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HEALTH CONSULTATION

PYROTECHNIC SPECIALTIES, INCORPORATED
BYRON, PEACH COUNTY, GEORGIA


STATEMENT OF ISSUES

The Georgia Division of Public Health (GDPH) was asked by the Agency for Toxic Substances and Disease Registry (ATSDR) to conduct a public health consultation of Pyrotechnic Specialties, Inc. (PSI) in Byron, Peach County, Georgia. In January 2002, ATSDR received a petition regarding PSI from a community group requesting the agency to conduct a public health assessment at the facility. ATSDR determined that a public health consultation was an appropriate activity to respond to the petition. The purpose of this health consultation is to determine the potential for adverse health effects from exposure to on-site and off-site environmental contamination generated by PSI and to consider the need for additional public health actions.

GDPH has reviewed citizens' concerns and environmental sampling data provided by the Georgia Environmental Protection Division (GEPD). This health consultation evaluates potential pathways of exposure to contaminated groundwater, surface water, and soil.


SITE DESCRIPTION AND HISTORY

Pyrotechnic Specialties, Inc. (PSI) is located at 1661 Juniper Creek Road, in Byron, Peach County, Georgia. The facility is located approximately 2 miles north of downtown Byron. PSI also owns a closed solid waste landfill located across the street from the facility. The closed landfill is situated on approximately 28 acres of land. South of PSI is a wooded area which drains into a tributary of Juniper Creek. A wooded area and a small residential community are west of PSI. Scattered trailer homes are located northwest/northeast of the facility and extend approximately 1 mile from PSI along Juniper Creek Road (see Figure 1). Approximately 630 people live within 1 mile of the site. The Peach Metals facility is located 1 mile east of PSI. Property boundaries of the two facilities are adjacent to each other.

PSI is located on approximately 244 acres of land that was once used as a Nike Missile Battery that was owned and operated by the U.S. Department of Defense (DOD). Nike missile batteries were located across the United States in the 1950s and 1960s and used for national air defense. DOD sold the facility to ICI Americas, Inc. (ICI) in 1968. ICI modified and/or added multiple structures to the facility. PSI purchased the facility from ICI in 1991. About 50 acres of land is currently being used by PSI for production and storage of pyrotechnic devices and explosives under contracts with DOD and others. The site consists of 118 buildings that include several storage sheds (located near production areas), used for storing hazardous waste, and bunkers, used to store pyrotechnic devices and explosives. The remaining 194 acres are wooded. The property is surrounded by 6-foot-high chain link fence and a security guard is on duty 12 hours per day, 5 days a week. All entry gates are locked when personnel are not at the facility [1].

In 1991, ICI requested an environmental assessment of the site before the property was purchased by PSI. Westinghouse Environmental and Geotechnical Services (Westinghouse) completed a groundwater study at the site in August 1991. The objective of the study was to evaluate the environmental impact of manufacturing activities at the facility and to determine what impact, if any, manufacturing activities had on groundwater in the surrounding area [1]. Results are reviewed in the Discussion section of this health consultation.

PSI Process Description

PSI manufactures pyrotechnic products and compositions, pelletizes these compositions, and assembles explosives for DOD, aerospace industries, and automotive companies. The production line includes fuses, safety devices, tracers, demolition devices, ignition elements, and igniters.

After all stages of production are completed, PSI decontaminates the walls and all equipment used during production. Hazardous waste is generated throughout the production process and during the final decontamination stage. Before 1998, the wastewater Exiting ATSDR Website generated from decontamination was discharged by a drainage system into a concrete sump and pumped into evaporation tanks. The evaporation tanks were heated to evaporate moisture from the discharge. The remaining sludge Exiting ATSDR Website was transported to an open burn (OB) unit and burned with other waste material. Besides evaporation tank sludge, the types of waste burned in the OB unit included solvent soaked rags, reactive waste, barium, chromium, lead, and lead azide containing waste. Lead azide, used in the production of lead detonators, is considered highly toxic, highly reactive and extremely dangerous because it is shock sensitive [2].

Regulatory History

The GEPD Hazardous Waste Branch has conducted numerous compliance evaluation inspections (CEIs) at PSI since 1996. The most significant compliance violation noted was treatment of hazardous waste by open burning without a permit. PSI had conducted open burning of its hazardous waste since purchasing the facility from ICI in 1991. Before PSI, ICI had also conducted open burning of its hazardous waste since 1968. GEPD required PSI to apply for a Hazardous Waste Facility Permit in 1997. A Consent Order was issued by GEPD on February 2, 1998, because PSI failed to meet the requirements of an application for a Hazardous Waste Facility Permit [4]. Open burning of hazardous waste continued at PSI without regard to environmental regulations [1].

