PETITIONED PUBLIC HEALTH ASSESSMENT
T.H. AGRICULTURE AND NUTRITION (ALBANY)
ALBANY, DOUGHERTY COUNTY, GEORGIA
The Agency for Toxic Substances and Disease Registry (ATSDR) received a petition for a public health assessment of the T.H. Agriculture & Nutrition (THAN) site in Albany, Georgia, in 1992. To address concerns expressed by the THAN petitioner, ATSDR evaluated environmental data for on-site air, off-site air, surface water, sediment, and groundwater. Based on ATSDR's review and evaluation of relevant environmental sampling data, ATSDR concluded the THAN site poses no apparent public health hazard.
Specifically, available air sampling data indicate that contaminants were not at levels of health concern either before or during the low temperature thermal desorption of on-site soils. The contaminants detected in surface water and sediment in the south pond and in the depression area are below levels of health concern. Perimeter wells installed at the outer edges of the groundwater plume have not indicated contamination at levels of health concern. This review of perimeter wells indicates that off-site private wells are not expected to have been affected by site contamination. Cancer mortality data for the community surrounding the site are lacking. However, neither the magnitude nor the duration of estimated exposures to site-related chemicals were sufficient to make cancer effects a plausible consequence of these exposures.
ATSDR recommends the following: 1) continue to monitor groundwater wells at and near the
THAN site, and 2) sample private wells in the vicinity of the THAN site if perimeter monitoring wells indicate contamination at levels of health concern.
The Agency for Toxic Substances and Disease Registry (ATSDR) received a petition in 1992 for a public health assessment of the T.H. Agriculture & Nutrition (THAN) site. The petitioner expressed several concerns in the petition letter. These concerns included (Petition Letter, 1992):
- potential health hazards to the community from baking contaminated soils on-site (i.e., thermal desorption);
- contamination of a holding pond used annually to host a fishing rodeo for children;
- number of cancer cases occurring in the immediate vicinity of the site;
- lack of information concerning the impact of contamination; and
- pollution of the aquifer that supplies drinking water for the area.
This public health assessment evaluates concerns expressed by the petitioner with regard to the THAN site.
The 12-acre THAN site consists of two parcels: the western parcel and the eastern parcel. The western parcel, currently owned by T.H. Agriculture & Nutrition Company, Incorporated, consists of approximately 7 acres and was used as a formulation, storage, and distribution center for agricultural chemicals from the 1950s to the late 1970s. From 1978 to 1982, the western parcel was used primarily as a warehouse and distribution center. The western parcel has been inactive since 1982 (EPA, 1993).
The eastern parcel of the THAN site consists of approximately five acres. The parcel is believed to have been used for formulating liquid pesticides in the 1960s (WCC, 1990). Agricultural chemicals were reportedly blended and stored on this parcel after 1973 (WCC, 1990). Since its purchase in 1985 by Mr. Larry Jones, the parcel has been an active welding supply store.
Data obtained during site characterization activities confirmed that on-site soil and groundwater have been impacted by past operations. The major contaminants identified at the site include organochlorine and organophosphorus pesticides, herbicides, and volatile organic compounds (VOCs) (WCC, 1992b).
The western parcel of the THAN site is fenced and zoned for industrial use (ATSDR, 1992b). The eastern parcel is partially fenced and zoned for industrial use. A mixture of light industry and residential properties surround the THAN site. The site is bounded on the south by Schley Avenue, on the west by the Georgia-Great Southern Railway, on the north by property owned by the Spilman Brick Company, and on the east by small clusters of trees (WCC, 1992b; CDM, 1995). East beyond the cluster of trees is a United States Department of Agriculture (USDA) laboratory and residences. North of the Spilman Brick Company is a large pecan orchard. Further west and southwest of the site are lightly populated residential areas (EPA, 1993).
According to water usage records from 1995, the last year for which data are available, groundwater in Dougherty County is used primarily for public supply, with irrigation and industrial applications following in usage (USGS, 1995). Within a 3-mile radius of the site are 315 wells, of which 12 supply city water. A survey of the 13 wells closest to the site found that 8 were not in use, 1 supplied 120 residents of a nearby subdivision, and the remaining 4 were used by between 1 and 7 people each (WCC, 1992a).
