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PETITIONED PUBLIC HEALTH ASSESSMENT

ESCAMBIA BRUNSWICK WOOD
(a/k/a BRUNSWICK WOOD PRESERVING)
BRUNSWICK, GLYNN COUNTY, GEORGIA


APPENDIX C: CONCLUSION CATEGORIES

ATSDR Public Health Hazard Categories


CATEGORY A: URGENT PUBLIC HEALTH HAZARD

This category is used for sites that pose a public health hazard where short-term exposures (< 1 yr) to hazardous substances or conditions.


CATEGORY B: PUBLIC HEALTH HAZARD

This category is used for sites that pose a public health hazard where long-term exposures (> 1 yr) to hazardous substance or conditions in the past, present or future could result in adverse health effects.


CATEGORY C: INDETERMINANT PUBLIC HEALTH HAZARD

This category is used for sites in which "critical" data are insufficient with regard to extent of exposure and/or toxicologic properties at estimated exposure levels.


CATEGORY D: NO APPARENT PUBLIC HEALTH HAZARD

This category is used for sites where human exposure to contaminated media may be occurring, may have occurred in the past, and/or may occur in the future, but the exposure is not expected to cause any adverse health effects.



APPENDIX D: DEMOGRAPHICS MAP

Demographics Map
Figure 1. Intro Map


APPENDIX E: POTENTIAL EXPOSURE PATHWAYS TABLE

Appendix E, Table 1 - Potential (Possible) Environmental Exposure Pathways at the Brunswick Wood Preserving, National Priorities List Site, Brunswick, Glynn County, Georgia

On-site Exposure Pathway Elements
Source Environmental
Medium

Pathway
Status

Point of
Exposure
Route of
Exposure
Exposed
Populations
Number
Exposed
Site Activities Groundwater Past, Current, Future Municipal or private wells Dermal absorption, Ingestion, Inhalation People who use water from the aquifer None Currently Known
Site Activities Soil Past, Current, Future On-site soils Ingestion, Dermal absorption Anyone who digs into the soil None Currently Known
Site & Recreational Activities Surface Water Past, Current, Future Burnett Creek Dermal absorption, Incidental ingestion Anyone who fishes,wades or swims in the creek None Currently Known
Site & Recreational Activities Sediment Past, Current, Future Burnett Creek Dermal absorption, Incidental ingestion Anyone who fishes,wades or swims in the creek None Currently Known

Off-site Exposure Pathway Elements

Recreational Activities Surface Water Past, Current, Future Burnett Creek (downstream) Dermal absorption, Incidental ingestion Anyone who fishes,wades or swims in the creek None Currently Known
Recreational Activities Sediment Past, Current, Future Burnett Creek (downstream) Dermal absorption, Incidental ingestion Anyone who fishes,wades or swims in the creek None Currently Known


APPENDIX F: ATSDR RESPONSE TO INITIAL AND PUBLIC COMMENTS

The Initial Comment period for the Brunswick Wood Preserving Public Health Assessment was from January 9, 1998 to February 8,1998 and the Public Comment period was from August 19, 1998 to September 20, 1998.

The comments received and ATSDR's responses to these comments are contained in this section of the Brunswick Wood Preserving Public Health Assessment.

Comment: An advisory concerning consumption of seafood in Burnett Creek, until fish can be tested, would strengthen the recommendations and clarify, "Indeterminant public health hazard".
   
Response: Fish advisories have been issued by the Georgia Department of Natural Resources for portions of the Turtle River, Purvis, and Gibson Creeks. There is insufficient data to make this type of recommendation for Burnett Creek.
   
Comment: Reword the discussion of funding the removal of the CCA pile. On page 3, "EPA funds", and on page 7 (Actions Taken), "GAEPD....is waiting for funds".
   
Response: Page 3 changed as follows: ...(GADNR) secured funding from EPA and began removal...
Page 7 changed as follows: GAEPD has removed three of the four cells of contaminated soil from the site, but lacks funds for removal of the fourth cell.
   
