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PUBLIC HEALTH ASSESSMENT

GRIFFITH OIL COMPANY
ARCADE, JACKSON COUNTY, GEORGIA


SUMMARY

The Griffith Oil Company is located on B. Whitfield Road in Arcade, Jackson County, Georgia. The site operated as a used oil recycling facility for approximately 16 years beginning in 1975 and has been inactive since operations ceased in 1991. Activities performed at the site prior to usage as an oil recycling facility are not known. Large volumes of wastes, including fuel storage tanks and drums, were abandoned on-site. Soil samples obtained during a site inspection in June 1994 by the Georgia Department of Natural Resources, Environmental Protection Division (GEPD), were determined to be characteristically hazardous for ignitability. In 1995, GEPD proceeded with a removal action under the authority of the Georgia Hazardous Site Response Act (HSRA). Hydrocarbon-contaminated soil associated with several waste storage areas was excavated during the removal action and is stored on-site.

To evaluate the impact of past site activities to groundwater in the vicinity, GEPD contracted to perform a phased groundwater assessment. Major activities performed during the assessment included a government agency file review, literature search, geologic mapping of the site and vicinity, inventory and sampling activities at on- and off-site water supply wells, and the installation and sampling of six monitoring wells.

Results of the site assessment indicate that the site is a source of volatile organic compounds (VOC) to the saprolite and bedrock aquifer systems on and around the site. VOCs detected in individual water wells located a short distance west of the site include the regulated compounds tetrachloroethene (PCE), trichloroethene (TCE), and 1,1-dichloroethene (DCE).

The presence of VOCs in groundwater suggests that additional source(s) of organic contaminants may exist at or near the site. Unidentified sources are likely continuing to feed contaminant migration beyond the site boundary. Based on the levels of VOCs detected in private wells, the site is considered a public health hazard, and an alternative water supply source is recommended to protect residents dependent on groundwater for their drinking water supply. Further site characterization is also recommended. The Georgia Department of Human Resources also recommends that a repository be established where the public can obtain information about the site. This document was made available for public comment at the Jefferson Public Library, Jefferson, Georgia, and the Athens/Clarke County Library, Athens, Georgia. Those are both appropriate places for an information repository.


BACKGROUND

The GEPD requested that the Georgia Department of Human Resources (GDHR), Toxics and Health Hazards Consultation Section, evaluate the extent of contamination and the potential for adverse health effects associated with the Griffith Oil Company site. This public health assessment discusses the extent of cleanup at this site, past and present contaminant levels, the potential and/or actual completed exposure pathways, the public health implications of exposure, and lists public health protection recommendations.

A. Site Description and History

The Griffith Oil Company site is located on 3.87 rural acres, approximately 3 miles southeast of Arcade, Georgia (Figure 1). The property operated as a used oil recycling facility from 1975 until 1991. Key features at the site at the time of closure included a concrete block waste holding facility (sump), two wooden shelters that housed used oil tanks and drums, four drainage lagoons , a bermed soil stockpile, above ground piping, and underground utilities (Figure 2). Large volumes of wastes were abandoned on site when operations ceased in 1991. The site is surrounded by a locked fence with barbed wire restricting public access and is bordered in all directions by residential housing. The nearest private home is approximately 300 feet from the site (Figure 3). No schools or public recreation areas exist within one mile of the site.

The site was brought to the attention of GEPD in early 1994 following a citizen's complaint to the U.S. Environmental Protection Agency (EPA). During the complaint investigation, an estimated 50 used oil storage tanks, ranging in size from 4,000 to 20,000 gallons, and one 50,000-gallon holding tank were discovered on site. Most of the tanks were full. The integrity of several of the tanks was questionable. The soils surrounding the tanks were visibly stained and some were pooling with petroleum sludges . Approximately 300 55-gallon waste oil drums, characterized as being in poor to fair condition, were also found on site. Stressed vegetation, petroleum and fuel odors, and tainted soil and sediment were found throughout the entire property. Oil samples taken from an impoundment area tested positive for the hazardous characteristic of ignitability [1]. The site entered the GEPD Hazardous Site Inventory (HSI) in May 1994.

The Griffith Oil Company was classified by GEPD as a used oil treatment/storage/disposal facility, but neither applied for nor obtained any permit or variance from GEPD or the appropriate federal authority to treat, store, or dispose of hazardous wastes. The owners of the facility were only permitted to transport hazardous wastes from a generator of hazardous waste to an approved or permitted hazardous waste facility. GEPD issued Consent and Administrative Orders in early 1995 to the owners of the property to determine the extent of soil contamination, perform a hazardous waste determination on any wastes at the site, and to remove all soil and sediment with contamination levels exceeding criteria specified in the HSRA Rules of Hazardous Site Response. The responsible parties were unresponsive to the orders issued.

In March 1995, GEPD contracted to determine the extent of soil contamination, to collect and analyze samples of soil, groundwater, and materials on site, and for the removal of contaminated soil, debris, structures, storage tanks, and drums.

Soil sampling was performed to determine the extent of contamination and areas requiring excavation. Based on sampling results, four areas, including a shed, tank impoundment and surrounding area, three lagoons, and the sump were excavated to stabilize the soil. The excavated soil was analyzed and characterized as nonhazardous material and placed in a bermed stockpile on site.

No hazardous constituents were discovered during the sampling of tank and drum contents [2]. After removal of the debris, structures, tanks, and drums, a high pressure washer was used to clean the remnant. Water used for decontamination was stored on site and later treated and transported to an industrial waste water facility. Scrap metal and other materials were sent to recycling facilities when possible. Approximately 439,000 gallons of waste water/product were removed and disposed from the site [3]. After completion of activities, the site was graded to permit drainage into the remaining lagoon. Removal activities were completed in the fall of 1996.

Beginning in March 1997, a groundwater investigation was initiated that included: 1) an inventory and characterization of individual water wells; 2) sampling of on-site water supply and off-site individual water wells; 3) installation and testing of groundwater monitoring wells, and 4) an evaluation of alternative water supplies available to residents with contaminated groundwater as their drinking water source.

