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
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
Without testing during and
after the remedy there can be no assurance to the public that the threat is
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 www.enviro-isues.net 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."