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PUBLIC HEALTH ASSESSMENT

T.H. AGRICULTURE AND NUTRITION/MONTGOMERY PLANT SITE
MONTGOMERY, MONTGOMERY COUNTY, ALABAMA


SUMMARY

The T. H. Agriculture and Nutrition/Montgomery Plant (THAN) National Priorities List (NPL) site is an industrial facility in Montgomery, Montgomery County, Alabama. Two different properties comprise the THAN site. The northern property is the former site of the THAN plant, while the southern property is the location of Industrial Chemicals, Inc. (IC). Currently, Astro Packaging, Inc. owns the IC property, and Williamson Industries, Inc. retains the THAN property. Development of the site began shortly after World War II when Wittichen Chemical Company (WCC) constructed a sales, packaging, and warehouse facility for water-treatment and plating chemicals.

There are 60 contaminants of concern found on and off the THAN site. On-site groundwater, subsurface soils, shallow soils, sediments, and surface water are contaminated. Some contaminants of concern were found in off-site monitoring and domestic water wells. Surface water, shallow soils, and sediment found off-site have been contaminated.

About 1,342 people live within a mile radius of the THAN site. People who live in the nearby Twin Lakes mobile home community are concerned about possible exposure to contaminated water, air, and soil. They are worried that fish in the Twin Lake ponds may be contaminated. We found no evidence to suggest that a completed exposure pathway exists for contaminants of concern to reach the Twin Lakes community. Also, the evidence indicates that fish caught in the ponds are not a completed human exposure pathway. However, CSX Transportation workers, Department of Transportation (DOT) workers, utility workers, telephone repairmen, and trespassers are exposed to contamination in sediments in the ditch near State and U.S. Highway 31/82.

We classified the site as a public health hazard based on the available data. The data suggest that THAN site workers, CSX Transportation workers, DOT workers, utility workers, telephone repairmen, and trespassers may have been exposed to levels of toxic chemicals that can cause adverse health effects. These adverse health effects may be caused by short term exposure to the chemicals. Data are inadequate or unavailable for some environmental media. The limited health outcome data available does not show that the site has had an adverse impact on the health of the surrounding population.

Additional sampling and monitoring of groundwater are necessary to describe and track the extent of contamination northwest of the site in wells that are 48-69 feet in depth. Public access to the site should be further restricted by additional fencing. The Alabama Department of Public Health has informed CSX Transportation workers, South Central Bell workers, Alabama Power workers of the presence of constituents in the east ditch. ADPH advises that DOT workers, utility workers, and trespassers be warned that contaminants have migrated off-site in the east ditch.

BACKGROUND

The Alabama Department of Public Health (ADPH), in cooperation with the Agency for Toxic Substances and Disease Registry (ATSDR), will evaluate the public health significance of the T.H. Agriculture and Nutrition (THAN) site. ATSDR, located in Atlanta, Georgia, is a federal agency within the United States Department of Health and Human Services. The agency is authorized by the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) to conduct public health assessments at hazardous waste sites. ADPH and ATSDR will judge whether the site can cause harmful health effects and, if so, will recommend actions to reduce or prevent such effects.

A. Site Description and History

The THAN site is located on the west side of the City of Montgomery, Montgomery County, Alabama. It is situated on State Highway 31/U.S. Highway 82 (Highway 31/82) at latitude 32 22' 31" north and longitude 86 22' 39" east (Figure 1, Appendix A). The Gulf Mobile & Ohio (now owned by CSX Transportation) railroad tracks and right-of-way run between the THAN site and Highway 31/82. Maxwell Air Force Base (MAFB) is located approximately 1600 feet to the east across the railroad and highway. The THAN site is bordered to the south by Sherman Industries, Inc. Twin Lakes property (now operating as Lakewood estates) and Kruger Commodities, Inc., comprise the western boundary of the property. The northern site perimeter edges private property.

The general terrain of the THAN site is flat with some downward slope to the north. The average elevation is approximately 159 feet above mean sea level (MSL), with a total relief of five feet. Drainage ditches run along the eastern and western boundaries of the site. The Alabama River, located roughly two miles northeast, has a pool stage of 120 feet above MSL, and has a slope along its banks of approximately 20 feet.