Approximately 50 individual water wells are within a 0.25 mile buffer of the site, with the nearest well approximately 0.1 mile from the northwest border of the site [4]. GEPD contractors interviewed residents to evaluate well water usage, well construction, and to obtain permission to collect groundwater samples. These interviews indicated that groundwater produced from the evaluated individual water wells is used for drinking, cooking, washing, and irrigation and is the primary water source for the surveyed residents. No complaints of odor, foul taste, hardness, iron, or sulfur were reported [5]. Sample results from June and August 1997 and January 1998 for inventoried individual water wells indicated that some of the wells contained hazardous constituents above the HSRA criteria [5]. As a result, GEPD has advised local residents about the potential health effects from drinking, cooking with, and bathing in the water from the contaminated wells and recommended the use of alternative water supplies including bottled water and water filtration systems.

Also in October 1997, Arcade officials applied for a federal Community Development Block Grant to help finance connecting residences near the site to the Jackson County water supply. In March 1998, this request was denied. Officials reapplied in 1998. The response was not issued before completion of this document. Other funding sources are being explored by local officials with support from GEPD to provide connection to the Jackson County water supply and to assist the affected residents financially with installation costs for water filters or the purchase of bottled water.

In July 1998, the Administrative Order was amended to require the submission of information on other "responsible parties" and a Compliance Status Report. The site is currently a HSI Class I site. This designates the site as needing corrective action. This designation was made based upon the documentation of several individual water wells contaminated by releases from the site. The date required for filing a petition for a hearing regarding this action has passed, and no petition was filed by the owner of the property.

B. Site Visit

GDHR staff visited the area on February 13, 1998, accompanied by the Jackson County Health Department senior Environmental Health Specialist, the Clarke County Environmental Health Manager, and the District Environmental Health Program Manager. Because removal activities were completed, and remaining structures and materials were visible from the site periphery, site access was not attempted. The following observations were noted:

  1. Access to the site was restricted by a locked gate and a 6-foot chain link fence topped with barbed wire. A no trespassing/warning sign was posted at the front gate.

  2. There was no activity at the site. Stockpiled soil, two tanks, several structures, and a small quantity of debris were present on site.

  3. There were no odors or leachate evident.

  4. Unstressed trees and other flora separated the site from adjacent residential property structures.

C. Demographics, Land Use, and Natural Resources Use

Demographics

According to 1990 census data, Jackson County has a population of 30,005. This is a 18.4% increase from the 1980 population of 25,343. The population has increased primarily on the western edge of the county as a result of the enormous growth of the neighboring county, which has more than doubled its population in the last ten years. Additional demographic information for Jackson County, Georgia is shown in Table 1.

Land Use

The area surrounding the site is approximately 50% residential and 50% undeveloped, forested land (Figure 3).

Natural Resource Use

According to local officials, the creek and land near the site are not used for fishing, hunting, or agriculture. All of the residents living near the site use individual water wells for normal household water use, including consumption.

D. Health Outcome Data

Health outcome databases available for this public health assessment are the Statewide Hospital Discharge database and Vital Records. No site specific health outcome data related to this site was identified. According to the local county health department, no health studies have been performed in the community.


COMMUNITY HEALTH CONCERNS

To date, neither GDHR nor the Jackson County Health Department have received inquiries from the community about the Griffith Oil Company site. In February 1998, GDHR staff investigated the Jackson County, Clarke County, and University of Georgia Libraries, and the Internet for evidence of community involvement activities regarding this site. No evidence of community health concern was found. Back issues of the local newspapers, the Jackson Herald and the Athens-Banner Herald, were searched for articles covering site activities and documenting community concerns. One newspaper article located in the Athens Banner-Herald (02/08/98) included interviews with local residents with affected wells who expressed concerns about nausea, oily deposits in yards and plumbing, a decrease in property values, the cost to affected homeowners of possible legal action, and the cost and availability of alternative water supplies.

To date, no official repository has been established where people in the community can go to readily access information about the site. This document was available for public comment at both the Jefferson Public Library and the Athens/Clarke County Library, which are both appropriate locations for a site information repository. As additional data become available, the information will be reviewed by GDHR. GDHR will also respond to any health concerns posed about the site.


ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

This section of the public health assessment describes environmental sampling previously conducted at the site and identifies contaminants found in specific environmental media. GDHR evaluates these contaminants to decide if they pose a danger to public health. The Agency for Toxic Substances and Registry (ATSDR) and other agencies have developed comparison values (CV) to select contaminants for further health evaluation. Concentrations less than the CV are unlikely to pose a health threat, while concentrations above the CV do not necessarily pose a health threat. Because of the practical limitations associated with evaluating the many chemicals often found at a hazardous waste site, CVs are used to eliminate from further evaluation those chemicals that do not pose a health threat to exposed populations. The most important consideration is whether exposure has occurred, is occurring, or will occur in the future. If exposure can be established, GDHR then bases the determination of a contaminant's inclusion in further discussion on the quality of the data and environmental factors, including the mobility and persistence of the contaminant, and also on the level of community concern regarding the contaminant.

The maximum concentrations of regulated substances detected are summarized in Tables 2, 3, and 4; the CVs for each contaminant are also listed. The data tables include the following acronyms:

EMEG = Environmental Media Evaluation Guide
CREG = Cancer Risk Evaluation Guide
RMEG = Reference Dose Media Evaluation Guide
MCL = Maximum Contaminant Level
HSRA = Hazardous Waste Response Act Action Level
MRL = Minimal Risk Level

EMEGs are media-specific comparison values developed by ATSDR for use in selecting environmental contaminants of potential noncancer health concern. EMEGs are derived from minimum risk levels (MRLs).

MRLs are estimates of daily human exposure to a chemical that is likely to be without an appreciable risk of harmful effects (noncarcinogenic) over a specified duration of exposure. MRLs are based on human and animal studies and are reported for acute (14 days), intermediate (15-364 days), and chronic (365 days) exposures.

CREGs are estimated comparison concentrations for specific chemicals based on one excess cancer in a million persons exposed over a lifetime. The CREG calculation assumes that exposure occurs 24 hours a day, 365 days a year, over a 70-year lifetime.

RMEGs are used by health assessors when a chronic EMEG does not exist and when the RMEG is lower than other CVs. The RMEG is derived from the EPA Reference Dose. Similar to MRLs, Reference Doses are estimates of daily human exposure to a chemical that is likely to be without an appreciable risk of harmful (noncarcinogenic) effects.

