PETITIONED PUBLIC HEALTH ASSESSMENT
ESCAMBIA BRUNSWICK WOOD
(a/k/a BRUNSWICK WOOD PRESERVING)
BRUNSWICK, GLYNN COUNTY, GEORGIA
Brunswick Wood Preserving (BWP) is in Brunswick, Glynn County, in eastern Georgia. ATSDR's involvement at BWP began in 1991 in response to a citizen's petition indicating concerns about potential exposures at the site. On May 15, 1992 ATSDR released a public health consultation for this site. This public health assessment is the result of the sites' proposal to the National Priorities List (NPL) in December 1996. The site began operating as the Escambia Treating Company in 1958 and was sold to the Brunswick Treating Company in 1986. Both owners of the site manufactured wooden poles and pilings, which were treated with creosote and solutions of pentachlorophenate. This activity, as well as, improper storage and disposal practices led to the contamination of several environmental media with chromated copper arsenate (CCA), pentachlorophenol (PCP), polycyclic aromatic hydrocarbons (PAH's), and dioxin. The site was closed in March 1991. In April 1991 the Environmental Protection Agency (EPA) began a preliminary assessment and then initiated a two-phase removal action of the contaminated materials. Removal of contaminated soil is near completion and EPA has collected additional samples for the final Remedial Investigation (RI).
The site is categorized as an indeterminant public health hazard based upon data reviewed and observations made by ATSDR. This conclusion category was selected because the extent and magnitude of groundwater contamination and the extent of contamination in Burnett Creek have not been fully characterized. Data reviewed for this public health assessment does not indicate that exposure to chemicals at levels of concern is occurring. However, additional sampling data is needed and will be reviewed by ATSDR as it becomes available.
ATSDR recommends (1) Implementing analytical protocols for sampling of potable water that are protective of public health; (2) Restricting the use of groundwater at the site until extent and characterization of the potential contamination is completed; (3) Verifying that there are no additional private wells down gradient of BWP than those identified in 1991; (4) Determining the extent of contamination in Burnett Creek and whether fish, commonly harvested for human consumption, are accumulating site-related contaminants to levels that might pose health hazards to individuals consuming the fish.
ATSDR will review any additional data made available (e.g., the forthcoming RI) and will issue a public health assessment or public health consultation which discusses the results of our review.
The BWP facility (a.k.a. Escambia Wood Treating) in Brunswick, Georgia is a former wood treating facility that produced treated telephone poles. The facility covers 84 acres in a light industrial area just outside the Brunswick city limits. The property is bordered by railroad tracks on the east and south and by Perry Lane road to the north. Burnett Creek flows along the west side of the site with marsh lands to the east and north. The 50 acre production area consisted of two wood treating process areas and a four acre water-containing surface impoundment. The site also contains four buried impoundments and a treated pole storage area. The site is closed, fenced, posted and with a security guard is present 24 hours a day.
The facility was opened in 1958 as the Escambia Treating Company. In July of 1986 the entire property, except for a small adjacent property and one surface impoundment, was sold to the Brunswick Treating Company. Both owners of the site manufactured wooden poles and pilings which were treated with creosote and solutions of pentachlorophenate dissolved in an oil carrier. The facility initially handled only oil-based preservatives (e.g., creosote and PCP), but around 1970 a separate facility was constructed for CCA wood treatment (1). Following treatment BWP's wood products were dried in drip tracks and stored in treated wood storage areas prior to shipment. The creosote and PCP pressure treatment process created a large amount of wastewater , which was treated on site prior to its release to local surface waters. The process areas, the drying tracks, and the storage areas were not underlain with concrete slabs or other material that might prevent the wood preserving compounds from being washed into the surrounding soil (1). As a result of normal operations and storage practices, wood preservatives and spent wastewater were released to the surrounding soil.
The site was abandoned in March 1991 after BWP declared bankruptcy. The EPA entered into a Consent Decree with the various owners/operators, because of their inability to take corrective action or continue operating a wastewater treatment system. In April 1991 EPA conducted a preliminary investigation and determined that CCA, PCP, PAH's, and dioxins used in BWP industrial processes had contaminated onsite soil. EPA also noted through groundwater sampling that some compounds had migrated to the underlying groundwater.