The THAN site consists of 16.4 acres divided into two parcels (Figure 2, Appendix A). The northern property (THAN property) consists of 11.6 acres, and the southern property (IC property) covers approximately 4.8 acres. There is no physical barrier between the two properties. Williamson Industries, Inc., owns the northern tract of land and leases it to Capitol City Insulation, Inc. The southern property is owned by Astro Packaging who leases it to Industrial Chemicals, Inc. Because the THAN site is composed of two different properties, the history of each will be addressed individually.

THAN Property

The THAN property is at 3405 Birmingham Highway (Highway 31/82). A warehouse located on the eastern third of the property is the only significant structure. The southern and western boundaries of the property are covered by a pine forest, much of which has been cut for timber. There is a small pond and low-lying marshy area near the center of the property. Immediately northwest of the warehouse is the location of a former waste disposal area. A low region located south of the warehouse has been filled by the current owner to alleviate water drainage problems on the property.

The THAN property was developed shortly after World War II by the Wittichen Chemical Company (WCC). WCC used the property as a sales, packaging and warehouse facility for water-treatment and plating chemicals. Before WCC developed the property, aerial photographs suggested that it was used for agriculture. The warehouse on the property is the original structure associated with site development.

In December 1966, WCC sold their operation to Thompson-Hayward Chemical Company (THCC), a wholly-owned subsidiary of Philips Electronics and Pharmaceutical Industries Corporation. THCC stored and distributed agricultural and industrial chemicals at the site from approximately 1966 to 1980. The company reportedly used pits at the rear of the warehouse for disposal of empty or broken containers, carboys, drums and bags of chemicals.

THCC ceased operations at the plant in October 1980, and the Alabama Water Improvement Commission (AWIC) concluded a Compliance Inspection Report of the site (2). Two disposal pits, approximately 20 feet by 10 feet and 10 feet by 10 feet, were noted in the report. ADPH investigated the THAN site further by taking soil and groundwater samples. In June 1981, the company changed its name to T. H. Agriculture and Nutrition Company, Inc., (THAN) (1).

In November 1980, THAN retained the services of P.E. LaMoreaux (PELA) to perform an investigation of the property. PELA placed four groundwater monitoring wells (TH-1, TH-2, TH-3, TH-4) on the THAN property in December 1980. The reported analytical results from the monitoring wells showed that lindane was present in quantities that exceeded the Federal and State Drinking Water Standards for that time (3).

ADPH requested that the lindane levels in the groundwater be reduced to below 4.0 micrograms per liter (µg/L). PELA submitted a cleanup plan to ADPH and began remedial actions in March 1981. As a part of the remedial cleanup plan, 375,000 gallons of groundwater were pumped into the Montgomery Sanitary Sewer System in October 1981 to determine the potential effects of lindane on the city sewage system (4,5). The results suggested that no bioaccumulation of pesticides had occurred in sewage (4). Consequently, an additional 983,280 gallons of water were discharged in April 1982 to remediate groundwater. Other remedial actions included treating and discharging surface water into a Publicly Owned Treatment Works (POTW), and removal of approximately 3,243 tons of soil, and 35-40 drums (55 gallons each) of waste materials. The soil and waste material were excavated and sent to Chemical Waste Management in Emelle, Alabama.

From July 1982 to January 1983, systematic testing of the groundwater monitoring wells was performed by ADPH and PELA. Results of the sampling suggested that all lindane concentrations were within acceptable limits (5). In February 1983, the Alabama Department of Environmental Management (ADEM) informed THAN that the files were being closed on the investigation because the problem appeared to have been remediated.

In June 1983, the property was leased to The Pallet House, a pinewood pallet construction business. The Pallet House leased the site until September 1983. In December 1983, the property was leased to a trucking company named Jeff Express, Inc., which retained the lease until December 1984 (6).

Because of a potential sale of the property, groundwater samples were taken by PELA in January, April, and October 1985. The results of the sampling showed that lindane was present in quantities exceeding maximum consumption levels for drinking water for that time. Subsequent resampling in October 1985 showed that lindane levels were within drinking water standards (7). The property was sold to Williamson Industries, Inc., in April of 1986. However, THAN retained the responsibility for cleaning up the property. Williamson Industries, Inc., currently leases the site to Capital City Insulation, Inc., a commercial insulation business.