MCLs represent contaminant concentrations in drinking water that EPA deems protective of public health over a lifetime (70 years) at an exposure rate of drinking 2 liters of water per day. MCLs are enforceable levels of contamination for public water supplies. In addition to health considerations, the available technology to decrease levels and other engineering and economic considerations are used when establishing MCLs.

HSRA sets action levels for soil and groundwater at hazardous waste sites to establish policies, procedures, requirements, and standards to protect and enhance the quality of Georgia's environment and to protect public health. As defined by HSRA, these action levels provide environmental media clean-up levels for regulated substances that pose no significant health risk on the basis of standardized exposure assumptions [6]. "Individual water well" means any well constructed for the purpose of obtaining groundwater for a single-family dwelling and intended for domestic use. Federal and state laws establish primary and secondary drinking water regulations pursuant to section 1412 of the Public Health Service Act, as amended by the Federal and Georgia Safe Drinking Water Acts and related regulations, and are applicable to public water systems only, not to individual water wells [7] [8].

A. On-site Contamination

Soil

In May 1995, GEPD contractors collected and analyzed over 500 on-site soil samples for total petroleum hydrocarbons (TPH). Soil boring samples throughout the site contained detectable levels of TPH down to an average of approximately 3 feet [3]. Forty-four soil samples were analyzed for inorganics (metals) and volatile and semivolatile organic compounds (VOC and SVOC) in an attempt to correlate TPH with VOC constituents and the locations where they exceeded HSRA criteria. This correlation could not be established since the waste hydrocarbons found at the site were almost exclusively heavy oils and greases. Because TPH is not regulated as a hazardous constituent and boundaries were visually distinguishable between TPH-contaminated soil and the red clay, mass excavation was not recommended [3]. Based on TPH sampling results, four areas, including a shed, tank impoundment and surrounding area, three lagoons, and the sump were excavated to stabilize the soil. The excavated soil was analyzed and characterized as nonhazardous material and placed in a bermed stockpile on site.

Nine regulated substances were detected at levels exceeding HSRA action levels in on-site soil prior to remediation activities. These action levels represent HSRA Type 3 Risk Reduction Standards. Type 3 standards are health-based cleanup levels for non-residential properties. Risk Reduction Standards define the levels of regulated substances required to demonstrate compliance under HSRA for corrective actions that are protective of human health and the environment. Table 5 compares the corrective action results for on-site soil to applicable criteria which exceed Type 3 Risk Reduction Standards.

Tanks and Drums

The origin and the generating process of the materials found on site are unknown; therefore, federal hazardous waste characteristics were considered in the sampling and hazard classification of each tank and drum located on site. Drums and tanks containing solids were disposed as non-hazardous materials while those containing liquids were disposed as hazardous. Exploratory trenching in suspicious areas was conducted, but no buried drums were found on site.

Air

Air was not monitored on or off site except during removal activities. Perimeter, work area, and exclusion zone perimeter air monitoring were performed during the removal project duration. The airborne concentrations of contaminants during soil excavation activities varied because of wind, weather, and the concentration of contaminants in the soil. No readings above allowable background levels were observed [3]. No adverse health effects are expected as a result of inhalation exposure to vaporized contaminants at this site.

Groundwater

Two aquifer systems are identified at this site: the upper (saprolite) and the lower (bedrock) aquifers. No confining unit was identified at the saprolite-bedrock interface; therefore, the two aquifer systems are assumed to be interconnected hydrologically. Two on-site supply wells and five on-site monitoring wells were sampled.

1. On-site Supply Wells

On-site supply wells were sampled in August 1997 by GEPD contractors. No regulated VOCs, SVOCs, or PCBs were detected in the on-site water supply. No metals were detected above HSRA action levels. Figure 4 shows the location of the supply wells and the levels of contaminants found.

2. On-site Monitoring Wells

Five on-site monitoring wells were installed in the upper aquifer by GEPD contractors in June 1997 and were sampled in August 1997. PCBs were not detected. Nine regulated VOCs and one regulated SVOC were detected at levels exceeding HSRA action levels. The presence of two metals detected above the HSRA action levels are assumed to reflect the elevated turbidity of groundwater samples from both wells and the site geology [5]. Figure 4 shows the location of the monitoring wells and the levels of contaminants found in these wells.

B. Off-site Contamination

Soil

Off-site soil has not been sampled because data analysis results and visual inspection determined that soil contamination is limited to the site.

Groundwater

One off-site monitoring well and twenty-four individual water wells within a one-quarter mile buffer of the site were sampled in June 1997 by GEPD contractors, and in August 1997 and January 1998 by GEPD.

1. Off-site Monitoring Well

One off-site monitoring well was installed in the upper aquifer and sampled in August 1997 by GEPD contractors. PCBs were not detected. One regulated VOC and one metal were detected at levels exceeding HSRA action levels. Figure 4 shows the location of the off-site monitoring well and the levels of contaminants found in this well.

2. Individual Water Wells

Prior to sampling, each well was purged with its pump until stabilization of water quality parameters (e.g. pH, temperature) was achieved. Whenever possible, well samples were collected from a spigot prior to the juncture of the pressure tank. When this was not possible, samples were collected as near to the water source as possible.

Individual water wells were sampled by GEPD contractors in June 1997 and by GEPD in August 1997 and January 1998. No SVOCs or PCBs were reported in samples analyzed by GEPD contractors. Analyses of all of the sampling data indicate that the site is the source of three regulated VOCs above HSRA action levels in five wells near the site [5]. Lead was detected above the HSRA action level initially in three well samples; however, an elevated level of lead was detected only in one out of two samples of a duplicate taken from one well. Elevated levels of lead may be from other sources not associated with the site including plumbing and well construction materials, and site geology in which lead-prone aquifer material (amphibolite) was encountered in subsurface deposits at the site [5]. Cadmium was detected above the HSRA action level in one water well sample, but not in the subsequent sample. Table 6 summarizes individual water well sampling results.

Surface Water

Water samples were collected from three areas of the creek: the suspected contamination entry point, and approximately one-half miles upstream and downstream from the suspected contamination entry point. Lead was the only contaminant exceeding appropriate standards as specified in the GEPD Rules of Water Quality Control. The levels of lead detected could be attributed to natural causes.

C. Quality Assurance and Quality Control

The validity of the analysis and conclusions drawn for this public health assessment are determined by the availability and reliability of the referenced information and assumes that adequate quality assurance and quality control measures about chain-of-custody, laboratory procedures, and data reporting were followed.