On December 2, 1998, GEPD issued a directive prohibiting the treatment and storage of hazardous waste at the facility until (1) PSI complied with regulations for financial assurance requirements pursuant to the application for a Hazardous Waste Facility Permit, and (2) until the company demonstrated that emissions from the OB unit were not a threat to human health and the environment [1]. To date, PSI has not provided any air monitoring data on emissions from the OB unit.

GEPD and PSI met on August 3, 1999, to discuss deficiencies noted by GEPD in PSI's permit application. PSI disclosed that hazardous waste was still being burned in the OB unit [1]. On September 13, 1999, GEPD issued Administrative Order requiring PSI to immediately cease the treatment and storage of hazardous waste at the facility until a permit authorizing these activities is issued by GEPD [5]. On February 8, 2000, GEPD petitioned to have the Administrative Order enforced by an Order of the Court because PSI was still out of compliance [1]. The Superior Court of Peach County ordered PSI to comply with the Administrative Order on November 25, 2002 [6].

In addition to the above regulatory actions, GEPD has noted on numerous CEIs, indications of previous hazardous waste releases that have occurred at the facility. Although several releases have been documented, one of the most significant hazardous waste releases resulted from discharging hazardous waste from a sink located in a production area building into a buried drum outside the building. The fate of the disposed waste is unknown because the drum has never been emptied or removed.

Aside from a Hazardous Waste Facility Permit, PSI has several other permits issued for its facility. These permits include the following:

  • Storm Water Discharges from Industrial Activity Permit (issued by the Georgia Department of Natural Resources Water Protection Branch)

  • Purchase, Sell, Store, Transport, Manufacture Explosive License (issued by the Office of Georgia Safety Fire Commission)

  • Hazardous Material Certification of Registration (issued by the U.S. Department of Transportation)

  • License/Permit for the Manufacture of High Explosives (issued by the U.S. Department of Treasury, Bureau of Alcohol, Tobacco, and Firearms)

Groundwater Use

Water supply wells in the Byron area are reported to derive water from well depths of 90 to 600 feet. The deeper (400 to 500 feet in depth) of these are public water supply wells for Byron and the vicinity. The Byron well field is located approximately 2 miles southeast of PSI. Private drinking water wells in the area have been reported at a total depth of 90 to 140 feet [2]. Potable water used at PSI is supplied by two drinking water wells located on the site.


DISCUSSION

Consultation Methodology

For each environmental medium (e.g., air, soil, groundwater), GDPH examines the types and concentrations of hazardous contaminants. In preparing this document, GDPH used ATSDR comparison values to screen contaminant levels and to determine the chemicals of concern (i.e., chemicals that exceed one or more comparison value) which warrant further evaluation. Comparison values are concentrations of chemicals that can reasonably, and conservatively, be regarded as harmless, assuming default conditions of exposure. Comparison values generally incorporate ample safety factors to ensure protection of sensitive populations (e.g., children and the elderly). Because comparison values do not represent thresholds of toxicity, exposure to contaminant concentrations at levels above comparison values will not necessarily lead to adverse health effects. The comparison values used in this document are discussed further in Appendix B. GDPH then considers how people might come into contact with the contaminant(s). Because the level of exposure depends upon the route of exposure and the concentration of the contaminants, this exposure information is essential to determine whether a public health hazard exists.

Groundwater Exposure Pathway

Groundwater refers to bodies of water, or aquifers, which lie under the Earth's surface. Groundwater can become contaminated when chemicals migrate or leach from soils or from contaminated areas into an underlying aquifer. Water typically flows at a slow rate through an aquifer, thus lessening the chance of contaminant migration. Wells and springs are supplied by groundwater, and it is only through drinking or other domestic uses of well and spring water (e.g., bathing, cooking, or irrigating) that people are directly exposed to contaminated groundwater.

Groundwater Quality Data

On-site Evaluation

In 1991, Westinghouse conducted a groundwater characterization study. The objective of the study was to evaluate the environmental impact of manufacturing activities at the facility to determine the impact, if any; manufacturing activities had on groundwater in the surrounding area [1].

