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009 Remedial Design: Questions and Responses
April, 19



      The 009 Landfill in Brunswick, Ga. contains manufacturing waste from production of the pesticide toxaphene. Toxaphene is a biocide that was used to control agricultural pests prior to the Federal Government canceling its use in the early 1980’s for environmental concerns.

      The 009 landfill was created out of a "borrow pit" used to construct nearby Spur 25 highway.  Manufacturing waste, called "sludge," was placed in the borrow pit. The sludge contained high concentrations of toxaphene pesticide and toxaphene-related chemicals. The landfill was closed in 1980 when toxaphene appeared in a nearby creek—a violation of Hercules, Inc. permit. Since then toxaphene has been found along the highway, in an adjacent neighborhood, and on unused school property near the landfill. The majority of the off-site material is now in a temporary landfill cell on-site.

      The Environmental Protection Agency (EPA) and the responsible party – Hercules, Inc.—signed a Record of Decision (ROD) agreeing to cleanup the site. However, the final plan for cleanup differs in substantive ways from the original requirements of the ROD. Most importantly, there appears to be no quality control procedures in place for assuring the public that the toxaphene is fully impounded. The public received the first actual view of the cleanup at a meeting on March 24, 1988, after the EPA had given approval for the changes in the design. The following questions were raised.

      Why worry about this at all? Isn’t it all just underground? Toxaphene was banned for two reasons: it increases cancer in laboratory animals and it is very persistent in the environment.  There is a tremendous amount of toxaphene contaminated waste out there—thousands of cubic yards of waste. With a half-life (time to degrade by 50%) of at least a decade there will be carcinogenic waste for several human lifetimes. It is important to fully treat this waste and make it harmless.

      The EPA says the toxaphene is not in the water. Why be concerned if it isn’t moving? The EPA also acknowledges that toxaphene is difficult to analyze, and the mutagenic and carcinogenic compounds are not known. Toxaphene is not one chemical—it is several hundred different chemicals. Each of these chemicals has a slightly different solubility in water. Right now, the test for toxaphene uses only one or two of the 600+ chemicals in the mixture for identification. During a civil trial both Hercules scientists and their subcontractors testified that they could not always identify toxaphene in samples. Several times in the last few years studies were invalidated do to problems in measuring toxaphene. At a meeting during 1997, EPA scientists acknowledged that toxaphene analysis was error-prone and agreed to look for better methods of analysis. Overall, toxaphene measurement is qualitative not quantitative.

      Toxaphene is a real threat to groundwater at this site. Relying on toxaphene monitoring is risky; the best solution is to fully treat all toxaphene in the ground to assure groundwater will never become contaminated.

      What does the Record of Decision require for proper treatment? There are three issues:

      surface soil treatment, subsurface soil treatment, and groundwater. The surface soil target for toxaphene is 0.25 parts-per-million (ppm). The subsurface soil target is 76 ppm. For groundwater, any level of toxaphene above 0.003 ppm after treatment is considered significant. The ROD details a combination of surface soil excavation, in situ stabilization and capping to meet these goals.

      Where did these "goals" come from? The levels were set based on health and environment models. The scientific establishment still holds that toxaphene is a mutagen, carcinogen and biocide. The mixture is still banned from sale. No new information has become available suggesting that toxaphene is now safe or safer than when the ROD was written. The original health-based risk estimates should be followed during cleanup.

      Why were changes made to the ROD criteria? Initially, EPA and work contractors stated that it was do to "safety concerns" for site workers. However, when asked to justify these concerns by explaining why and how the site could become unsafe, both the EPA and contractors reversed positions and said there was no real threat to workers and the changes were needed because of concrete dilution effects. In fact, Hercules’ contractor plainly stated at the public meeting that the initial tests of the stabilization process failed to reach target levels of toxaphene cleanup, although previous public documents said that they did reach the goals. Later, EPA reaffirmed the changes were needed for safety concerns. The public explanations for the changes are too contradictory for an understanding of why the ROD standards are being ignored.

      How will the cleanup be done? The ROD calls for treatment depths to be confirmed using soil analysis until all areas 76 ppm and higher are immobilized. The EPA’s present plan calls for treatment to be discontinued after reaching the water table—which fluctuates depending on the weather—and does not require sampling for toxaphene performance criteria prior to quitting the treatment.

      Are the ROD goals for surface soil being met? Surface soil treatment has primarily been an off-site issue to ensure that people do not come into contact with toxaphene during their daily lives. Remedial actions following the ROD standards have been accomplished in the neighborhood, the school property, and along Spur 25. The major remaining surface issue is the drainage ditch. The proposed plan will likely meet the surface goals, and testing is not really an issue since surface soil samples are easy to collect.

      Are the ROD goals for subsurface soil being met? Perhaps not. According to the ROD, subsurface soil would be treated to 76 ppm. Because of danger from dust, and release of toxaphene when the sludge is exposed, the ROD calls for in situ (or "in place") stabilization. Prior to treatment the site was to be mapped and all toxaphene plotted on charts based on depth, area extent, and concentration. This was performed. However, these charts are apparently not being used to guide the cleanup. Instead the ROD seems to have been set aside and a new set of standards implemented.

      The standards that have been recently presented to the public indicate that remediation will follow an entirely arbitrary set of rules established by the contractor. The methods may not be "in place" remediation at all and no testing may be performed to assure the public that all of the toxaphene is cleaned up. There appear to be significant grounds for doubting if the cleanup proposed is both scientifically and legally acceptable.

      Are the ROD goals for groundwater being met? According to the ROD, protection of groundwater is through reduction of toxaphene contact with groundwater. The ROD states:

      "Actual or threatened releases of hazardous substance from this Site, if not addressed by implementing the response action selected in this ROD, may present an imminent and substantial endangerment to public health, welfare or the environment." In other words, if the cleanup goal of 76 ppm is not met then the public cannot be assured there is no "imminent and substantial endangerment."

      Without testing during and after the remedy there can be no assurance to the public that the threat is removed.

      Will any testing be done? Although the ROD calls for testing there is no testing protocol in the plans approved by EPA. At a public meeting, the EPA and the work contractors made very conflicting statements suggesting no testing will be done.

      What can happen if the toxaphene is left in contact with groundwater? A set of monitoring wells will be left in place after the remedy, and annual sampling performed. According to EPA representatives this is enough to determine long-term risk. However, these wells will all be placed along the eastern most edge of the site. Since the ROD was developed, there have been a variety of major construction projects in the immediate vicinity that can alter local groundwater flow; for example, a lake is going in directly across Spur 25. These changes were not anticipated or modeled and they can influence local ground water movements. Toxaphene has an extremely long environmental life and there is simply no way EPA can predict where toxaphene will be in the next 50 or so years if toxaphene is left in contact with the groundwater. This is why the original ROD called for immobilization to 76 ppm; any toxaphene that was missed by the immobilization process would rapidly "attenuate" (dilute or breakdown). These changes to the ROD mean that EPA cannot assure toxaphene removal from the Brunswick groundwater.

       "Bottomline?" The EPA has accepted substantial changes to the ROD. These changes reduce the

      effectiveness of the ROD in assuring the public that toxaphene is immobilized. The actual cleanup

      appears to be dictated by the amount of rainfall during the cleanup and how much toxaphene is

      actually left seems to be only a rough guess.


Written by R. Kevin Pegg, Ph.D.; edited by Dr. Mary S. Saunders. Copies of the report are available from the GEC, at the Glynn County library, or at  on the Internet. 

"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."



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