The sampling done by GEPD contractors is assumed to have been validated through the GEPD contract laboratory quality assurance program. Based on this assumption, the sampling protocols and analytical results provided data deemed to be of sufficient quality and reproducible enough to be judged as representative of site conditions.

D. Physical and Other Hazards

Physical hazards are present at this site (surficial debris) that do not pose a threat to public health because site access is restricted.


PATHWAYS ANALYSIS

To determine whether nearby residents are exposed to contamination migrating from the site, GDHR evaluates the environmental and human components that determine if a potential or completed exposure pathway exists. An exposure pathway is a description of the process by which a chemical contaminant moves from a source of contamination to a receptor population. This exposure could have occurred in the past, could be occurring now, or could occur in the future. A completed exposure pathway exists if all five of the following elements can be proven to exist: 1) source of contamination, 2) a transport mechanism to the environmental medium; 3) a point of exposure; 4) a route of exposure to the body; and 5) a receptor population.

Exposure pathways are either completed or potential. In completed pathways, all five elements existed at one time or are currently present. In contrast, potential pathways indicate that at least one of the five components is missing, but could have existed, could exist, or might exist in the future.

Though contaminants exist at levels above the HSRA criteria, a public health hazard only exists if there are actual exposures to the contaminants and at high enough doses to result in adverse health effects.

The discussion that follows incorporates only those contaminants and exposure pathways that are relevant to the site.

A. Completed Exposure Pathways

As previously discussed, the improper storage, treatment, and disposal of used oil products have affected on-site soil and groundwater. Two completed exposure pathways exist at this site: ingestion, inhalation, and/or dermal absorption of contaminated on-site soil in the past; and ingestion, inhalation, and/or dermal absorption of contaminated groundwater in the past. Table 7 shows the completed exposure pathways for the site.

On-site Soil

The former operators/employees of the facility were the population at greatest risk for past contact with contaminated soil. No information is available about the operator/employees safety procedures, use of protective equipment, or health status. Other persons who may have been exposed to contaminated soil at this site include facility contractors, guests, trespassers, and nearby residents. Indications are that children have not accessed the site, except in rare circumstances.

Exposure routes through dermal absorption, ingestion, and dust inhalation are possible. A health hazard may have existed for facility operators/employees if they came into contact with the most contaminated soil on a regular basis for an extended period of time. The potential for such exposures to have occurred is minimal because workers were not likely assigned to the areas of highest contamination all day, every day. Consequently, It is unlikely that the presence of contaminants has adversely affected the health of workers. This conclusion is based on the overall low levels of the compounds identified, the relative isolated locations of the contaminated soil (limited to on-site), and the lack of any potential sustained direct or indirect human contact or significant route of exposure (air, water, soil, or food).

Present and future exposure to contaminated soil should not be a concern since the contaminated soil has been excavated, stockpiled, bermed, and a drainage system has been established reducing the likelihood for exposure.

Individual Water Wells

As stated, two aquifer systems are identified at this site, the upper (saprolite) and the lower (bedrock) aquifers. In the upper aquifer, groundwater flow is radial in the site vicinity and mimics the local topography, while the lower aquifer exhibits primary and secondary groundwater flow directions of northwest to southeast and northeast to southwest, respectively. Hydraulic conductivity testing in upper aquifer groundwater monitoring wells revealed values that correspond well within the range of values for aquifers of this type [5]. No monitoring wells were installed in the lower aquifer and the rate of groundwater flow in this aquifer could not be determined.

Results of on-site groundwater sampling indicate that several HSRA-regulated compounds exceed regulatory action levels in the saprolite aquifer. Results of off-site groundwater sampling indicate that three HSRA-regulated VOCs exceed regulatory action levels in both the saprolite and bedrock aquifers. The contamination migration pathways determined for the two aquifers are supported by the contaminant levels detected in on-site monitoring wells and in off-site individual water wells. Based on the data collected to date, there is no conclusive evidence of off-site groundwater contamination by inorganics due to releases from the site.

Individual water wells that are contaminated with VOCs constitute a past completed exposure pathway because residents who are affected have been advised not to use their water, thus eliminating current and future exposures if people are not using the contaminated water. Officials are trying to obtain funding to provide alternate water so that present and future exposure to contaminated groundwater will not occur. Past exposures could have resulted from ingestion of drinking water, inhalation of vapors, and skin absorption from bathing or other domestic water uses.

If a plume exists under housing, the rising vapors might penetrate homes through cracks or drains in the basement or slab flooring and expose residents through inhalation of vapors. Experience indicates that the likelihood of this exposure is usually very low, but can occur.

B. Potential Exposure Pathways

Individual Water Wells

The northwest-striking, vertically dipping fault identified northwest of the site may be the preferred pathway for constituents to migrate from the site. Individual water wells located downgradient and northwest of this structure (and in the accompanying topographic valley) may be affected in the future [5]. If additional wells are contaminated by a migrating plume, residents may be exposed to contaminated groundwater through ingestion, inhalation, and dermal absorption during normal household water use and through inhalation during infiltration of VOCs from the soil into homes. Table 7 shows the potential exposure pathways for the site.

Based on this evaluation, individual water wells in the potential migration plume will continue to be monitored by GEPD, and residents will be notified if contamination is present. These actions will substantially decrease the likelihood of future exposure to contaminated groundwater at a level or duration that could cause adverse health effects.


PUBLIC HEALTH IMPLICATIONS

A. Toxicological Evaluation

GDHR estimated daily doses for those people exposed to contaminants in soil and in drinking water. The doses were then compared to MRLs, which are estimates of daily human exposure to a chemical that are likely to be without an appreciable risk of harmful effects (noncarcinogenic) over a specified duration of exposure. MRLs are based on human and animal studies and are reported for acute (14 days), intermediate (15-364 days), and chronic (365 days) exposures. GDHR also estimated the excess cancer risk for the contaminants of concern.

The contaminants of concern at this site that exceed HSRA action levels for regulated substances are tetrachloroethene (PCE), 1,1,2-trichloroethane (1,1,2-TCA), ethyl benzene, bis(2ethylhexyl) phthalate (DEHP), phenanthrene, naphthalene, arsenic, and lead found in on-site soil, and 1,1-dichloroethene (DCE), trichloroethene (TCE), PCE, cadmium, and lead found in individual water wells.

