fall of 1992 the Environmental Protection Agency met with the citizens of
Georgia and stated these facts from the Remedial Investigation:
toxaphene is a health concern at the 009 landfill,
toxaphene migration through surface runoff and groundwater can occur,
toxaphene was offsite on school property and in the neighborhood.
EPA then proceeded to describe the results of the Feasibility Study:
removal and incineration were impractical,
toxaphene was too dangerous to excavate,
in situ stabilization and capping were the best alternatives.
would be studies to determine the depth of toxaphene migration in soils
groundwater, and studies would determine the best conditions for
immobilization and capping.
backup plan was also included. In case the experimental in situ plan was not
toxaphene would be extracted chemically and only clean dirt left behind.
extensive onsite and offsite study was performed. Offsite areas were cleaned
consolidated onsite. A study was conducted and the results suggested in situ
should work. At that
though, the thorough cleanup promised the community was derailed and a plan
put in place
was much less than promised. As result, there are no assurances that this
site is completely
for the decades originally promised.
Toxaphene is highly toxic to every species tested from microbes, to water
bugs, to insects, to
to dogs, to humans. These toxic effects range from poison, to mutation, to
tumors. There is
doubt of this, and the effects are felt even when toxaphene is diluted
nearly a billion times.
Because of this, the EPA originally called for all toxaphene to be handled
underground to prevent
exposure in the air. This did not occur, the site was excavated even though
it was dangerous
so. According to a study performed in 1995 by Hercules with EPA oversight,
the treatment at
009 landfill was to continue past the sludge to immobilize toxaphene already
groundwater beneath the site. Treatment documents indicate that this did not
According to EPA/Hercules, treatment encompassed all of the major sludge
bands, however this
appears doubtful as well.
Treatment efficiency can only be achieved if rainwater and groundwater
cannot enter the treated
This is dependent on two things, monolithic solidification and a rain
is doubt that monolithic solidification was used at the 009 site. In the
the site would be solidified using augers, pumped cement, and overlapping
techniques producing a single monolith by fusing treated cylinders. Based on
diagrams, visual description and records there is no overlapping of
treatment cells to produce a
monolith. An initial pit was excavated and the contents placed above ground.
This hole was then
with dirt from another freshly excavated area while concrete was mixed using
device. This process was repeated using the freshly excavated hole. In order
to be a true
monolith, the equipment should fuse adjacent treated cells. There is no
indication this occurred.
Therefore, there will be cracks or gaps between each treatment cell that
water may percolate
through and continue to contaminate area soils. Further, individual blocks
independently, placing additional stress on the cap.
Technically the method used is a form of ex situ processing. There are
methods of ex situ
processing of excavated wastes that are enclosed and generate no aerosols.
However, the method
actually created the most dust and toxaphene release possible for any
considered. This was exactly the opposite treatment conditions promised by
acknowledges repeatedly that this method of above ground mixing is not safe.
The reason cited
the change: this method is less expensive and faster.
of treatment is insufficient and much less than promised. There are three
dimensions: north to south length, east to west width, and the depth of
treatment. The length and
treatments appear to be sufficient; however, the depth of treatment likely
missed much of
eroded toxaphene. In March of 1995 EPA published reports showing the
depths. These charts were based on extensive studies and used the Record of
Decision criteria of
parts per million as the cleanup target. EPA/Hercules ignored these charts
when performing the
cleanup, instead using an unscientific method of visual identification of
sludge. A set of charts
"Record Drawing of Completed Landfill Cross Sections" dated September 1999,
provided. Comparing the 1999 actual treatment with the 1995 actual toxaphene
EPA/Hercules may have missed large amounts of toxaphene sludge during
have a reference datum for "MSL" or Mean Sea Level. References to the ground
of toxaphene are given as distances above MSL. For example, in cell 4, the
1995 chart of
toxaphene levels shows four sludge bands at 22, 18, 12, and 9 feet above
Mean Sea Level.
However, the 1999 treatment chart shows that treatment stopped at 12 feet
MSL, at the bottom
third lowest band, thereby missing one entire sludge band (the 9 foot MSL
band) shown on
1995 chart (“raw” data collected during actual construction also show that
missed). Since EPA/Hercules did not perform the ROD-required soil testing,
these charts and
spreadsheets are all we have to use. Based on these, it appears that
EPA/Hercules failed to treat
the sludge. Comparing other cells also reveals high levels of untreated
present and in contact with groundwater.
original specification was for a solid thick clay cap. This type of cap is
well known to provide
waterproof tops for landfills. Instead a loose mixture of waste and cement
was used. During a
preclosure inspection the EPA told the Glynn Environmental Coalition the cap
standards." RCRA- the Resource Conservation and Recovery Act- provides a
specifications for landfill linings and tops. The GEC was promised
information for which RCRA
standard was met by the cap. To date the information has not been provided.
When the change
made an Explanation of Significant Differences (ESD) was issued stating
field tests would
the 3% cement cover was equivalent to the clay cap before it was used.
limited data given suggests the cement cap could be an order of magnitude
less efficient than the
original clay cap provided for by the ROD.
Finally, the Record of Decision clearly calls for treatment of the ditch
adjacent to the site to
prevent water influx from the bed of the ditch to the landfill cell. This
has not occurred. The
treatment runs very close to the eastern edge of the drainage ditch. During
high water levels,
should migrate from the ditch to the treated cells. A culvert was to inhibit
action. Plans were drawn up, but never implemented. These ROD criteria have
not been fulfilled.
“monolith” would be a single concrete sheet completely replacing the old
sludge cells. If
stripped away the covering dirt this site would look from above like a
cement globs, sitting on top of sludge and toxaphene contaminated soil.
other EPA site an in situ treatment is failing (Shattuck Chemical; Denver
Colorado). In situ
been widely implemented in the last few years, but this is still an
experimental treatment and
much is known about long-term stability. However, the Shattuck site is
failing after only two
apparently because it was under engineered for the local weather conditions.
is an element of uncertainty in heavy construction over wide areas. No site
can be perfectly
or the concrete perfectly mixed. But at 009 there were so many changes with
thought or testing that the final treatment is inexact to the point where it
is impossible to
determine if the treatment is under engineered or not.
final report card on this treatment gives EPA/Hercules an overall "D" grade.
cleanup was fairly thorough, but only due to a civil lawsuit by the
neighborhood and constant
diligence by the School Board. Some offsite areas were poorly tested,
particularly the transport
So a "B" grade for offsite work is fair.
onsite treatment it appears the EPA failed to provide a product that meets
RCRA standards for
bottom and top, failed to prohibit water infiltration, failed to meet ROD
goals for the
drainage ditch, and, most importantly, failed to immobilize all of the
sludge. It appears likely this
treatment could fail and allow significant water infiltration in less than a
generation. All of these
for an "F" final grade for onsite treatment. So an overall “D" or "D-" seems
as other communities are finding, this site is likely to continue to be a
problem after EPA has
"completed" its work. An outside review on the techniques and monitoring is
surely called for at
poorly treated waste pile. The monitoring plan presently in place, in
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."