Comment: The discussion of wells should read, "Current or recent testing of municipal and private wells near the site indicate no site related in.....", or otherwise mention one detection in a private well.
   
Response: The sentence was changed to read as follows: 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.
   
Comment: A discussion of the useful life of the CCA pile cover should be included in the next document if it is still in place.
   
Response: The fourth cell remains on site, but will be removed as soon as funding is approved. The pile is covered and placed within a concrete berm to prevent recontamination of the site. The site is fenced and locked to restrict access.
   
Comment: Surface Water and Sediment - The entire section needs to be re-written and corrected. See page 3 of Appendix A, Groundwater. The creek is tidal and is fished recreationally to the borders of the site.
   
Response:

Paragraph was changed to indicate that the creek is tidal.F-2

   
Comment: Air- This section should note that there are houses closer to the site than the air testing station.
   

Response:

The following sentence was added to this section: There are some homes closer to the site than the testing station, but no data was available from these locations for analysis.
   

Comment:

Health Effects by Exposure Pathway - In paragraph two the conclusion the site did not pose a public hazard in the past is unsupportable and contradicted by appendix F.
   

Response:

ATSDR's conclusion that soil and sediment did not pose a public health hazard in the past is supported by data and the exposure scenario ATSDR used when estimating worker and trespasser exposures to contaminants in the soil. Under the scenario the workers and trespassers who were most likely to come into contact with or inadvertently ingest contaminants in the soil may have an increased likelihood of developing adverse health effects or cancer if exposed to the highest levels of these contaminants over an extended period. ATSDR believes the exposure doses overestimate the actual exposures incurred by workers and trespassers, because exposure was most likely intermittent and brief. The highest levels of contaminants were detected in sediment in the lagoons and the drainage ditches, water covering these areas limited access to the underlying sediment. Therefore, it is unlikely that workers or trespassers contacted sediment in these areas during past site operations. Most likely exposure to soil and sediment was intermittent and brief, therefore, workers or trespassers would not be expected to have adverse health effects.
   

Comment:

Community Health Concerns - This section is very weak and needs further research.
   

Response:

This section was modified as follows: Residents have expressed concern in the past 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.
   

Comment:

Comparison of Morbidity and Mortality Data - The conclusion that, " ....there is no completed exposure pathway for the site", should be deleted and replace with, "Data is insufficient to evaluate air and groundwater exposure in the past, work place exposure to soil was probable, and past and future seafood consumption might be a completed exposure pathway to site contaminants".
   
Response: Comparison of Morbidity and Mortality Data has been changed as follows: No health outcome data analysis was completed for this site, because the population around the site was too small to conduct a meaningful evaluation.
Note: Even if there were completed exposure pathways the limited size of the population around the site would prevent any meaningful data collection or analysis.
   
Comment: Conclusions - Conclusion #2 should read, "Past exposure to on-site soil was likely and data is insufficient to evaluate air exposure. There is no apparent public health hazard from soil exposure currently.
   
Response: ATSDR concluded that exposure to on-site soil was most likely intermittent and brief, because the highest levels of contaminants were detected in sediment in the lagoons and the drainage ditches, water covering these areas limited access to the underlying sediment. In addition, workers entering these areas most likely wore protective clothing, which would reduce exposure and any associated health effects. Air data for the site was limited, but the data available was evaluated. Based on that data and past experience with other wood preserving sites ATSDR concludes that the air exposure pathway does not pose a public health concern.
   
Comment: Page 2 - Summary. The conclusion, "....workers and trespasser most likely did not come in contact with contaminated soil at levels associated with public health Hazards", is not supportable and contradicted by Appendix F.
   