Soil

Estimates for exposure to naphthalene and arsenic through ingestion of contaminated soil were calculated for adults and not for children due to the site's history of restricted public access. Estimates for exposure to PCE, 1,1,2-TCA, benzene, ethyl benzene, DEHP, and phenanthrene were not calculated because either they did not exceed the appropriate CV or because no toxicological information is available on noncancer health effects. Lead levels in soil did not exceed EPA's recommendation for areas where contact by children is infrequent (2,000-5,000 parts per million [ppm]); therefore, values were not calculated for lead in soil [9].

Groundwater

Estimates for inhalation and ingestion doses of DCE, TCE, and PCE in groundwater were calculated. Inhalation exposure was calculated using the same formula used for ingestion exposure based on studies which predicted that the dose of volatile compounds associated with showering and other normal household water uses is similar to the dose resulting from ingestion [10]. Estimates for cadmium in groundwater were not calculated because the cadmium detected did not exceed the CV. Estimates for lead in groundwater were not calculated because no health guideline (MRL) exists to compare to the calculated dose. We do not know how much lead in drinking water will result in an elevation of blood lead levels; however, exposure to lead should be avoided whenever possible because we do know that the health effects of lead, especially on children, are serious. Estimates for dermal absorption of contaminants were not calculated because dermal absorption is considered negligible for the contaminants of concern.

Based on the values of the exposure doses, none of the estimated doses exceeded MRLs for chronic limited exposure (365 days/year for 15 years [length of operation of facility]). Lifetime cancer risk estimates for individuals exposed to arsenic in soil and DCE, TCE, and PCE in groundwater exceed risk values for adults based on chronic long-term exposure. This estimated cancer risk assumed that exposure to adults would be every day for a total of 15 years (the length of time the facility was in operation). GDHR feels that exposure to the contaminants of concern for the total duration of facility operations is highly improbable. Therefore, the actual increased cancer risk is likely much lower than estimated and may, in fact, be zero.

B. Child Health Initiative

A susceptible population may exhibit a different or enhanced response to some or all of the contaminants found at the Griffith Oil Company site. Reasons for this difference include genetic makeup; developmental stage; age; health and nutritional status (including dietary habits that may increase susceptibility); and substance use (including drugs, tobacco, and alcohol). Health effects are also related to individual characteristics such as age, gender, and nutritional status that influence how a chemical might be absorbed, metabolized, and eliminated by the body, and the individual's potential for noncancer or cancer outcomes. Children with immature and developing organs will be more vulnerable to toxic substances than will healthy adults.

As part of the ATSDR Child Health Initiative, public health assessments must indicate whether any site-related exposures are of particular concern for children.

As previously indicated, children are not at risk of past, present, or future exposure to contaminated soil at this site because of the history of restricted public access. Contaminants in groundwater are not considered to be a health threat to children since no contaminant exceeded the CV and no estimate of exposure dose exceeded the corresponding MRL for children. Based on the results of the cancer risk estimates, as with adults, if children have been exposed to contaminated groundwater every day for fifteen years during the operating period of this facility, they may have a slightly increased risk of cancer from exposure to DCE, TCE, and PCE. However, the probability that chronic exposure occurred over a 15-year period is highly unlikely.


CONCLUSIONS

The conclusions and recommendations are situation-specific.

  1. Residents in the site vicinity are dependent on groundwater supplied from individual water wells for consumption and household use. Past industrial activities at the site have contaminated the aquifer with VOCs at levels above HSRA groundwater action levels. Use of groundwater contaminated by releases from this site in the past, present, and future may cause adverse health effects (slightly increased risk of cancer if used over a long period of time) to sensitive populations. Therefore, the site poses a public health hazard for people who use contaminated well water as their household water supply. Actions have been taken to provide those with affected well water an alternative water supply. For those people who are using an alternative water supply the health hazard has been temporarily eliminated, but a permanent solution is needed and is being sought by GEPD.

  2. People in the area are concerned about their health because of consumption or possible future consumption of contaminated groundwater. To date, a repository has not been established where people can readily access information about the site and about the risk of exposure to site contaminants.

  3. This site was remediated to contain petroleum contamination of on-site soil. The risk of current and future exposure to contaminated soil is minimal following removal activities completed in late 1996. GDHR concludes that past exposure to contaminated soil did not pose a public health hazard since exposure to the levels of hazardous constituents detected resulted in doses below the MRLs for chronic exposure.

  4. The horizontal and vertical extent of groundwater contamination in the site vicinity has not yet been determined. The possibility exists that the previous removal action performed at the site did not completely remove the VOC sources that may still be affecting groundwater on and off the site.

  5. As a HSI Class I site, the GEPD Director has determined that this site requires corrective action. (Sites listed on the HSI are separated into four classes which signify the threat to human health and the environment: Class 1 sites have known human exposure to regulated substances, have known sources of continuing release, or cause serious environmental problems; Class II sites require further evaluation before the need for corrective action is determined; Class III sites meet alternative risk reduction standards, and for Class IV sites, corrective action meeting risk reduction requirements is being or has been conducted under federal or state authority [11]).

  6. As part of the Administrative Order issued by the GEPD Director, the owners have been ordered to determine the extent of soil contamination, perform a hazardous waste determination on any wastes at the site, excavate and remove all soils contaminated above Type 3 risk reduction standards, remove and dispose of all remaining tanks, containers, and vessels, report the results of these activities to GEPD in a timely manner, and submit information on other "responsible parties" and a Compliance Status Report.

RECOMMENDATIONS

The interpretation, advice, and recommendations presented in this public health assessment are based on the data and information referenced and discussion with state environmental officials. Additional data could alter the recommendations. As additional data become available, GDHR will review them and will respond to additional requests.

  1. Establish a public information repository at the Jefferson Public Library for residents to review sampling data and reports pertaining to the site, as the EPA does for federal Superfund sites.

  2. Continue pursuing remediation efforts.

  3. Continue to inform affected residents of the potential exposure pathways and promote behaviors that may decrease their risk of exposure. GEPD is currently supervising these activities.

  4. Continue to encourage the use of alternative water supplies to protect affected residents and continue with plans to provide a permanent alternative water supply.

  5. Continue monitoring individual water wells in the vicinity of the site and initiate appropriate measures to minimize or eliminate exposure. GEPD is currently supervising these activities.

