EPA Region 4 is responding to the
September 26, 2005, Office of Inspector General (OIG) Ombudsman Report,
“Appropriate Testing and Timely Reporting Are Needed at the Hercules 009
Landfill Superfund Site, Brunswick, Georgia”. The OIG found the method
used to analyze and quantify toxaphene was inappropriate and either under
quantified or failed to identify toxaphene present in the sample. The
inappropriate method quantified toxaphene from the 8- and 9- chlorine
toxaphene compounds that are not present after toxaphene enters the
environment and dechlorinates to the 6- and 7- chorine toxaphene compounds
that are environmentally persistent and plentiful in Brunswick. Through a
journal article, the EPA is proposing to change cancer and non-cancer risk
assessments to considering only 3 of the 800+ chemicals in toxaphene,
containing 8 or 9 chlorine molecules, and ignoring all the others.
Toxaphene is a mixture of chemicals, patent-protected by Hercules, that
included, “Any polychloro camphene containing from about 40 to about 75% of
chlorine …,” — i.e., any camphene compounds with between 3 and 10 chlorine
molecules attached — and identified these chemicals as the toxic ingredients
of the invention.
1990, the EPA, Georgia EPD, and Hercules chemists met with others and agreed to change how toxaphene was analyzed, quantified, and defined. The
three chemists were called the "Toxaphene Task Force" (TTF). In 1993 the
TTF changed how toxaphene was quantified in Brunswick, where toxaphene was
manufactured from 1948 to 1980. The OIG used laboratory analysis
chromatograms to demonstrate how the EPA and GA-EPD manipulated data
produced by the TTF method.
The EPA is now in the process of responding to the OIG. The March 21, 2006,
EPA letter to the OIG said the
journal article would be key to their
response, and also mentions Hercules pressuring the European Union,
Brussels, to change their report,
"Investigation into the Monitoring,
Analysis and Toxicity of Toxaphene in Marine Foodstuffs" (MATT). The OIG
relied extensively upon the MATT study. EPA anticipates a final response to
the OIG around June 22, 2006.
of Concern About the EPA’s Article
EPA’s article raises a number of issues about which citizens of Glynn County
should be concerned:
The EPA proposes limiting toxaphene toxicological assessments to only 3
chemicals, with 8 or 9 chlorine molecules, that are rare (or missing) once
toxaphene enters the environment, out of the over 800 in the mixture. The
EPA, using the Toxaphene Task Force method (TTF), quantifies toxaphene by
looking at these same 8- and 9- chlorine toxaphene chemicals. The EPA's
focus on these toxaphene chemicals could be an effort not to retest areas
tested by the TTF method at Brunswick’s six sites, two of which are
Superfund Sites. The OIG did find a lot of toxaphene chemicals with 6 or 7
chlorine molecules in water, soil, and fish in Brunswick.
The EPA’s article claims that since the Inuit of northern Canada don't have
high breast cancer rates, therefore toxaphene does not cause breast cancer.
This claim ignores transgenerational effects and delays caused by time to
move north through the atmosphere, bioaccumulate in animals, and then in
people. Not all toxaphene chemicals move through the air the same, and some
come to the ground before others due to temperature, rain, and other
factors. Also, the toxaphene released in Brunswick, Georgia, was toxaphene
and toxaphene manufacturing wastes that was dumped directly into our estuary
and several landfills around town. Still, the EPA has made an interesting
argument for comparing the Inuit breast cancer rate (the EPA’s background
population) with breast cancer rates in Brunswick.
The EPA’s article mixes atmospherically transported toxaphene fish data from
far northern regions with Brunswick’s dumped toxaphene and toxaphene
manufacturing waste fish data, which have far different ratios of toxaphene
chemicals and different toxicological properties.
4. The EPA’s article promotes toxaphene chemicals that bioaccumulate as
the only ones important to toxicology and ignores toxaphene metabolites
produced by the liver as the body tries to remove the poison. These
metabolites are suspected to be potential endocrine disrupters (act like
hormones in the body). The toxicology of toxaphene is very poorly
understood, and even less in known about the cancer and non-cancer effects
of the metabolites.
EPA, Georgia Environmental Protection Division, and Hercules Inc. were
caught "hiding the poison" by the OIG. Now, through a journal article, the
EPA seeks to change the way toxaphene risks are assessed by measuring
toxaphene compounds that are either not found in environmental samples, or
only in extremely small amounts. The other 800 chemicals in the toxaphene
mixture, many of which are found in very large amounts in Brunswick’s
environment and toxicologically not well understood, pose unacceptable risks
to human health and the environment and must be considered when assessing
The EPA response to the Inspector General’s report on the Hercules 009 Site
uses Terry Creek Site (above) data, but none from the Hercules 009 Site.