will be Hx-Sed
EPA Region 4's contention that the OIG focused on only water
appears to be intentionally misleading. The OIG noted extensively that EPA
Region 4 was steadfast in their refusal to report all chemicals present and
has engaged in reporting only some of the chemicals known to be present
since 1993, which is prior to the testing of Altama Elementary school by the
three parties (EPA Region 4, Georgia EPD, and Hercules) that developed the
The OIG noted:
"Unfortunately, EPA Region IV and I continue to disagree as to whether
environmental testing for toxaphene degradation products by the GC/NIMS
methodology should include Hx-Sed and Hp-Sed. Region IV does not agree with
the OIG's stated opinion that Hp-Sed and Hx-Sed congeners need to be
definitively determined in environmental testing for toxaphene degradation
- Slide: 2006 Groundwater… Again, EPA is implementing Simon &
Manning, even though the OIG said it would underestimate amount present.
- Slide: Toxaphene Exposure… EPA Region 4 presented irrelevant
information about toxaphene exposure in the Netherlands. Unlike the
Netherlands, the school is sitting next to a Superfund Site containing the
manufacturing wastes from the production of toxaphene with documented
releases and failures to control migration to drainage ditches and school
property. Furthermore Toxaphene was manufactured in Brunswick and the
wastes, including dioxin, were disposed in the landfill. It is all the
manufacturing waste chemicals that are a concern, and not just technical
toxaphene. The landfill contains toxaphene manufacturing wastes and
off-grade product that will have much different chemicals ratios and
contaminants than the toxaphene pesticide sold for agricultural use. For
these reasons, it is imperative to test for and report all chemicals
- Slide: Re-evaluation of Site Risks 1.) EPA Region 4 recalculated
risk from toxaphene and published it as Simon & Manning. The OIG explicitly
said the calculations should be provided. The GEC asked for the
calculations from EPA Region 4 and they could not produce the calculations,
nor would the authors. The GEC has this correspondence from EPA Region 4.
2.) EPA Region 4 claims prevalent congeners (Hx-Sed and Hp-Sed,
or toxaphene with 6 and 7 chlorines attached) are of lesser concern because
they are eliminated from the body quickly. No data in support was
presented, but there is a lot to the contrary.
3.) EPA claims there is no screening criteria for prevalent
congeners, which is incorrect. Prior to the meeting in 1991 when an
agreement was made to change EPA Method 8081, the parties agreed previous
testing did report "total" or "apparent toxaphene," which did report all
toxaphene chemicals present. Furthermore, the method advocated by the OIG,
Gas Chromatography - Negative Ion Mass Spectroscopy (GC-NIMS) has been used
in Glynn County for fish and water since at least 2000 and has been
identifying and quantifying the very chemicals EPA Region 4 claims there are
no screening criteria. Under the Performance Standards Act, scientifically
accepted and peer reviewed analytical methods can be used by the EPA. In
the case of NIMS, the EPA has been using the method for over 20 years and
the results extensively published in scientific peer reviewed journals. EPA
Region 4 inferred that since research is being conducted about analytical
methods that testing cannot be done at the school, which is misleading and
outright wrong. The presentation concerning risks appears to be intended to
baffle and confuse the BOE concerning the OIG findings, recommendations, and
appropriate methods to test the school to definitively determine risk to
- Slide: Region 4 Response… EPA Region 4 claims weathered toxaphene
poses less risk, but produced no data in support. Available science
contradicts EPA Region 4's position, and identifies the chemicals being
excluded and not reported as being MORE toxic than the technical toxaphene
mixture. The ATSDR Toxicological profile for Toxaphene states:
"Toxaphene components A and B have been isolated and found to possess
toxicity that is 6 and 14 times greater, respectively, than the technical
toxaphene mixture as measured by comparing intraperitoneal LD50 values in
mice (Casida et al. 1974). Toxicant A has been identified as a mixture of
2,2,5-endo,6-exo,8,8,9, 10-octachlorobomane and 2,2,5-endo,6-exo,8,9,9,10-
octachlorobomane (Matsumura et al. 1975; Turner et al. 1975) and toxicant
B has been identified as 2,2,5- endo,6-exo,8,9, 10-heptachlorobomane (Casida
et al. 1974). It has further been determined that toxicant B and four of
its derivatives, each with an additional chlorine atom at position
3-exo,8,9, or 10, may be responsible for the bulk of toxaphene’s acute
toxicity (Saleh et al. 1977)."