PUBLIC HEALTH ACTION PLAN

GDHR and ATSDR are committed to providing a plan of action to protect public health where recommendations indicate a need.

Actions Completed

GDHR provided this document for public comment at the Jefferson Public Library and at the Athens/Clarke County Library. That action opened the site repositories, and other documents and information may now be made available at the library as they become available.

GEPD has provided information to residents about contamination in their well water. GDHR will provide assistance as needed.

Actions Planned

GEPD is monitoring contaminated wells and is seeking a permanent alternate water supply for affected residents.


PREPARERS AND REVIEWERS OF REPORT

Preparer

Jane Perry Britt, MPH
Consultant
Georgia Department of Human Resources

Reviewers

Jim Brown
Branch Chief
Hazardous Waste Management Branch
Georgia Environmental Protection Division

ATSDR Regional Representative

Robert Safay

ATSDR Technical Project Officers

Gail Godfrey
Division of Health Assessment and Consultation


 

REFERENCES

  1. Georgia Environmental Protection Division, Hazardous Site Response Program, project assignment form, 03/08/95.

  2. Georgia Environmental Protection Division, Hazardous Site Response Program, disposal contract: Troy Lee Griffith Oil Company.

  3. OHM Remediation Services, Corp., final report for demolition of storage tanks, disposal of waste materials, and removal of drums at the Griffith Oil Company in Arcade, GA, 12/96.

  4. Georgia tax map #55.

  5. Tetra Tech Em, Inc., site assessment technical memorandum, Griffith Oil Company site, Jackson County, Georgia, 09/97.

  6. Georgia Environmental Protection Division, rules of Georgia Department of Natural Resources, hazardous site response, chapter 391-3-19, 1992 as amended.

  7. U.S. Environmental Protection Agency, code of federal regulations, 40 CFR 141.1, 07/01/96.

  8. Georgia Department of Natural Resources, rules for safe drinking water, Chapter 391-3-5-.03, 10/16/95 (rev).

  9. U.S. Environmental Protection Agency, recommendations for response activities for residential lead-contaminated bare soil, Federal Register: 60:175, 47247, 09/11/95.

  10. Weisel, C. and Wan-Kuen J., ingestion, inhalation, and dermal exposures to chloroform and trichloroethene from tap water, Environmental Health Perspectives, 104:1, 06/96.

  11. Georgia Environmental Protection Division, Hazardous site inventory, 07/97.

  12. Agency for Toxic Substances and Disease Registry, toxicological profile for trichloroethene (update), 09/97.

  13. Agency for Toxic Substances and Disease Registry, toxicological profile for tetrachloroethene (update), 09/97.

  14. Agency for Toxic Substances and Disease Registry, toxicological profile for 1,1-dichloroethene (update), 05/94.

TABLES

TABLE 1. DEMOGRAPHIC INFORMATION*
Jackson County, Georgia

Population by Age (percentile)

0 - 4 Years

5 - 19 Years

20 - 34 Years

35 - 49 Years

50 - 64 Years

65 Years and Over

1990 Total Population

7.2

22.0

24.2

21.0

13.6

12.0

30,005

Racial Characteristics (percentile)

White

Black

Other Races

Hispanic1

1990 Total Population

89.8

9.7

0.53

0.53

30,005

Annual Income Groups by Household (percentile)

Less than $5,000 $5,000 - $10,000 $10,000 - $14,999 $15,000 - $24,999 $25,000 - $34,999 $35,000 - $49,999 $50,000 - $74,999 $75,000 - or more

7.4

8.8

11.4

21.4

19.4

17.4

10.8

3.5

Population 25 Years Old and Over by Years of School Completed (percentile)

Some School High School Graduate2 Some College Bachelor's Degree Graduate or Professional Degree
45.4 31.9 13.7 6.0 3.0

1 Persons of Hispanic origin may be of any race
2 Includes General Equivalency Diploma
* Source: University of Georgia Cooperative Extension Service, the Georgia county guide, 1994


TABLE 2. COMPARISON OF SOIL SAMPLE RESULTS TO APPLICABLE EXPOSURE COMPARISON VALUES FOR INGESTION*

Contaminant Maximum Level (ppm) Soil Comparison Value*

Estimated Dose (mg/kg/day)
and MRL** (ppm)

Concentration (ppm)

Reference

PCE 3.6 20.0

10.0

RMEG
CREG
NA
1,1,2-TCA 10.0 NA   NA
Benzene 19.6 20.0 CREG NA
Ethyl benzene 72.5 200.0 RMEG NA
DEHP 155.0 NA   NA
Phenanthrene 580.0 NA   NA
Naphthalene 117.0 40.0 EMEG Adult: 0.00008
MRL= 0.021
Arsenic 84.8 0.5

0.6

EMEG
CREG
Adult: 0.00006
MRL= 0.0003
Lead 559.0 NA   NA

ppm: parts per million
mg/kg/day: milligrams per kilogram body weight per day
RMEG: Reference Dose Media Evaluation Guide
CREG: Cancer Risk Evaluation Guide (1x106 excess cancer risk)
EMEG: Environmental Media Evaluation Guide
MRL: Minimal Risk Level. MRLs are based on chronic oral exposure unless otherwise indicated.
1 Based on intermediate oral exposure. No chronic exposure MRL for naphthalene has been determined.
NA: Not applicable. No CV or MRL available.
* Source: ATSDR, Drinking water comparison values (expires 06/30/98)
** Source: ATSDR, Health guidelines comparison values (expires 06/30/98)


TABLE 3. COMPARISON OF INDIVIDUAL WATER WELL SAMPLE RESULTS TO APPLICABLE EXPOSURE COMPARISON VALUES FOR INGESTION*

Contaminant Maximum Level (µg/L) Drinking Water Comparison Value*

Estimated Dose (mg/kg/day)
and MRL** (ppm)

Concentration (µg/L)

Reference

1,1-dichloroethene 73.7 0.06
7.0
CREG
MCL
Child: 0.007 Adult: 0.002 MRL= 0.009
Trichloroethene 60.8 3.0
5.0
CREG
MCL
Child: 0.006
Adult: 0.002 MRL=0.21
Tetrachloroethene 93.5 0.7
5.0
CREG
MCL
Child: 0.009
Adult: 0.003
MRL= 0.052
Cadmium 6.8 7.0
5.0
EMEG
MCL
NA
Lead 110.0 15.0
15.0
HSRA
MCL
NA