Response: The conclusion, "....workers and trespasser most likely did not come in contact with contaminated soil at levels associated with public health hazards", is supported by ATSDR's exposure/dose scenario and site related data. The highest levels of contaminants were detected in sediment in the lagoons and the drainage ditches, water covering these areas limited access to the underlying sediment. Therefore, it is unlikely that workers or trespassers contacted sediment in these areas during past site operations. Most likely exposure to soil and sediment was intermittent and brief, therefore, workers or trespassers would not be expected to have adverse health effects.
   
Comment: The final conclusion, "....no apparent public health hazard in the past", is not supported by any data and based on assumptions.
   
Response: ATSDR's determination, "no apparent public health hazard in the past", is based on site related data and very conservative assumptions. As stated in the soil consult, ATSDR assumed that a 70-kilogram worker performed outdoor activities in the contaminated area 5 days a week over 20 years, and that a 50-kilogram trespasser (assuming a child/teenager between the ages of 7 and 14 years) accessed contaminated areas, 2 days a week over a 7 year period. ATSDR, also assumed that, during these activities, individuals were incidentally exposed to the most contaminated soil; therefore, ATSDR used maximum measured concentrations of contaminants in on-site soil in estimating exposure doses. For exposure through the skin, ATSDR assumed that approximately 10% of a worker's or trespasser's skin surface was exposed to soil.
   

Comment:

Page 16 - Conclusions. Paragraph 2. On-site soil or sediment posed no apparent public health hazard to workers and trespassers in the past, and put, "The potential existed in the past for frequent exposure to contaminated soil over an extended period of time".
   

Response:

ATSDR does not agree that worker and trespasser past exposures were frequent and over an extended period. ATSDR developed a scenario using very conservative assumptions when estimating worker and trespasser exposures to contaminants in the soil. On the basis of these very conservative assumptions, ATSDR derived exposure doses and excess cancer risk for workers and trespassers. Under the scenario the workers and trespassers who were most likely to come into contact with or inadvertently ingest contaminants in the soil may have an increased likelihood of developing adverse health effects or cancer if exposed to the highest levels of these contaminants over an extended period. ATSDR believes the exposure doses overestimate the actual exposures incurred by workers and trespassers, because exposure was most likely intermittent and brief.
   
Comment: Summary - Does it seem appropriate to say that "at this time no data have been reviewed which indicate that exposure to chemicals at levels of concern is occurring; however, additional sampling is required to complete the health evaluation?" This statement would provide a balance between what is known and what is not known and create less anxiety in the surrounding community.
   
Response: The following was added to the second paragraph of the summary:
Data reviewed for this health assessment does not indicate that exposure to chemicals at levels of concern is occurring. Additional sampling data will be reviewed as it becomes available.
   
Comment: Groundwater Pathway Evaluation
Recommendation #2, "Restrict the use of groundwater at the site..." should state whether it is talking about on-site, off-site, or both.
Recommendation #4, "Determine the extent of contamination in Burnett Creek....." should be more specific regarding the types of fish or marine species which should be sampled; i.e., fish and seafood commonly harvested for human consumption. We are concerned with the site assessment as it relates to human health, not a general environmental assessment.
   
Response: Recommendation #2 was modified as follows: Restrict the use of groundwater on-site until the extent and characterization of the potential contamination is completed.
Recommendation #4 was modified as follows:
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.
   
Comment: Appendix B - Soil and Sediment Pathway Evaluation
Did ATSDR consider longer exposure periods or different receptor populations in determining that there are no adverse health effects expected from exposure? The justification for this statement was that the levels of contamination off-site were much lower than those recorded on-site.
   
Response: ATSDR considered exposure periods in terms of past, present, and future exposures. Receptor populations considered were workers, trespassers [children and adults], and residents. The only possible past exposures would have been workers and trespassers, because no one lives or has lived on-site in the past. Based on studies ATSDR can estimate how much soil a person may inhale or ingest when they work at the site or trespass. Using these conservative assumptions, we estimated worst case exposure possibilities. ATSDR then developed a scenario using very conservative assumptions when estimating worker and trespasser exposures to contaminants in the soil. On the basis of these very conservative assumptions, ATSDR derived exposure doses and excess cancer risk for workers and trespassers. Under the scenario the workers and trespassers who were most likely to come into contact with or inadvertently ingest contaminants in the soil may have an increased likelihood of developing adverse health effects or cancer if exposed to the highest levels of these contaminants over an extended period. ATSDR believes the exposure doses overestimate the actual exposures incurred by workers and trespassers, because exposure was most likely intermittent and brief.
   
