received for review the Work Plan for Off-site Soil Sampling, LCP Chemicals
Superfund Site, Brunswick, Georgia, dated August 13, 2004. In an earlier
newsletter, a draft plan (dated May 7, 2004) was received and reviewed.
The current plan provides increased sampling coverage compared to the
earlier draft plan. Overall, the sampling plan should provide information on
the presence or absence of toxins in the neighborhood.
The LCP Chemicals superfund site is a 550-acre site along the Turtle
River in Glynn County Georgia. The site was the location of several
industrial chemical plants producing bleach, petroleum products, or paint.
These operations left the area heavily contaminated with known chemical
toxins in ground, water and air pollution. The site is in the process of
being cleaned with Federal and State oversight. One unresolved issue for the
local community is the extent of contamination from air pollution and
surface runoff. Various industries at the site used "stacks" and fans to
vent chemical processes directly into the air. Most pollutants travel only a
short distance before settling back to the ground, 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."
[emphasis added; Section 7.1.3, airborne redeposition (page 42,
Operable Unit One Upland Soils and Estuary March 2002)].
In May 2004, the Environmental Protection Agency along with the site
responsible parties released a draft sampling plan for the adjacent
neighborhood. That draft plan contained several technical flaws. Many of
the samples were to be taken on LCP property north of the neighborhood.
Testing grids were widely dispersed, with the samples likely not
representative of actual toxins, if present. There was a lack of clarity in
the draft plan as well. It appeared the plan was merely to "prove" earlier
studies were valid, rather than actually look for site chemicals. The draft
plan was objected principally because the neighborhood was not sampled
thoroughly enough to determine if toxins may be present.
The Current Testing Plan
The Work Plan summarizes past sampling activities both on the LCP site
and in the neighborhood next to the site (the ARCO neighborhood), and
outlines additional testing. According to section 2.5 of the Work Plan this
study is designed to answer the question: "Are there levels of
mercury, lead, arsenic, Aroclor-1268 (including a full scan of PCBs), and
PAHs above Remedial Goal Options (RGOs) in surface soils of areas to the
southeast of the LCP site."
Surface soils are targeted since any chemicals in the neighborhood are
likely from airborne contamination. The ARCO neighborhood is directly
southeast of the LCP site. For the main contaminants the Remedial Goal
Options (RGO) are:
RGO (Parts Per Million)
(Derived from table in section 3.4 of the work plan).
The current plan still uses a two-phase approach as described in the
previous draft plan. However, the sampling pattern is completely different
in this version.
Under this testing plan, there is an initial round testing twenty
composite samples taken on a grid pattern beginning on the edge of the LCP
site and extending south and east. Each composite is made up of five
discrete samples blended together for testing purposes. A sampling grid for
this study is about ¼ of a city block.
Two different types of samples will be taken, a 0-3 inch deep sample for
the Agency for Toxic Substances and Disease Registry (ATSDR) public health
assessment, and a 0-12 inch deep sample for the EPA’s risk assessment. The
ATSDR study is much more relevant to public exposure in the neighborhood
than EPA’s study. If material did arrive at the neighborhood from airborne
dispersion it would not be 12-inches deep in the ground, it would be very
near the surface. The EPA’s sampling method represents sample dilution by
mixing uncontaminated deeper soil with any possibly contaminated materials
on the surface.
In this version of the plan the samples are adjacent to one another and
grouped from the fences outward, a better sampling pattern. Further, each of
the discrete samples used in the composite is retained in this Work Plan
version for verification testing. That can allow for elimination of
false-positive or false-negative composite samples.
Additional tests are performed in the event of LCP site chemical
detection in the neighborhood. This second phase of testing would look at
property in the neighborhood east and south of the first phase of detection.
The Work Plan defines a "conceptual site model" in section 2.3. Under
this model "potential impacts to offsite areas should be minor and/or
limited to areas in the immediate vicinity of the Site." However, this
conceptual site model is apparently not backed with any modeling studies. No
observations are cited in the text. There is no scientific basis for the
assumption that "impacts to offsite areas should be minor..." At this time,
without the neighborhood sampling, the conceptual site model is only wishful
thinking on the part of the EPA and responsible parties.
There is a large pond on the western edge of the sampling plan nearly due
south of the LCP site. This pond was likely in the path of plumes from LCP.
Residents fish this pond and the sediments should be included in the
testing. There is no planned testing and this oversight should be corrected.
At a bare minimum, a computer air dispersion model should be provided
showing this pond is excluded from receiving past plumes from LCP.
The ATSDR’s sampling of 0-3 inches of surface soil for a health
assessment should produce valid data for the neighborhood. This testing plan
is more comprehensive than the draft Work Plan received previously. The
selection of composite testing grids, although awkwardly numbered, seems
consistent with potential airborne plumes. The testing methods are fully
explained in this Work Plan, and the testing goals are actually described.
Overall, the plan seems likely to provide relevant safety information for
the neighborhood, if implemented as written.
Written by R. Kevin Pegg, Ph.D.; edited by Dr. Mary S.
Saunders. Copies of the newsletter are available from the GEC, at the Glynn
County library, or at www.Enviro-Issues.com on the Internet.