In March 1987, the U.S. Environmental Protection Agency (USEPA) completed an internal evaluation of the THAN property using the Hazard Ranking System (8). As a result, the THAN property was proposed to the National Priorities List (NPL), or Superfund, in June 1988. From 1988 until 1990, Golder Associates, Inc., installed monitoring wells along the boundary between the THAN/IC properties and performed systematic groundwater testing. The analytical results of the tests showed that some groundwater was contaminated with pesticides and volatile organic compounds (VOCs) not previously recorded in past studies of the THAN property disposal pits. Golder Associates, Inc., alleged that the substances were associated with the Industrial Chemicals (IC) property.

IC Property

The IC property is located south of the THAN property at 3355 Birmingham Highway (Highway 31/82). The western third of the property is the site of a former evaporation lagoon and incinerator. This area is covered by grass and shrubbery. The central part of the IC property is paved, and has several buildings and tanks used for formulation, distribution, and storage of industrial and agricultural chemicals. The eastern portion of the property is covered by a paved parking lot.

The IC property formerly was owned by Montgomery Industries who sold the property to Pennwalt Corporation (now Elf Atochem North America) in 1951. Pennwalt Corporation's Agricultural Chemicals Division (ACD) owned and operated the property from 1952 to 1970. ACD formulated pesticides and herbicides at the site until 1970 when it was replaced by Pennwalt's Chemical Specialties Division (CSD). The CSD handled, stored, and distributed water-treatment chemicals until November 1978.

In May 1978, Pennwalt closed an approximately 700,000 gallon lined lagoon. The lagoon was used as an evaporation pond for processing wastewater. Pond supernatant, sludge, and underlying soil were disposed of through a company called Resource Industries. Sludge and soil were reportedly taken to a private facility owned and operated by Resource Industries; water was treated and released to the Montgomery Sanitary Sewer System.

In 1979, Pennwalt sold the property to Astro Packaging, Inc. Astro Packaging, Inc., currently leases the property to Industrial Chemicals, Inc. IC operates a packaging and distribution facility that handles solvents, water treatment chemicals, and assorted industrial chemicals.

In August 1990, the THAN site was officially listed on the NPL and was ranked number 332 of 1,073 sites on the NPL at that time (9). The USEPA identified THAN and Elf Atochem, Inc., as Potentially Responsible Parties (PRPs) for the site contamination. Atochem, IC, Astro Packaging, Inc., and the USEPA signed an administrative Order By Consent for a Remedial Investigation/Feasibility Study in 1990.

Geology

The THAN site sits on several packages of sedimentary rocks called formations. The formations are relatively flat-lying deposits that range in age from Upper Cretaceous (approximately 79 million years) to Holocene (< 10,000 years). The formations from youngest to oldest are the alluvial and terrace deposits, the Eutaw Formation, the Gordo Formation, and the Coker Formation.

The alluvial and terrace deposits are recent accumulations that were deposited by the ancestral and current Alabama River. Clay and sand layers make up the upper portion of the unit, while the lower half of the unit is composed of sand and gravel. The deposits are thought to extend down from the surface to a depth of approximately 48 feet beneath the THAN site. However, the thickness of the unit is known to vary significantly in the area and does extend below a depth of 90 feet in areas northeast and east of the site (10). The data further suggest that the depth of the alluvial and terrace deposits south of the site appear to be consistent with the depth found on-site. Areas north and west of the site cannot be evaluated because data are insufficient at this time. The alluvial/terrace deposits comprise an aquifer known as the Alluvial/Terrace aquifer. Groundwater flow in the aquifer is from north-northwest to northeast (11).