Comment: Also, there is a mention of two lagoons and some stained soil which remain on site (page 6, paragraph 1). Are there any plans for remediation of these areas?
   
Response: Plans for further remediation will be addressed by the Feasibility Study when it is completed.
   
Comment: Considering that you know of six spills in the area and the extensive nature of what has been left by the wood preserving facility, how could you state that soil and sediment pose no health hazard in the future?
   
Response:

The U.S. Environmental Protection Agency has excavated and removed the majority of contaminated soil and sediment from the site and replaced it with clean soil and gravel. This action virtually eliminates the possibility of exposure to contaminants through contact with on-site soil and sediment in the future. Soil samples for volatile organic compounds, polycyclic aromatic hydrocarbons, benzo(a)pyrene, pentachlorophenol, dioxins, and arsenic were collected from the site perimeter and found to be below levels of public health concern.

However, as stated in the Groundwater Pathway Health Consultation, site-related contaminants have been detected in groundwater beneath the site. The extent of this contamination has not been fully characterized. The Remedial Investigation and Feasibility Study should provide more information on this pathway. Private wells in the area have not shown contamination to date, but should be monitored until the extent of groundwater contamination has been determined, because they could pose a health hazard in the future.

   
Comment: Who is to say that fish caught, or the oysters harvested, outside of Burnett Creek have not been effected?
   
Response:

The Georgia Department of Natural Resources (GDNR) has sampled fish from different areas of the Turtle River and found elevated levels of polychlorinated biphenyls and mercury. GDNR has issued 'Guidelines for Eating Fish from Georgia Waters'. This booklet contains recommendations designed to protect you from experiencing health problems associated with eating contaminated fish. For Glynn County (outside of Burnett Creek) there are guidelines for the consumption of fish and seafood from Purvis and Gibson Creeks and the Turtle River.

There has not been sufficient sampling done to determine whether or not fish in Burnett Creek have or have not been affected by site related contaminants. Burnett Creek in the area near the site is dry most of the time, but the creek does contain water during periods of heavy rain and high tides. Due to the predominantly low, but fluctuating level of the creek it appears that few people fish the creek. If people are fishing the creek, ATSDR recommends sampling of the species commonly harvested for human consumption.

   
Comment: I would like to commend the EPA on the thoroughness of their investigation.
   
Response: Thank-you on the behalf of both ATSDR and EPA.
   
Comment: It seems that for the last 20 years there has been contamination of the soil and the waterways surrounding this site.
   
Response: ATSDR and EPA agree that the owner/operators of the Brunswick Wood Preserving facility had been releasing contaminants from their wood treating process into the environment for a number of years. Unfortunately, the extent of the contamination was not known until EPA began a preliminary site investigation after the facility was closed due to bankruptcy in 1991.
   
Comment: This almost adds insult to injury that the $1.4 million dollar price tag in the cleanup is coming from our taxes.
   
Response: The majority of monies used for cleaning up hazardous waste sites comes from a Trust Fund rather than from tax payers. The Superfund Trust Fund was set up to pay for the cleanup of these sites. The money comes mainly from taxes on the chemical and petroleum industries. The Trust Fund is used primarily when those companies or people responsible for contamination at Superfund sites cannot be found, or cannot perform or pay for the cleanup work.
   
Comment: We do not agree with your conclusion that "past exposures to on-site soil and sediment, which were likely sporadic and of short duration, are not a public health concern."
   