In response to immediate health threats posed to nearby residents or people accessing the site, EPA initiated a two-phase removal action of the contaminated materials. During the first phase, EPA conducted a preliminary assessment and determined that elevated levels of wood preserving compounds were present in the process area's soil at depths up to 9 feet below ground surface. Contaminants identified in soils include PCP, PAH's, arsenic and chromium. Dioxin, an impurity of PCP, was also identified. EPA conducted limited onsite groundwater monitoring and found that wood preserving compounds released to the onsite soil had migrated vertically to the underlying surficial aquifer beneath the site (1). EPA also identified and tested more than 50 private wells in the immediate area of the site. Only one well had detectable levels of wood preserving compounds, but follow-up samples failed to confirm the presence of contamination in the well (2).
The second phase of the removal action included demolition of the CCA process area, the construction of cells for staging excavated soil, and the excavation of the soil underlying a creosote/PCP impoundment to the west of the creosote/PCP process area. EPA stored more than 127,000 tons of excavated contaminated soil in four onsite lined and covered cells. Depleted funding resources delayed removal activities and stockpiled contaminated soil remained onsite for several years. In November 1996, Georgia Department of Natural Resources (GADNR) secured funding from EPA and began removal of the stockpiled soils (3).
The site has been visited on numerous occasions by ATSDR regional representatives and GADNR staff. On 29 May 1997 a site visit was conducted by Robert Knowles, ATSDR; Bob Safay, ATSDR; Hal Emmett, Georgia Division of Public Health; and Brian Farrier, EPA. Public access to the site is restricted by a perimeter fence, which prevents potential exposures to on-site surface soils. There was no evidence of trespassers. The facility's buildings and treatment areas were dismantled and removed from the site. Railroad ties, fence posts, wood chips, and scrap metal had been removed. Three of the four large mounds of contaminated soil (approximately 150,000 tons) at the site were removed by truck and railroad to a permitted landfill. The fourth pile remains onsite and is covered by a geo-textile tarp. This waste cell contains the soils removed from the CCA area, and will be addressed as part of the NPL remedial cleanup.
EPA is currently onsite collecting additional soil and groundwater data, which will be incorporated into the final RI. Groundwater data is being collected with cone penetrometer technology; in addition, piezometric data is being collected. After the RI is completed a Feasibility Study will begin.
The nature and extent of contamination associated with the Brunswick Wood Preserving site is discussed below and in the attached Health Consultations (see Appendix A for Groundwater and Appendix B for Soil and Sediment). In addition, surface water has the potential for contamination but no data is available to evaluate this pathway. At this time, there have been no completed pathways of human exposure identified at this site.
The Brunswick Wood Preserving site is located in northern Glynn County, Georgia on Perry Lane Road. The population of the county was listed as 61,437 in the 1990 U.S. census. The land use surrounding the site is mixed residential and industrial. There is an estimated total population of 2,103 within a one mile radius of the site with 207 children age 6 years and under, 172 adults 65 and older, and 515 females from 15-44 years of age. A break down by race indicates that the area is predominantly White (2,042), but has some Black (49) and Hispanic (17) citizens.
ATSDR staff reviewed available on-site and off-site monitoring and sampling data and identified the following potential exposure pathways at this site: Soil, Groundwater, and Surface Water.
Some contaminants from the soil have migrated into the surficial aquifer (groundwater) beneath the site. Potential exposure from the groundwater pathway is evaluated in the Groundwater Pathway Consultation in Appendix A of this document. Current testing of municipal and private wells near the site indicate no site related contaminants in excess of Maximum Contaminant Levels (MCL), but further characterization of the groundwater is needed.
As discussed in the summary, EPA identified PCP, PAH's, arsenic, chromium and dioxin in onsite soil. The contaminated soils were excavated and placed in four onsite lined covered cells. Three of these cells have been removed from the site by the Georgia Environmental Protection Department (GAEPD), with state Superfund monies, and placed into a permitted landfill. More information on the soil pathway can be found in Appendix B.
During heavy rain, conditions on site allow surface water and sediments from a large drain pipe on the southern most portion of the site to migrate to Burnett Creek. There is a potential for site related contaminants to accumulate in fish in Burnett Creek. The creek is tidal and therefore dry much of the time. Creek access is limited near the site and it does not appear to be used frequently for recreational fishing, but this pathway should be further evaluated. Recreational harvesting of finfish and shellfish for local consumption occurs downstream from the site and commercial harvesting of shrimp and blue crabs occurs below the U.S. 341 bridge, one half mile south of the site (1). Surface waters migrating off site have not been tested, so there is no data available to evaluate this pathway. There is potential for site related contaminants to enter the food chain. Sediment is discussed in more detail in Appendix B.