Important to note is that the EPA OIG identified toxicant B, Hp-Sed,
as being one of the most prevalent chemicals present. Attachment C
identifies the congeners that are accepted as being technical toxaphene,
which do include the very chemicals EPA Region 4 continues to advocate for
not reporting, even when they are known to be present. As Attachment C
demonstrates, EPA Region 4 has arbitrarily excluded chemical components of
the technical toxaphene mixture with 6 and 7 chlorines attached (Hp-Sed and
Hx-Sed), which are the chemical components identified by the OIG as most
prevalent, and as the most toxic by ATSDR.
Contrary to the contentions of EPA Region 4 that these chemicals
pose less risk and lesser concern, ATSDR found:
"Information on the toxicities of components in the original mixtures is
limited to perhaps 10 congeners, the most familiar being the appreciably
toxic and persistent toxicant A and toxicant B."
The ATSDR Toxicological profile for Toxaphene states the
following about the toxicological effects of toxaphene on children:
"Pregnant women, fetuses, nursing infants, and very young children may be at
greater risk of adverse health effects from pesticide exposure than the
general population (Calabrese 1978). Exposure to organochlorine
insecticides, such as toxaphene, may adversely affect reproductive
physiology (i.e., hormonal balance) in certain women (Calabrese 1978).
Embryos, fetuses, and neonates up to age 2-3 months may be at increased risk
of adverse effects following pesticide exposure because their enzyme
detoxification systems are immature (Calabrese 1978). Animal studies suggest
that detoxification of the toxaphene mixture may be less efficient in the
immature human than the metabolism and detoxification of the single
components such as toxicant A or B (Olson et al. 1980). Infants and children
are especially susceptible to immunosuppression because their immune systems
do not reach maturity until 10-12 years of age (Calabrese 1978)."
"Animal studies suggest that detoxification of the toxaphene mixture may be
more inefficient in immature animals and possibly also in children than the
metabolism and detoxification of the single components such as toxicant A or
"Humans living in areas surrounding hazardous waste sites may be exposed to
toxaphene via ingestion of contaminated water or even ingestion of soil,
particularly by children. Inhalation exposure to toxaphene via
volatilization from contaminated water or soil may also occur."
"Subsets of the human population that may be unusually susceptible to the
toxic effects of toxaphene include pregnant women, their fetuses, nursing
babies, young children, people with neurologic diseases (particularly
convulsive disorders), and individuals with protein-deficient diets. Others
at increased risk include people with hepatic, cardiac, renal, or
respiratory diseases, those with immune system suppression, and those
ingesting alcohol or consuming therapeutic or illicit drugs."
Slide: Conclusions… 1.) EPA Region 4, based upon the use of previous
testing from 1993 the OIG found inappropriate, concluded there is no site
related impact. Relying on an analytical method known to exclude the
chemicals that are most prevalent and most toxic underscores EPA Region 4's
effort to prevent testing that will report all chemicals present.
2.) EPA Region 4's claim that toxaphene does not poses a health
risk is not supported by data but rather a flimsy argument that there is no
risk to students if unknown chemicals are present. Risk cannot be
determined until the school is tested and all chemicals present are
In closing, the cleanup of the Hercules 009 Landfill Superfund
Site was based upon cleaning up toxaphene to 0.25 ppm would also cleanup the
other chemicals such as dioxin, a waste product from the manufacture of
toxaphene. If all the toxaphene chemicals are not reported, the other toxic
chemicals in the toxaphene manufacturing wastes will not be cleaned up. The
first step in protecting children is to report all chemicals present on
Altama Elementary School property. In addition, sufficient information
should be collected to assure the Glynn County BOE that drainage ditch
maintenance can be conducted without recontamination, and school property is
not encumbered by chemical contamination.
Keith A. Maruya, Wakeham, S.G., Analysis of Toxaphene Residues in
Sediment and Fundulus from Terry/Dupree Creek. Skidaway Institute of
Oceanography, University System of Georgia. July 31, 1998.
Keith A. Maruya. Analysis of Toxaphene Residues in Fin- and Shellfish
from Terry/Dupree Creek, Glynn County, Georgia. Skidaway Institute of
Oceanography, University System of Georgia. June 16, 2000.
Health Consultation - Terry Creek Dredge Spoils Areas/Hercules Outfall
Brunswick, Glynn County, Georgia. Agency for Toxic Substance and Disease
Registry. December 7, 1999.
Analytical and Environmental Chemistry of Toxaphene. Pergamon Press.
Telephone Memorandum to Lavon Revells, US EPA; from Dan Keck, Black &
Veatch Waste Science, Inc. July 27, 1995.
Telephone Memorandum to Gary Bennett, US EPA Environmental Services
Division; from Kristen Lombard, Black & Veatch Special Projects, Corp.
May 16, 1996.
Memorandum from Danny Reed, Georgia Environmental Protection Division;
to Dr. Randy Manning, Georgia Environmental Protection Division, October