Response: Currently, no one lives on-site and no one has lived on-site in the past, therefore, exposure was not continuous. The only possible past exposures would have been workers and trespassers. Based on studies ATSDR can estimate how much soil a person may inhale and ingest when they work at the site or trespass. Using these conservative assumptions, we estimated worse case exposure possibilities. ATSDR then developed a scenario using very conservative assumptions when estimating worker and trespasser exposures to contaminants in the soil. On the basis of these very conservative assumptions, ATSDR derived exposure doses and excess cancer risk for workers and trespassers. Under the scenario workers and trespassers who were most likely to come into contact with or inadvertently ingest contaminants in the soil may have an increased likelihood of developing adverse health effects or cancer if exposed to the highest levels of these contaminants over an extended period. ATSDR believes the exposure doses overestimate the actual exposures incurred by workers and trespassers, because exposure was most likely intermittent and brief.
   
Comment: ATSDR needs to get all the Corps of Engineers documents including the Main Report and Environmental Impact Study.
   
Response:

ATSDR will request a copy of the Corps of Engineers Environmental Impact Study and other related documents.

   
Comment:

...the Maximum Contaminant Level Goal (MCLG) should be used concerning water etc. as that is what EPA/the law says should be aimed for always. In many cases the MCLG is ZERO - therefore one should always seek to get levels lowered.

   
Response: ATSDR used the most conservative value of either the Maximum Contaminant Level (MCL) or the ATSDR Comparison Value in its analysis of the groundwater pathway. The Maximum Contaminant Level (MCL) is the highest concentration of a contaminant permissible in a public drinking water supply and the Maximum Contaminant Level Goal (MCLG) is a non-enforceable concentration of a drinking water contaminant that is protective of adverse human health effects and allows an adequate margin of safety.
   
Comment: ATSDR should issue an immediate advisory for Burnett Creek, Turtle River etc. and for the harbor.
   
Response:

There has not been sufficient sampling done to determine whether or not fish in Burnett Creek have or have not been affected by site related contaminants. Burnett creek in the area near the site is dry most of the time, but the creek does contain water during periods of heavy rain and high tides. Due to the predominantly low, but fluctuating level of the creek it appears that few people fish the creek near the site. If people are fishing the creek, ATSDR recommends sampling of the species commonly eaten.

The Georgia Department of Natural Resources (GDNR) has sampled fish from different areas of the Turtle River and found elevated levels of polychlorinated biphenyls and mercury. GDNR has issued 'Guidelines for Eating Fish from Georgia Waters'. This booklet contains recommendations designed to protect you from experiencing health problems associated with eating contaminated fish. For Glynn County (outside of Burnett Creek) there are guidelines for the consumption of fish and seafood from Purvis and Gibson Creeks and the Turtle River.

   
Comment: ...I noticed the effects from site toxics via the air pathway (breathing fumes carried over the area even at low levels) seems to have been forgotten, it should be evaluated too.
   
Response:

The following is an excerpt from the Initial Release of the Public Health Assessment that addresses the Air exposure pathway:

The air exposure pathway has been eliminated as an exposure pathway of concern at the site. During soil removal activities soils are wetted to keep fugitive dust emissions to a minimum 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. Each sample was collected over a 24 hour period and then analyzed by GAEPD labs and the GA 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.

   
Comment: ATSDR should get more involved with the U.S. Army Corps of Engineers activities in Brunswick Harbor.
   
Response: ATSDR is not a regulatory agency. We have no authority to get involved in the proposed dredging activities in Brunswick Harbor.
   
Comment: In the Background and History, migration of contaminants to off-site soils documented in the past through soil testing indicates an airborne exposure route existed in the past. This is consistent with my observations of excessive dust plumes and soil covered vegetation while the facility was in operation during dry periods. Inclusion of past airborne migration with the discussion of migration into underlying groundwater would be helpful. (Off-site soil contamination levels did not indicate a need for removal).
   
Response: The following modification was made to the Air section: 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 data to evaluate past air exposures on or off-site. Based on air data collected in 1996 there are no current exposures to site related contaminants at levels of health concern in air.
   

