Report of Off-Site Soil Sampling, LCP Chemicals Superfund” dated April 2005,
and an ATSDR Public Health Consultation based on the report were received
for review. The Environmental Protection Agency Data Report document bears
the warning legend: “DRAFT: Do not cite or quote” making it difficult to
comment directly on the data or discussion contained within the report.
Overall the report indicates there is no future cause for concern among
residents. The testing shows no plumes of chemicals moving from on-site into
Chemicals Superfund site was the location of several industrial chemical
plants producing bleach, petroleum products, or paint. These operations left
the area contaminated with known chemical toxins from ground, water and air
pollution. The 550-acre site of uplands, buildings and marsh front along
the Turtle River in Glynn County Georgia is in the process of being cleaned
with Federal and State oversight.
emergency cleanup several years ago soil testing data in the neighborhoods
surrounding the site indicated a potential problem. Site chemicals appeared
in a significant number of samples, although in amounts too low to be
harmful. The Environmental Protection Agency promised residents at that time
a more thorough study would be conducted to verify or eliminate the
possibility of harmful levels off-site.
industries at the site used “stacks” and fans to vent waste chemicals into
the air, and the ARCO neighborhood is in the pathway of any possible
contamination. In an earlier evaluation the Environmental Protection Agency
noted: “It is very likely that this airborne deposition traveled with
prevailing winds, and mercury was therefore distributed over a potentially
rather large area. The prevailing wind direction for this area is from the
northwest, away from the marsh area.” [ Section 7.1.3, airborne redeposition
(page 42, Operable Unit One Upland Soils and Estuary March 2002)].
current testing is that promised study. The study was designed with
oversight from agencies such as the Agency for Toxic Substances and Disease
Registry (ATSDR), State of Georgia Environmental Protection Division (Ga EPD)
and Glynn County Health Department, also with input from the Glynn
Environmental Coalition. Several meetings were held during this process to
garner public input as well.
were two possible patterns of toxin occurrence that could result from nearby
operations. One would be a plume extending from the plant site into the
neighborhood whereby properties closest to the fence line would have the
highest rates of contamination. A second pattern is often called
“heterogeneous” contamination, meaning that “hot spots” of contamination
occur randomly over an area. A “block-by-block” approach was taken for the
testing where each block of homesites in the area was tested by subdividing
into grids and using composite sampling. This type of grid would detect
either the plume or “hot spot” contamination, with the added benefit that
each block could be told their property had been tested and found clean, or
remediated on a case-by-case basis. The study was divided into two phases,
with the nearest homesites tested in phase 1, and the phase 2 testing only
occurring as needed.
Composite sampling takes several
individual samples and mixes them into one sample for testing. Generally
composite sampling is more effective for plume-type contamination than for
the “hot-spot” type of contamination since hot spots can be diluted with
uncontaminated soil using composite samples. Since the plume-type of
contamination was the most likely form for airborne deposition into the
neighborhood composite sampling made sense. Had any of the composites
samples shown evidence of “hot-spot” type contamination the GEC would have
insisted on resampling using the discrete single-sample methods.
Soil samples were tested for
Mercury, Lead, Arsenic, PAH (chemicals that can cause cancer), and PCB.
There were two types of samples: shallow surface samples from the upper
three inches, and deeper surface samples from the top foot. These different
methods were used to satisfy differing requirements for estimating risk used
by EPA and ATSDR. Effort was made to select samples where deposition could
have occurred decades ago—away from trees and structures and with no
evidence of human disturbance or covering over. Residential cleanup levels
for the state of Georgia were used throughout.
Testing patterns were reasonable
and methods to obtain bona fide representative soils appear adequate.
PAH-We would not expect to
find PAH in surface soil samples more than 10 years after airborne
deposition. Aromatic hydrocarbons are volatile, light sensitive, and
digested by soil bacteria. It was no surprise that PAH was not found.
PCB- the presence of
Aroclor-1268 in all of the samples at concentrations up to 440 µg/kg (Table
2) indicates the EPA was correct when stating “It is very likely that
this [LCP] airborne deposition traveled with prevailing winds…” toward
the ARCO neighborhood. The obvious source for this PCB is the site, so the
neighborhood was contaminated, and probably was significantly contaminated
during operations decades ago. At this point in time it is fair to say the
PCB levels are not threatening and no remediation is called for. However,
public health managers should note that long-term residents in this area may
- emphasize “may”- have been exposed in the past to high levels of
Mercury-Levels of Mercury
found are considerably less than the levels set by the state of Georgia for
residential areas. The levels are higher than some studies suggest are safe;
however, this review is not the place for that debate. Mercury levels shown
in Tables 2 and 3 for the neighborhood are below the levels required for
Lead- One composite had a high Lead reading, high enough for concern
at that point in the neighborhood. There is no pattern suggesting a plume of
Lead—the reading is a single “hot spot” of high Lead. EPA’s report argues
for Lead paint chips as the source of the high Lead reading, but they
provide no evidence to prove or disprove that conclusion. We would prefer to
see more Lead testing in this neighborhood.
Heavy metal contamination can
occur in “hot spots” and additional spots could be missed by the grid format
of composite sampling.
Arsenic- Tables 2 and 3
indicate Arsenic is slightly elevated in neighborhood soils, but not at
levels that cause concern. Both the amount and type of Arsenic is important
in determining risk, and these levels are low enough to indicate no further
studies are needed.
Other compounds—No other
compounds were found at levels that raise concerns.
“Is the ARCO neighborhood safe
from LCP toxins?” Yes. Studies are rarely definitive, but this one comes
very close. With the exception of the single Lead “hot spot” --which should
be clarified with a follow-up study-- this study shows that the LCP
Superfund Site will not impact the future health of the Arco neighborhood
by R. Kevin Pegg, Ph.D.; edited by Dr. Mary S. Saunders. Copies of the
Technical Assistance Report are available from the GEC, at the Glynn County
library, or at www.Enviro-Issues.net on the Internet.
"This project has been funded wholly or partly by the U.S. Environmental
Protection Agency under Assistance Agreement Number 1-994850-01-0 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." Volume 10, Number 1,