According to the 1990 Census of Population and Housing (U.S. Bureau of the Census, 1991), the demographic statistics for locations within 1 mile of the site indicated 3,972 persons reside in 1753 households. Of the 3,972 persons, 94% are white; 5% are black; 0.2% are American Indian, Eskimo, Aleut; and 0.8% are Asian or Pacific Islander. Children aged 6 or younger number 338 and adults aged 65 and older number 476. Please refer to Figure 1, Appendix A, for additional demographic statistics.
In 1984, THAN conducted removal activities at the site. In accordance with a clean-up plan approved by the Georgia Environmental Protection Division (GAEPD), surficial soils were removed from areas where they exceeded established clean-up criteria. Major remedial activities included demolition of several buildings, excavation of selected surface soils and subsurface disposal areas, installation of a perimeter fence, and establishment of a vegetative cover (EPA, 1993). Approximately 450 samples of soil, wood, concrete, and water were collected and analyzed during clean-up operations to verify that the cleanup criteria established by GAEPD had been met (WCC, 1990).
A second removal was initiated in March 1992 at a former burial area on the western portion of the THAN property containing pure product and high levels of contamination (EPA, 1993). Soils that contained greater than 1000 parts per million (ppm) of total pesticides were treated by on-site thermal desorption and reduced in concentration to less than 25 ppm total pesticides, as confirmed by post-removal sampling (EPA, 1996). The top 1-7 feet of soil from areas of contamination, which included over 20,000 tons of soil, were removed from the western portion and shipped to a permitted hazardous waste fill (EPA, 1993). The excavated areas were to be backfilled with a uniform engineered clay cover (EPA, 1996).
In 1993, the Environmental Protection Agency (EPA) divided the site into two Operable Units (OU): OU 1, which addresses soil contamination on the western parcel and groundwater contamination on both parcels; and OU 2, which addresses soil contamination on the eastern parcel. On May 21, 1993, EPA issued a Record of Decision (ROD) on OU 1, which required no further action with respect to soil, because past remedial action had adequately addressed the soil contamination, but called for pumping and treating of contaminated groundwater beneath the entire site (EPA, 1993).
On April 26, 1996, EPA issued a ROD on OU 2, selecting a remedy that provided for 1) excavation of soil contaminated with organic compounds, 2) on-site treatment of soil by low-temperature thermal desorption, and 3) air and groundwater monitoring (EPA, 1996). Current remedial activities for the eastern parcel include the transfer and processing of soil.
ATSDR had already conducted a public health assessment of the THAN site before receiving the 1992 petition. Since the petition, several additional public health activities have been completed. The following text discusses ATSDR's previous investigations regarding the THAN site.
ATSDR concluded that the site was of potential public health concern because possible human exposure to lindane, toxaphene, DDT, and methyl parathion existed via ingestion of and dermal contact with soils and groundwater (ATSDR, 1990). The limited information available was insufficient for a thorough evaluation of the exposure potential or the risk to human health. Therefore, ATSDR recommended establishment and implementation of a soil sampling and a groundwater monitoring program to further characterize the extent of site contamination. Following the 1990 public health assessment, numerous sampling events were conducted at the THAN site to characterize the extent of soil, sediment, surface water, and groundwater contamination.
ATSDR reviewed two proposed remediation plans and addressed the human health impact (ATSDR, 1992a). One plan was developed by the potentially responsible party (PRP) and one by the EPA. ATSDR determined that EPA's proposed removal action levels would be protective of human health for industrial use of the site. However, ATSDR could not determine whether the PRP's would address human exposure scenarios because soil samples were not collected from a depth of 1 to 5 feet.
ATSDR reviewed the Thermal Desorption Work Plan describing remediation activities at the site (ATSDR, 1993). However, emission results from the low temperature thermal desorption (LTTD) of on-site soils during the test period were not provided. All other phases of the operation appeared to be protective of public health. ATSDR recommended monitoring downwind air near the fence-line perimeter and at the air dispersions model's maximum predicted impact point.