The study included sampling groundwater from five monitoring wells installed in June 1991. The monitoring wells included four downgradient monitoring wells (MW-1, MW-2, MW-3, and MW-4), and one upgradient well (UGM-1) used for background purposes. The well depths ranged from 26 feet below ground surface (bgs) to 56 feet bgs. Westinghouse collected samples from each monitoring well and submitted the samples for analysis. The groundwater samples were analyzed for volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs), pesticides, polychlorinated biphenyls (PCBs), dissolved metals, cyanide, and nitrate. Analytical results indicated that trichloroethylene (TCE) was the only contaminant detected. MW-3 contained 5 micrograms per liter (µg/L) TCE and MW-4 contained 14 µg/L TCE [1]. Results from MW-4 exceeded the regulatory drinking water maximum contaminant level for TCE, which is 5 µg/L (see Appendix B). Given that available data on groundwater analysis is over a decade old, and that manufacturing activities have taken place at the facility since then, further characterization is needed. If groundwater contamination exists, delineation of the vertical and horizontal extent of contamination would be required to make sound public health conclusions.

Potable water for PSI is supplied by two drinking water wells located on site. GEPD has not sampled these wells and does not have any data on these wells. It is not known whether these wells are contaminated with TCE or any other regulated contaminant. Exposure to contaminated groundwater might occur through ingestion by employees at the facility (Table 1).

Table 1. Potential Exposure Pathways

Pathway Exposure Pathway Elements Time
  Source Medium Point of Exposure Route of Exposure Exposed Population  
On-site groundwater Past hazardous waste spillage and on-site disposal Groundwater Well water Ingestion, dermal absorption, inhalation Current employees
(80-100)
Past, present, future

Off-site Evaluation

A visual survey conducted by GDPH on January 31, 2003, did not indicate the presence of private well houses at residences located within approximately 1/2 mile northwest and northeast of PSI. However, during GEPD's 1991 environmental investigation of the Peach Metal facility located east of and adjacent to PSI, GEPD sampled drinking water wells from seven residences located within one mile from the Peach Metal facility. Drinking water was sampled for fecal coliform, cyanide, nitrates, metals, and VOCs. In all seven cases, analytical results indicated non-detect for all the hazardous constituents included in the analysis. At the request of the community group who petitioned ATSDR, GEPD sampled these seven wells for the same parameters again in March 2002. In all seven cases, analytical results indicated non-detect for all the hazardous constituents included in the analysis [7]

GEPD also confirmed that residences located within ½ mile of the PSI area are connected to the Byron public water supply [8]. The Byron supply wells draw from a deep (~460 feet below ground surface) Cretaceous Sand Aquifer confined by bedrock, which helps prevent contamination from surface sources. According to Byron's 2001 Annual Water Quality Report, the quality of Byron drinking water surpasses federal and state drinking water quality standards [9]. Furthermore, Byron's water is sampled daily to ensure public health protection. Therefore, residents utilizing this source of drinking water are unlikely to be exposed to contaminated groundwater.

Groundwater at PSI's closed landfill across the street from the facility has never been sampled. Because of historical manufacturing activities, and because this landfill was used for soild waste disposal, the potential for groundwater contamination exists. Therefore, further characterization is needed. If groundwater contamination exists, delineation of the vertical and horizontal extent of contamination would be required to make sound public health conclusions.

Soil and Surface Water Quality Data

Soil sampling and surface water sampling data pertaining to PSI has not been obtained. However, according to the GEPD Resource Conservation and Recovery Act (RCRA) Facility Assessment (RFA) completed in December 2001, several areas of concern require further investigation. Evidence of dilapidated and leaking hazardous waste storage drums, discolored soil, and drainage pathways next to production areas and hazardous waste storage sites were noted by GEPD. Furthermore, past open burning activities were likely to have left residuals of lead and other heavy metals in the soil surrounding the open burn area.

Moreover, soil at PSI's closed landfill across the street from the facility has never been sampled. Because of historical manufacturing activities, and because this landfill was used for solid waste disposal, the potential for soil contamination exists. Therefore, further characterization is needed. If soil contamination exists, delineation of the vertical and horizontal extent of contamination would be required to make sound public health conclusions.

Because areas of concern were noted in the RFA, PSI will now be required to submit a RCRA Facility Investigation (RFI) workplan to describe how each area of concern will be investigated. This includes an assessment of potential soil, surface water, and groundwater contamination. After the RFI workplan is approved by GEPD, PSI will be required to implement the workplan and submit the results in a report to GEPD. On the basis of the results of the report, corrective action might be required at PSI to remediate any contaminated areas.