µg/L: micrograms per liter
mg/kg: milligrams per kilogram
CREG: Cancer Risk Evaluation Guide (1x106 excess cancer risk)
EMEG: Environmental Media Evaluation Guide
HSRA: Hazardous Site Response Act
MCL: Maximum Contaminant Level
MRL: Minimal Risk Level. All MRLs are based on chronic exposure unless otherwise indicated.
NA: Not Applicable (concentration does not exceed CV; no MRL exists).
1 Based on acute oral exposure. No intermediate or chronic oral exposure MRLs have been derived for trichloroethene because the available intermediate and chronic duration data are limited by lack of applicable information [12].
2 Based on acute oral exposure. No intermediate or chronic oral exposure MRLs have been derived for tetrachloroethene because the available intermediate and chronic duration data are limited by lack of applicable information [13].
* Source: ATSDR, Drinking water comparison values (expires 3/98)
** Source: ATSDR, Health guidelines comparison values (expires 3/98)


TABLE 4. COMPARISON OF INDIVIDUAL WATER WELL SAMPLE RESULTS TO APPLICABLE EXPOSURE COMPARISON VALUES FOR INHALATION*
(Based on the assumption that the amount of contaminant absorbed through the lungs is equivalent to the ingested dose)

Contaminant Maximum Level (µg/L) Drinking Water Comparison Value*

Estimated Dose (mg/kg/day)
and MRL** (ppm)

Concentration (µg/L)

Reference

1,1-dichloroethene 73.7 0.06
7.0
CREG
MCL
Child: 0.007
Adult: 0.002
MRL=0.021
Trichloroethene 60.8 3.0
5.0
CREG
MCL
Child: 0.006
Adult: 0.002
MRL=0.12
Tetrachloroethene 93.5 0.7
5.0
CREG
MCL
Child: 0.009
Adult: 0.003
MRL= 0.04
Cadmium 6.8 7.0
5.0
EMEG
MCL
NA
Lead 110.0 15.0
15.0
HSRA
MCL
NA

µg/L: micrograms per liter
mg/kg: milligrams per kilogram
CREG: Cancer Risk Evaluation Guide (1x106 excess cancer risk)
EMEG: Environmental Media Evaluation Guide
HSRA: Hazardous Site Response Act
MCL: Maximum Contaminant Level
MRL: Minimal Risk Level. All MRLs are based on chronic exposure unless otherwise indicated.
NA: Not Applicable (concentration does not exceed CV; no MRL exists).
1 Based on intermediate inhalation exposure. No chronic inhalation exposure MRL has been derived for 1,1-dichloroethene because the available chronic duration data are limited by lack of applicable information [14].
2 Based on intermediate inhalation exposure. No chronic inhalation exposure MRL has been derived for trichloroethene because the available chronic duration data are limited by lack of applicable information [12].
* Source: ATSDR, Drinking water comparison values (expires 06/30/98)
** Source: ATSDR, Health guidelines comparison values (expires 06/30/98).


TABLE 5. COMPARISON OF REMOVAL ACTION SOILS RESULTS TO APPLICABLE HSRA RISK REDUCTION STANDARDS (RRS)*

Constituent

Maximum Level (ppm)

Soil Exposure1 (mg/kg)

Groundwater Protection Criteria (mg/kg)

Type 3 RRS

Type 1 RRS

Appendix III Table 2

100 x Appendix III Table 1

Appendix I

PCE 3.61 1,100 120 NA 0.5 0.18
1,1,2-TCA 10 80 8 NA 0.5. 0.5
Benzene 19.6 50 5 NA 0.5 0.02
Ethyl benzene 72.5 26,000 2,600 NA 70 20
DEHP 155 4,100 460 NA NA 50
Phenanthrene 580 NA NA NA NA 110
Naphthalene 117 18,000 1,800 NA 2 100
Lead 559 NA 4002 75 NA NA
Arsenic 84.8 38 4.3 20 NA NA

NA: Not Applicable
PCE: tetrachloroethane
1,1,2-TCA: 1,1,2-trichloroethane
DEHP: bis(2ethyl hexyl)phthalate
1 Based on U.S. Environmental Protection Agency (EPA), Region III, risk-based concentration tables, 03/17/97, considering direct soil exposure and inhalation of volatiles.
2 EPA-recommended lead cleanup level based on toxic effects to children.
* Source: Tetra Tech Em, Inc., site assessment technical memorandum, Griffith Oil Company site, Jackson County, Georgia, 09/97.


TABLE 6. ANALYTICAL RESULTS FROM INDIVIDUAL WATER WELL SAMPLING*

Sample ID Sample Date HSRA Action Level IW-1 IW-1D IW-2 IW-3 IW-4 IW-5 IW-6 IW-7 IW-8 IW-8D
  Volatile Organic Compounds (ug/L)
1,1-Dichloroethene 6/24/97
8/20/97
1/28/98
7 <5.0
--
--
<5.0
--
--
<5.0
--
--
18.0
--
--
--
67.3
66.9
--
21.0
Trace
--
--
--
--
--
--
--
--
73.6
--
--
73.7
Trichloroethene 6/24/97
8/20/97
1/28/98
5 <5.0
Trace
--
<5.0
--
--
<5.0
--
--
36.0
--
--
--
39.4
44.4
--
25.9
--
--
--
--
--
--
--
--
--
60.7
--
--
60.8
Tetrachloroethene 6/24/97
8/20/97
1/28/98
5 15.0
14.5
--
14.0
--
--
<5.0
--
--
37.0
--
--
--
78.7
78.5
--
45.4
--
--
Trace
Trace
--
--
--
--
--
93.3
--
--
93.5
  Metals (ug/L)
Cadmium 6/24/97
8/20/97
1/28/98
5 <5
--
--
<5
--
--
<5
--
--
<5
--
--
--
--
--
--
--
--
--
--
--
--
6.8
--
--
--
--
--
--
--
Lead 6/24/97
8/20/97
1/28/98
15 <5
2.6
--
<5
--
--
24.0
1.7
--
<5
--
--
--
2.4
4.0
--
2.6
--
--
21.0D
4.5
--
110.0
2.7
--
--
8.6
--
--
4.2

