The Glynn Environmental Coalition
(GEC) is disappointed that EPA Region 4 is refusing to re-test Altama
Elementary School to assure the soil is safe for children. Although the GEC
learned in 1996 that the testing method used at Altama Elementary School was
erroneous, it took 9 years of negotiating bureaucratic roadblocks to get the
EPA -- at the national level -- to agree. But EPA Region 4, based in
Atlanta, still has not acted on a 2005 EPA Office
of Inspector General (OIG) report which recommended using a different
analytical method to determine the amount of toxaphene present.
"Toxaphene was found on Altama
Elementary School during the containment of the Hercules Superfund Site,"
said Daniel Parshley, Project Manager for the GEC. "According to the EPA
Inspector General's report, the method used to identify contaminated soil
only reported about 10% of the pesticide present. Until the school is
tested by an appropriate method, we won't know if all the contaminated soil
has been removed and the schoolyard is safe."
"The Glynn County Board of
Education has acted very responsibly in the past to address our concerns
about toxic risks to our children," continued Parshley. "Regretfully, due
to inaction by a federal agency which is supposed to be protecting us, we
must again turn to our local officials for their help in getting some
movement on this matter."
Toxaphene is one of 12 chemicals
banned world-wide under the Stockholm Convention. Toxaphene products can be
detected in human blood, urine, breast milk, and body tissues. The OIG
expressed particular concern about several toxaphene chemicals that
bio-accumulate in the body and about babies being exposed through breast
milk. Toxaphene generally gets into the body through eating contaminated
fish, but air and soil exposure can be significant.
According to the EPA Office of
Inspector General, inappropriate testing methods were used to test for
toxaphene during the containment of the Hercules 009 Landfill Superfund
Site. The Glynn Environmental Coalition wants to know if the Altama
Elementary School has the banned pesticide toxaphene on the school yard.
"We need to be sure all kids are safe", said Bill Owens, GEC President.
"The school needs to be tested by an appropriate method before children
return to school this fall."
The Environmental Protection
Agency’s Office of Inspector General (OIG) issued a report, dated September
26, 2005, entitled
“Appropriate Testing and Timely Reporting Are Needed at the Hercules 009
Landfill Superfund Site, Brunswick, Georgia”. This document, developed
by EPA’s Ombudsman, refutes EPA Region 4’s methods for analyzing toxaphene
at the 009 Superfund Site, the Terry Creek Disposal Superfund Site, and at
other areas around Glynn County, Georgia. Nearly 15 years of data collected
on soil, air, water and biological samples tested in Brunswick are now in
doubt.
Toxaphene, a banned pesticide
manufactured at the Hercules Plant, has been analyzed in Glynn County by the
erroneous method. This includes sampling of neighborhoods, schools, and six
toxic waste sites. "The goal of the Glynn Environmental Coalition is to
have all areas sampled by the flawed method re-tested. At the top of our
priority list is Altama Elementary School that abuts the Hercules 009
Landfill Superfund Site," said Owens.
"The Environmental Protection Agency’s Office of Inspector
General said the previous method was inadequate, and we should not take
chances with children’s health and safety at Altama Elementary School,"
Owens stated.
Other areas where the erroneous
toxaphene analytical method was used include the neighborhoods around the
Hercules Plant, 4th Street Landfill, T Street Dump, Old Sterling Landfill,
Terry Creek Dredge Spoil Areas/Hercules Outfall Site, and the Hercules
Plant.
"Many years ago, the erroneous
toxaphene testing method was identified by agencies, experts, and our
community's own technical advisor, Dr. Kevin Pegg," said Parshley.
In an
October 2005 Technical Assistance Report to the community, Dr. Kevin R.
Pegg, who is contracted by the GEC to be the community's technical advisor
under an EPA Technical Assistance Grant, wrote:
"For more than a decade EPA Region 4 used the
toxaphene task force method (EPA Method 8081) in Glynn County despite
research showing the method does not give valid data on environmental
toxaphene. ... The method is not recognized by other governments or by
researchers as a useful method because it under-reports the actual toxaphene
concentration.
"It is
fair to say much of the data on toxaphene occurrence and exposure is
'inconclusive' for samples taken in Brunswick and tested by method 8081.
Not all of the thousands of samples examined so far are in error ....
However, virtually all of the groundwater and soil samples need retesting
to verify the presence or absence of weathered toxaphene." (emphasis
added)
Government agencies and experts
have repeatedly found and demonstrated that the erroneous testing method
used in Glynn County would either fail to detect toxaphene or seriously
underestimate the levels present. The toxicologist with the Agency for
Toxic Substance and Disease Registry (ATSDR) noted that use of the erroneous
testing method is likely to result in significant underestimation of
toxaphene concentration, and the estimated dose could be 10 times higher if
historical data are taken into account for dose estimation. A second
expert, Dr. Keith Maruya, interviewed for the Hercules 009 Landfill
Superfund Site Five-Year Review, gave an estimation of toxaphene levels up
to 10 times higher than reported by the erroneous analytical method.
The erroneous method has notably
failed even to find toxaphene when present at high and dangerous levels.
The OIG noted that the erroneous analytical method used was not effective
for detecting degraded toxaphene in soil, water, and fish. The severity of
the problem was demonstrated when 56 fish samples were analyzed by the
erroneous method and were reported as "no toxaphene present". When more
accurate analysis was done, toxaphene was found at over 52 times the EPA’s
"do not eat" level for toxaphene!
The OIG Report does not discuss
how a determination that the remedy is protective could be made with
admittedly questionable data that was used for the soil removal actions at
Altama Elementary School, the Remedial Design, and Remedial Action
decision-making. "Therein lies the problem at Altama Elementary School,"
said Bill Owens, GEC President. "We just don't know if Altama Elementary
School soils are safe. The EPA OIG did have sampling done to assure water at
the Hercules 009 Landfill Superfund Site was safe but did not have sampling
results to assure Altama Elementary School soils are safe."
The OIG noted that exposure and risk information is needed in order
to complete risk assessments, as studies indicate that toxaphene poses a
risk to human health. But the risk which soils pose to students at Altama
Elementary School cannot be assessed until correct sampling and testing are
completed.
The OIG
has recommended that a specific method of toxaphene analysis be used in
Glynn County to resolve the conundrum caused by the erroneous toxaphene
analytical method. Use of gas chromatography - negative ion mass
spectrometry (GC-NIMS) will provide the certainty needed to determine if
toxaphene and toxaphene breakdown products are still present in areas tested
erroneously, particularly at Altama Elementary School and the culvert
adjoining the school.
In addition, the IG named 16 other
toxic sites across the nation where appropriate re-sampling for toxaphene is
needed. For this reason, national environmental
organizations have been watching the developments in Glynn County closely.
"The stubborn insistence by EPA Region 4 to continue to rely on a biased and
unscientific method that has been rejected by the ATSDR (Agency for Toxic
Substance and Disease Registry) and the OIG can cynically be viewed as a
blind, ideological adherence to fiction in the face of facts. The result of
these actions, whether ignorant or intentional, is a failure to provide the
protection for human and environmental health that is promised in the
mission of the EPA," wrote Jennifer Sass, Ph.D., Senior Scientist for Health
and Environment at the Natural Resources Defense Council. In a joint
effort, 19 state and national
environmental organizations have supported the GEC's efforts to assure
Altama Elementary School is safe and are watching to see what the outcome
will be.
"Our hope, of course," says GEC
President Owens, "is that the re-testing will show no risk exists. But we
must protect our children with facts, not just hope."
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P. O. Box 2443