Comment:

Under "Site Visit", it states completed areas have been backfilled. To my knowledge, not all previously completed excavated areas have been backfilled. EPA Remedial Project Manager, Brian Farrier, might be able to clarify this statement.
   

Response:

The following sentence was deleted: Areas where soil excavation is complete are backfilled with uncontaminated soil and gravel.
   
Comment: Several dioxin/furan /PCB sources currently exist in the estuary. Any dioxin/furan sediment contamination may be additive to existing levels in the fish. Potential for exposure to multiple contaminants (mercury, chlorinated compounds, heavy metals) should be noted, also.
   
Response: The following sentence was added to the discussion under Burnett Creek Sediment: It is possible that dioxin/furan sediment contamination in Burnett Creek might be additive to existing levels in fish downstream from the site, increasing the potential for exposure to multiple contaminants.
   

Comment:

Using citizen communication of concerns to the Health Department may be an inaccurate measurement of interest and concern about the site.

   
Response: Community concerns for this site were gathered in part through the local Health Department, but were also solicited through an availability session at a public meeting on May 28, 1997, through flyers sent to residents surrounding the site, and through the local newspaper and a local newsletter.
   
Comment: The Soil and Sediment Pathway evaluation (December 23,1997) discussion for Burnett Creek Sediment is very good. It is unclear if the Food and Drug Administration (FDA) dioxin levels in food are being applied to commercial interstate seafood commerce, which takes into account dilution in the Nations food basket; or in a local consumption scenario. When discussing local consumption of fish from a creek, the FDA explicitly states that commercial action levels are not to be used for local consumption. Clarification of how FDA action levels are being applied would be helpful.
   
Response:

It is true that the FDA did intend these values for commercial interstate seafood commerce, but because there aren't many fish toxic guidance levels available, these values are sometimes used by states and other agencies as the basis for issuing freshwater fish and other sport fish consumption advisories.

The Soil and Sediment Pathway Evaluation for Burnett Creek has been modified as follows for better clarification:

ATSDR does not know with certainty the extent to which people fish in the creek or whether fish are accumulating low levels of site-related contaminants, such as dioxins/furans. ATSDR reviewed scientific literature to understand the relationship between dioxin/furan concentrations in sediment and uptake by fish. Findings from limited available studies provide some evidence that elevated fish tissue concentrations correlate to high dioxin/furan sediment concentrations, but differences in fish species and lipid content may influence uptake (Sherman, 1992). One study indicates that fish accumulated dioxins/furans to levels greater than 0.0000025 mg/kg TEQs from sediment containing dioxin/furan concentrations ranging from 0.0000141 mg/kg TEQs to 0.000142 mg/kg TEQs (Ling, 1995). The 0.0000025 mg/kg TEQ limit has been used by the Food and Drug Administration as a basis for issuing fish consumption advisories for dioxins/furans, but it is currently under review (FDA, 1981; ATSDR, 1989). Because sediment concentrations measured in Burnett Creek are similar to the literature-based values, dioxins/furans may be accumulating in Burnett Creek fish, if they reside exclusively in the stream area near the site.

ATSDR calculated cancer risk for an average adult (60kg) from eating fish using the FDA TEQ and assumed consumption rates from previous studies (the 1988 West study, a 1988 survey in New York, a 1985 survey in Wisconsin, and a 1980 survey by Rupp, National Marine Fisheries for the North-Central region of the U.S.). From these studies ATSDR used 15g/d for sport-fishers and 7.3g/d for self-caught fish as reasonable but yet conservative daily consumption estimates. ATSDR calculations indicate that elevated cancer risk is not significant for an average adult who consumes 2 fish meals or less per month over a 70 year period from Burnett Creek. For persons who consume 4 fish meals or more per month over a 70 year period from Burnett Creek theoretical cancer risk is slightly elevated. If people consume fish from the creek, then fish monitoring data are needed to more fully evaluate this exposure pathway.



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