HSRA: Hazardous Site Response Act
IW: Individual water well
D: Duplicate sample
µg/L: micrograms per liter
Bold highlight: result exceeds HSRA action level
--: Not tested for
* Source: OHM Remediation Services, Corp., final report for demolition of storage tanks, disposal of waste materials, and removal of drums at the Griffith Oil Company in Arcade, GA, 12/96; Georgia Environmental Protection Division, residential wells near Griffith Oil Company, 08/20/97, 01/28/98


TABLE 7. EXPOSURE PATHWAYS

Completed Exposure Pathways

Pathway Name Source Medium Exposure Point Exposure Route Receptor Population Time of Exposure
On-site soil Site Soil On-site soil Ingestion Former employees:
< 50
Past
On-site soil Site Soil On-site soil Inhalation Former employees:
< 50
Past
Off-site groundwater Site Groundwater Off-site groundwater Ingestion Nearby residents using contaminated well water:
Approx. 221
Past
Off-site groundwater Site Groundwater Off-site groundwater Inhalation Nearby residents using contaminated well water:
Approx. 22 1
Past
Pathway Name Source Medium Exposure Point Exposure Route Receptor Population Time of Exposure
Off-site groundwater Site Groundwater Off-site groundwater Ingestion Unknown Future
Off-site groundwater Site Groundwater Off-site groundwater Inhalation Unknown Future

1 Based on 1990 census data, Jackson County, GA population: households

Potential Exposure Pathways



FIGURES

Site Location
Figure 1. Site Location

Site Photographs Showing Key Features Site Photographs Showing Key Features
Figure 2. Site Photographs Showing Key Features

Site Map
Figure 3. Site Map

Levels of Contamination In and Location of On-Site Wells
Figure 4. Levels of Contamination In and Location of On-Site Wells


RESPONSES TO PUBLIC COMMENTS

The comments presented in this section were sent to ATSDR during the public comment period for the Griffith Oil Company Public Health Aassessment. The list of comments does not include editorial comments or comments on accuracy of stated facts. If the accuracy of a statement was questioned, the statement was verified or corrected. Comments which requested that additional information be added to the document without provided documented sources of that information are not addressed.

Comment 1: You say in the Conclusions section that actions have been taken to provide an alternative water supply. What actions?

Response: As stated in the Background section, Arcade officials applied for a federal Community Development Block Grant to help finance connecting residences near the site to the Jackson County water supply. In March 1998, this request was denied. Officials reapplied in 1998. Other funding sources are being explored by local officials with support from GEPD to provide connection to the Jackson County water supply and to assist the affected residents financially with installation costs for water filters or the purchase of bottled water.

Comment 2: You have based your conclusions on samplings of "contractors." Very little testing was done (i.e. no monitoring wells were installed in the lower aquifer.)

Response: GDHR realizes that limited groundwater sampling by agencies and contractors has occurred and recommends that GEPD continue to monitor individual water wells near the site. Results of samples taken from the upper aquifer indicated that the groundwater should not be used as a water source. GDHR and ATSDR are concerned about the quality of water that people drink or use for household and other purposes. Although GEPD may decide at some point to further investigate deeper groundwater quality, GDHR and ATSDR do not see a need to recommend that unless a possibility exits that someone may eventually use deeper groundwater.

Comment 3: You have made no attempt to give physical exams to anyone in the area.

Response: The term "public health assessment" is often interpreted by community members to mean that we are going to provide medical examinations or medical care. ATSDR and GDHR are not authorized to conduct such activities. The purpose of the public health assessment process is to assess the public health needs of communities affected by a release of hazardous substances. Public health assessment activities are initial evaluations of site-specific exposures and use existing data to make follow-up recommendations. At this time, we do not believe that people have been exposed to high enough levels of contaminants over a period of time that would result in adverse health effects; however, if someone continues to use the contaminated water over their lifetime, that person could have an increased risk of developing cancer. Because alternate water is provided and measures are being taken to find a permanent alternate water source, GDHR and ATSDR do not feel that people need to be referred to their physicians or health care provider for health follow-up. Please feel free to provide information in this document to your physician or health care provider if you are still concerned about your exposure.

Comment 4: Why don't you spend money on a pipeline? That would solve the problem.

Response: GDHR recommends that an alternative water supply be provided for affected residents. Access to the county water supply is one alternative, but GDHR has no regulatory authority to direct which alternative water supply will be selected.

Comment 5: You have done very little and highly suspect testing. This report is a bureaucratic whitewash.

Response: GDHR has enough information collected from private drinking water wells to support a decision for finding an alternate water supply for affected residences. Stopping exposure is our primary concern. Sampling is done systematically, and progress is slow. Additional sampling may be done if GEPD feels they need more to properly clean up the site.

Comment 6: The report is unnecessary because it is based on inconclusive testing. We are at risk to our health.

Response: Enough information was available to provide a health perspective for the environmental agency to complete their work. We all agree that people with contaminated well water should be provided an alternate water source. This document supports that conclusion based on available data. Other data that may become available in the future can also be evaluated for any public health implications. What is important to the health of those in the affected community is to stop current exposure and work toward preventing future exposures. Also, GEPD is working toward preventing further degradation of the environment as the result of site contamination. The process is a slow one.

Comment: Because we are a low income area, GEPD had the site inspected during operation and let it continue to operate. The county and state engineers say clean up did not get all of the contamination and it is still around and spreading.

Response: The facility was not required to be permitted by the Georgia Environmental Protection Division (GEPD) because it did not report the treatment, storage, or disposal of hazardous waste as required by law. As a used oil treatment/storage/disposal facility, the owners were required by federal regulations to provide notice to GEPD which conducted periodic inspections. The site has been classified as a HSI Class I site. This designates the site as needing corrective action. This designation was made based upon the documentation of several individual water wells which continue to be contaminated by releases from the site. The legal process to completely correct conditions is slow and is often frustrating to those who live near these sites. GEPD is working hard to correct the conditions.


CERTIFICATION

This Griffith Oil Company Public Health Assessment was prepared by the Georgia Department of Human Resources under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the public health assessment was begun.

Gail D. Godfrey
Technical Project Officer, SPS, RPB, DHAC


The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health assessment and concurs with the findings.

Richard Gillig
Chief, SPS, SSAB, DHAC, ATSDR



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