COMMUNITY HEALTH CONCERNS

Citizens living near PSI and the Peach Metals Industries facility formed Middle Georgia Advisory Group (MGAG), a local advisory group to express concerns about environmental contamination stemming from these facilities. The MGAG petition letter stated that an unusual amount of people living in the community are being diagnosed with rare neurological conditions, blood disease, and cancer.

Regarding PSI, the extent of groundwater, surface water, and soil contamination has not been determined. Although groundwater-monitoring wells have showed the presence of hazardous contaminants in the past, solid conclusions about public health hazards cannot be made because of the lack of available data describing the extent of contamination. However, off-site exposure pathways have not been determined. Moreover, residences located near PSI area are connected to the Byron public water supply.


CHILD HEALTH CONSIDERATIONS

The ATSDR and GDPH recognize that the unique vulnerabilities of infants and children demand special emphasis in communities faced with contamination of their water, soil, air, or food. Children are more likely to be exposed because they play outdoors and they often bring food into contaminated areas. Children are more likely to come into contact with dust, soil, and heavy vapors close to the ground. Also, children receive higher doses of chemical exposure due to lower body weights. The developing body systems of children can sustain permanent damage if toxic exposure occurs during critical growth stages.

At PSI, GDPH found no completed exposure pathways for children. Children might be potentially exposed to site-related contaminants of concern if children are brought on site and consume potentially contaminated well water; however, this does not seem likely to occur presently or in the past.


CONCLUSIONS

GDPH developed the following conclusions and assigned a public health hazard category to the site. A description of public health categories is provided in Appendix A.

GDPH considers this site to be an indeterminate public health hazard. Specifically, we conclude the following:

  1. Past, current, and future employees might be/might have been exposed contamination because PSI provides its water needs via two drinking water wells located on site. However, the health threat posed by exposures is not known because potential levels of contamination are not known.

  2. The extent and magnitude of contamination of groundwater at and near PSI has not been fully characterized.

  3. Residents living in the vicinity of PSI are connected to the Byron public water supply, where samples are analyzed daily to ensure the public has a safe drinking water supply. The consumption of water from this supply is not a health hazard.

  4. The extent and magnitude of groundwater contamination beneath the PSI site, and at the closed solid waste landfill located across the street from PSI, have not been fully characterized.

  5. The extent and magnitude of soil and surface water contamination at PSI has not been fully characterized.

RECOMMENDATIONS

These recommendations identify actions that GDPH has determined necessary to reduce and to further characterize potential public health hazards associated with the PSI site.

  1. Develop sampling plans for potable drinking water at PSI to analyze for hazardous constituents using methodologies having detection limits that are protective of public health.

  2. Restrict the use of groundwater for drinking on the site until the extent and characterization of groundwater contamination is completed.

  3. Verify the presence of any wells located adjacent to or downgradient of PSI. If any presently used wells are found adjacent to or downgradient of PSI, determine if these wells have been affected by site-related contaminants at levels that represent a public health concern.

  4. Delineate the vertical and horizontal extent of groundwater contamination at PSI so that sound public health conclusions can be made on the basis of scientific evidence.

  5. Determine if soil and groundwater underneath the closed landfill, formerly used by PSI and its predecessors, is contaminated. If it is contaminated, delineate the vertical and horizontal extents of soil and groundwater contamination and contaminant levels.

  6. Determine whether groundwater contamination and rainwater runoff from potentially contaminated soil at PSI result in subsequent surface water contamination of the tributary to Juniper Creek located on PSI's property.


PUBLIC HEALTH ACTION PLAN

Actions Completed

  1. GDPH attended a public meeting in Byron, Georgia, and provided educational materials to the community.

  2. GDPH mailed information about cancer to a representative of the Middle Georgia Citizens Advisory Group.

  3. GDPH conducted a site visit in January 2003.

Actions planned

  1. GDPH will continue to work with GEPD if a corrective action plan for the facility is required based on the results of the RCRA Facility Investigation. GDPH will review any relevant new data to evaluate exposures to people and will make additional recommendations if appropriate.

  2. GEPD will conduct and/or oversee additional contaminant characterization, on-site well sampling, and additional surveys of community wells.

  3. GDPH will mail a copy of this health consultation to the community group that petitioned ATSDR for a health consultation.

  4. GDPH will establish a public information repository at the Peach County Public Library for residents to review public health reports pertaining to the site.