The public has reported to ATSDR that when the BWP facility was operational dust plumes were observed emanating from the site, but ATSDR has no available data to evaluate past air exposures on or off-site. Based on air data collected in 1996 there is no current exposure to site related contaminants at levels of health concern in air. During soil removal activities, soils are wetted to minimize fugitive dust emissions and traffic is restricted at the site. Data from the Glynn County Initiative: Air Toxics Dataset was used to evaluate the air pathway. This data was collected by GAEPD under the Glynn County Initiative. The data was gathered from 9 March through 21 April 1996 at the following stations in the Brunswick area: AARCO, Emergency Management Station, Georgia State Patrol, Brunswick College, Jekyll Island, and St. Simons Island. Each sample was collected over a 24 hour period and then analyzed by GAEPD labs and the Georgia Tech Research Center. Quality Control and Quality Assurance checks of the data were performed by GAEPD. The Georgia State Patrol station is approximately one half mile from BWP. Data from this station was used in this evaluation. There are some homes closer to the site than the testing station, but no data was available from these locations for analysis. All possible site related contaminants were below ATSDR's Comparison Values.
Consumption of contaminated groundwater is a potential public health hazard, but the extent of contamination has not been fully characterized (see Appendix A). EPA has tested municipal wells that are part of Brunswick's public water supply and found no site related compounds at levels above EPA's MCL's. In addition, EPA sampled over 50 private wells adjacent to the site and found no evidence of site related contamination. ATSDR will evaluate any new data from EPA's RI as it becomes available.
Based on data reviewed ATSDR has determined that exposure to contaminated soil and sediment did not pose a public health hazard in the past (see Appendix B) and will not pose a public health hazard in the future due to the nearly completed removal of contaminated soil from the site by EPA.
ATSDR was not able to evaluate past exposures to ambient air due to unavailability of ambient air quality data. ATSDR did evaluate ambient air data collected in March and April of 1996 and determined all possible site related contaminants were below ATSDR's Comparison Values.
ATSDR is concerned about the offsite migration of sediments and surface water into Burnett Creek during heavy rains. Fish may be accumulating site related contaminants (e.g., dioxins/furans) that could be a public health hazard to people who eat fish from Burnett Creek.
In the past, residents have expressed concern over spills into Burnett Creek from Escambia Treating Company, but according to a representative of the Glynn County Health Department, no recent site related concerns have been expressed. ATSDR solicited public comments at a public meeting held 28 May 1997, but none were received. ATSDR will continue to monitor community concerns (e.g., communicate with Glynn County Health Department) as a continuation of the health consultation process.
ATSDR has implemented an initiative to protect children from hazardous waste, because they can be uniquely vulnerable to environmental toxicants, depending on the substance and the exposure situation. Children and infants are generally more vulnerable to toxic substances than adults due to immature and developing organs. Children also play close to the ground, which may increase their exposure to toxicants in dust, soil, and airborne particulate matter. Children also exhibit typical hand to mouth behavior, which may increase their intake of toxicants. ATSDR's evaluation contained within this document considered children as a susceptible sub-population and found no completed exposure pathways for them. Children might be potentially exposed to contaminants of concern from the site (1) if groundwater contamination migrates off-site into area drinking wells, or (2) if they eat fish from Burnett Creek, or (3) if they play in Burnett Creek near the site.
At this time data is insufficient to evaluate the potential exposure pathways (Appendix E). Due to the small number of people living in proximity to the site, an evaluation of such data and comparison with local population health data would not provide useful or meaningful information. Therefore, based on this information no health outcome data evaluation was conducted. However, once data from the groundwater characterization and an analysis of contaminants in fish is available, a further evaluation on the public health threat will be determined.
- ATSDR considers this site to be an indeterminate public health hazard. This conclusion is based primarily on the following:
- Groundwater - The extent and magnitude of groundwater contamination beneath the site has not been fully characterized and many private wells have not been regularly sampled for site related compounds since 1991.
- Surface Water and Sediment - The extent of contamination in Burnett Creek has not been adequately characterized to determine if site related contaminants are accumulating in fish at levels that might pose a public health hazard to people who may eat fish from the Creek.
These recommendations identify actions that ATSDR has determined necessary to reduce potential health hazards identified and to further characterize potential public health hazards.
- Implement analytical protocols for sampling of potable water using Minimum Quanitation Limits that are protective of public health.
- Restrict the use of groundwater onsite until the extent and characterization of the potential contamination is completed.
- Verify that there are no additional private wells adjacent and downgradient of BWP than those identified in 1991. Determine if private wells immediately adjacent and downgradient of BWP have been impacted by site related contaminants and if the levels are a public health concern. Health standards should be considered when establishing the analytical protocol for sampling of private wells.
