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Inspector General’s Final Response to EPA’s Plan to Continue  Underestimating Toxaphene

Dec 2006 Technical Assistance Report:


We received for review the response from the EPA’s Office of Inspector General (OIG) to EPA’s Region 4 Administrator regarding the analysis of toxaphene at the Hercules 009 Landfill Superfund Site. Previously the OIG had found that EPA Region 4 was using methods that underestimated toxaphene in soils, groundwater and animal tissues. As part of that finding EPA Region 4 was to utilize methods in keeping with the state-of-the-art in toxaphene testing, rather than decades-old methods that had been used.  EPA Region 4 provided a response to the OIG that raised a number of issues.  Principally, EPA Region 4 relied heavily on a position paper prepared by former EPA employee, Ted Simon, and Georgia Environmental Protection Division toxicologist Randall Manning, on weathered toxaphene (we reviewed the Simon and Manning paper in a prior newsletter).

   The OIG’s response is complex and contradictory. The OIG continues to argue that more research is needed for the toxicology of toxaphene. The report states clearly that much more work on analysis is needed, and urges EPA Region 4 to work directly with the EPA’s Office of Research and Development to analyze toxaphene. And, the response urges transparency in the manner in which EPA Region 4 calculates the remediation goals for the Hercules 009 Superfund Site.   Then again, the response states that they are dropping the matter, as “…you [Region 4 EPA] have adequately addressed the recommendations we made.”

   The accompanying review by Michael Wilson, a former scientist with EPA that worked for the OIG, is not very detailed. It relies almost entirely on the documents provided by EPA Region 4, and, according to the cover letter, was provided pro bono since the author is no longer at EPA. Regarding the Simon and Manning paper the author indicates it is the best science available because it is the only science available.  Further, Wilson could also not calculate a reference dose using the Simon and Manning paper.  Nonetheless, the author concludes that EPA Region 4’s burden of proof is met, despite the fact that he, like everyone else in the scientific community, is clueless as to the meaning and origin of the numbers cited by EPA Region 4 in the Simon and Manning paper.

   Essentially, one EPA employee has validated other EPA employees’ unscientific and irreproducible work. The letters infer no additional effort will be made on understanding toxaphene migration in Brunswick until after 2008. Note also, this marks the final report on the 009 Superfund site under the Technical Assistance Grant.


TECHNICAL ASSISTANCE REPORT    "This project has been funded wholly or partly by the U.S. Environmental Protection Agency under Assistance Agreement Number V994050-92-0 to The Glynn Environmental Coalition, Inc. The contents of this document do not necessarily reflect the views and policies of the U.S. Environmental Protection Agency, nor does mention of trade names or commercial products constitute endorsement or recommendation for use.”,     A full copy of this report and other information on the 009 site can be obtained by contacting the GEC at P.O. Box 2443, Brunswick, GA  31521


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