  5. GDPH will provide health education to the community as requested.

PREPARERS AND REVIEWERS OF REPORT

Author

Franklin Sanchez, B.S.
Chemical Hazards Program
Georgia Division of Public Health


Reviewers

Jane Perry, M.P.H.
Chemical Hazards Program
Georgia Division of Public Health

Lornette Harvey
Hazardous Site Response Program
Georgia Environmental Protection Division

CAPT John Steward, R.E.H.S, M.P.H.,
Technical Project Officer
Agency for Toxic Substances and Disease Registry

Robert E. Safay, M.S.
Senior Regional Representative
Agency for Toxic Substances and Disease Registry


REFERENCES

  1. Georgia Department of Natural Resources, Environmental Protection Division. 2001.RCRA Facility Assessment-Pyrotechnics Specialties, Inc. (Dec.)

  2. Hawley's Condensed Chemical Dictionary, 12th Ed. 1993. New York: John Wiley and Sons, Inc.

  3. Le Grand HE. 1962. Geology and Groundwater Resources in the Macon Area, Georgia. Georgia Geological Survey Bulletin No. 72.

  4. Georgia Department of Natural Resources, Environmental Protection Division. 1988. Consent Order EPD-HW-1290. (Feb. 2)

  5. Georgia Department of Natural Resources, Environmental Protection Division, 1999. Administrative Order EPD-HW-1339. (Sep.3)

  6. Superior Court of Peach County, State of Georgia. 2002. Motion For Judgment In Accordance With An Order of the Environmental Protection Division, State Of Georgia Civil Action No. 02-V-506. (Nov. 25)

  7. Georgia Department of Natural Resources, Environmental Protection Division. Certified Laboratory Report. March, 2002.

  8. Harvey L. Georgia Department of Natural Resources, Environmental Protection Division. Personal communication from L. Harvey to F. Sanchez confirming that residences located near PSI are connected to the Byron public water supply. February 5, 2003

  9. City of Byron. 2001. Water Quality Report, Jan 2002-Dec 2001

CERTIFICATION

The Georgia Department of Human Resources prepared this health consultation for Pyrotechnic Specialties, Inc., Byron, Peach County, Georgia, under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). This health consultation was conducted in accordance with approved methodology and procedures existing at the time the health consultation was begun.

Technical Project Officer, SPS, RPB, DHAC


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

Lisa C. Hayes
for Chief, SSAB, DHAC, ATSDR


Intro Map
Figure 1. Intro Map


APPENDIX A: ATSDR CATEGORIES OF PUBLIC HEALTH HAZARDS

No Public Health Hazard

A category used in ATSDR's public health assessment documents for sites at which people have never been and never will come into contact with harmful amounts of site-related substances.

No Apparent Public Health Hazard

A category used in ATSDR's public health assessments for sites at which human exposure to contaminated environmental media might be occurring, might have occurred in the past, or might occur in the future, but the exposure is not expected to cause any harmful health effects

Indeterminate Public Health Hazard

The category used in ATSDR's public health assessments for sites at which a professional judgment of the level of health hazard cannot be made because information critical to such a decision is lacking.

Public Health Hazard

A category used in ATSDR's public health assessments for sites that pose a public health hazard because of long-term environmental exposures (greater than 1 year) to sufficiently high levels of hazardous substances or radionuclides that could result in harmful health effects

Urgent Public Health Hazard

A category used in ATSDR's public health assessments for sites at which short-term exposures (less than 1 year) to hazardous substances or conditions might result in harmful health effects that require rapid intervention.


APPENDIX B: ATSDR COMPARISON VALUES

Comparison values are contaminant concentrations that are found in specific environmental media (air, soil, and drinking water) and are used to select these contaminants for further evaluation if people are exposed to the contamination. The comparison value used in this document is defined in the following below.

Environmental Media Evaluation Guides (EMEGs) are specific comparison values developed by ATSDR for use in selecting environmental contaminants for non-cancer health concerns. EMEG's are derived from Minimal Risk Levels (see below). Exposure to a level of contaminant below this level should not result in any noncancer, adverse health effects.

Maximum Contaminant Levels (MCLs) are the maximum permissible levels of contaminants allowed in public water supplies. The U.S. Environmental Protection Agency (EPA) deems exposure over a lifetime (70 years) to the MCL protective of Public Health at an exposure rate of drinking 2 liters of water per day for an adult and 1 liter of water per day for a child. In addition to health considerations, the available technologies to decrease levels and other engineering and economic considerations are used when establishing MCL's.



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