- Determine the extent of contamination in Burnett Creek and whether fish, commonly harvested for human consumption, are accumulating site-related contaminants to levels that might pose health hazards to individuals consuming the fish.
In accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended, data and information developed in the Public Health Assessment for the Brunswick Wood Preserving National Priorities List site in Brunswick, Georgia has been reviewed by ATSDR's Division of Health Education and Promotion and Division of Health Studies. No follow-up health activities were indicated for the site.
The Public Health Recommendation and Action Plan (PHRAP) for the Brunswick Wood Preserving National Priorities List site contains a description of actions taken, to be taken, or under consideration by ATSDR and/or other government agencies in the vicinity of the site subsequent to the completion of this public health assessment. The purpose of the PHRAP is to ensure that this public health assessment not only identifies public health hazards, but provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment.
The public health actions to be implemented are as follows:
A. Actions Taken
- ATSDR has completed three Health Consultations for this site to date (Groundwater Pathway, Dec 1997; Soil and Sediment Pathway Consultation, Dec 1997; and a Health Consultation in May, 1992).
- EPA conducted an initial investigation of the site in April 1991 and the Emergency Response and Removal Branch completed Removal Actions in April 1995.
- GAEPD has removed three of the four cells of contaminated soil from the site.
B. Actions Planned
- ATSDR will review new data in EPA's forthcoming RI/FS and make additional recommendations, if appropriate.
C. Recommendations for Further Action
- ATSDR will collaborate with the appropriate federal, state, and local agencies to pursue the implementation of the recommendations outlined in this public health assessment.
- This PHRAP will be evaluated annually unless additional information warrants more frequent evaluation. New environmental, toxicological, or health outcome data may determine the need for additional actions.
- Environmental Protection Agency. Memorandum from Greer C. Tidwell, Regional Administrator, USEPA to Don Clay, Assistant Administrator, Office of Solid Waste and Emergency Response, USEPA. Re: Request for $2 Million Exemption for the Escambia Wood Preserving - Brunswick Site in Brunswick, Glynn County, Georgia.
- Environmental Protection Agency. Brunswick Wood Preserving Sample Log, Private Wells, Volume 1. EPA,1991.
- Permar, J. 1996. Toxic Wastes. The Islander. November 4.
- Britt, J. 1997. Personal correspondence between Eastern Research Group, Inc and Jane Britt, Glynn County Health Department (January).
- Agency for Toxic Substances and Disease Registry. Record of Activity. ATSDR, 29 May 1997.
- Agency for Toxic Substances and Disease Registry. Record of Activity. ATSDR, 17 Nov 1993.
- Agency for Toxic Substances and Disease Registry. Toxicological profile for Pentachlorophenol. ATSDR, Atlanta, May 1994; DHHS publication no. (PHS) TP-93/13.
- Agency for Toxic Substances and Disease Registry. Toxicological profile for Creosote. (Update) ATSDR, Atlanta, August 1994.
- Agency for Toxic Substances and Disease Registry. Brunswick Wood Preserving Site Health Consultation, Brunswick, Glynn County, Georgia. ATSDR, 1992.
- Agency for Toxic Substances and Disease Registry. Brunswick Wood Preserving Petition Decision Summary, Brunswick, Glynn County, Georgia. ATSDR, 1993.
- Environmental Protection Agency. Removal Action Site Summary. EPA, 1995.
- Environmental Protection Agency. HRS Documentation Record. EPA, 26 May 1996.
- Environmental Protection Agency. Soil analysis results on Dioxin, Metals, and Organic compounds. EPA, 1997.
- Environmental Protection Agency. Draft - Expanded Site Inspection. EPA, 28 Feb 1994. EPA ID # GAD981024466EPA.
- Environmental Protection Agency. Brunswick Wood Preserving Sample Log, Private Wells, Volume 2. EPA, 1992.
- Georgia Department of Natural Resources. Glynn County Initiative: Air Toxics Dataset Ground Level Measurements. GADNR, Environmental Protection Division, 1996.
- Georgia Department of Natural Resources. Groundwater Conditions in Georgia, 1996. GADNR, Environmental Protection Division, 1997.
- National Oceanic and Atmospheric Administration. Brunswick/Glynn County Community Based Environmental Project. NOAA, Hazardous Materials Response and Assessment Division, May 1996.
Robert B. Knowles, Division of Health Assessment and Consultation
ATSDR Brunswick Wood Preserving Site Team
Carl B. Blair, Region IV Representative
Diane M. Drew, Division of Health Education and Promotion
Sandra Coulberson, Community Involvement Branch