Underlying the alluvial/terrace deposits is the Eutaw Formation. The Eutaw Formation at the THAN site begins at an approximate depth of 40 to 50 feet below land surface and is about 150 to 200 feet thick. Three subdivisions make up the Eutaw Formation: the Upper Eutaw, the Middle Eutaw, and the Lower Eutaw. The Upper Eutaw at the THAN site is gradational with the alluvial\terrace deposits. Fine-grained sand with interbedded silty clays, calcareous sandstone, and localized deposits of bentonite (an absorptive clay) compose the Upper Eutaw. It is believed that the Upper Eutaw aquifer and the Alluvial/Terrace deposit aquifer form a single aquifer in the area of the THAN site. Below the Upper Eutaw is the Middle Eutaw. The Middle Eutaw has total thickness of 62.5 feet and is separated from the Upper Eutaw by a confining clay bed. A confining bed or unit is usually a clay layer that has low permeability and porosity. Permeability is the rate at which a liquid moves through rock. Below the confining unit is a porous zone of sand and clay. The Middle Eutaw is separated from the Lower Eutaw by a clay layer approximately one foot thick. The Lower Eutaw is approximately 119 feet thick and is one of the City of Montgomery's water sources. Sand beds and clay-sand beds form the upper portion of the Lower Eutaw while a confining unit that is approximately 56 feet thick forms the lower segment. Groundwater flow in the Lower Eutaw is south-southwest.

Groundwater mixing between the Alluvial/Terrace aquifer and the Eutaw aquifer is thought to occur in the area of the site. According to the 1989 Environmental Science and Engineering RI/FS report for Maxwell Air Force Base (MAFB) (10), a hydraulic connection exists between the overlying Alluvial\Terrace aquifer and the underlying Eutaw aquifer. Stratigraphic breaks that are known to occur in Upper Cretaceous rocks in the area further support this belief (12). Stratigraphic breaks are sharp changes in rock type(s) that occur laterally. Also, outcrops of the Upper Eutaw can be seen south and north of the THAN site along the Alabama River, suggesting that extensive erosion has occurred in the area to the underlying Eutaw Formation. These factors combined with the vertical pulldown that is produced by the Montgomery West Well Field create the possibility for groundwater mixing.

B. Site Visit

In October 1993, the site was visited by Brian J. Hughes, Ph.D., ADPH; Janice Gilliland, ADPH; and David Thompson, ADEM. The team was accompanied by representatives of Atochem and King & Spalding, the law firm that represents Atochem. A second site visit was made in January 1994 by Neil Daniell, ADPH, and representatives of Atochem and King & Spalding.

Trees and underbrush separate the site from the Twin Lakes community, a residential mobile home community located 0.4 miles north-northwest. A fence encloses the THAN site on the north, west and south sides. However, it does not prevent trespass into the area. The THAN site is unfenced along Highway 31/82. There is no physical barrier between the two properties.

Most of the site is overgrown with small trees, grass, and scrub. Some of the vegetation is distressed. Scrub, emergent hardwood, and pine trees are growing over the pit areas on the THAN property. There is debris (plastic shards, an abandoned hopper, and similar items) near the west side of the IC property. A sewage line is located in the area of the west ditch at the rear of the property. Green algae can be seen growing on the water in the ditch. The site is poorly drained and standing water was observed during both site visits. Cattails were noticed in the wetter areas of the marsh.

It was observed during a tour of the area that some households still appear to be using their domestic wells.

C. Demographics, Land Use, and Natural Resource Use

Demographics

According to the 1990 Census data, the total population for the City of Montgomery is 187,106 people. Approximately 56.5% of the population is white, 42.3% is black, and 1.2% is of other races. Females comprise 53.5% of the population. The THAN site is located in the City of Montgomery Census Tract 60.85 (renamed from P60.01) that has a total population of 4,037 people (13).

A geographic information computer software program called Atlas GIS was used to estimate the population within one-mile of the THAN site. The program bases estimates of populations on the percentage of block groups contained within the specified radius, thus it is only an approximation of the actual population in the defined area. Atlas GIS gives an estimated population of 1,342 people living in 338 households within a one-mile radius. Approximately 68% of the population is white, 30% is black, and 2% is of other races. About 18% is under 5 years of age and 62% is 20 years old or younger. Only 11% of the total population is age 65 years or older. The median age is 26.1 years. Estimates were made of young children and elderly populations because of their increased sensitivity to toxic substances.

The THAN site is located along the western edge of the City of Montgomery. The nearest residences to the site are 0.3 miles north and 0.4 miles south. MAFB residences and base operations are 1 3/4 miles to the east.

Land Use

The area around the THAN site has mixed land use. A residential zone, an agricultural zone, an industrial zone, and a military base are all located within a one-mile radius of the THAN site. Commercial and industrial activity is concentrated on Highway 31/82. Kruger Commodities, Inc., Industrial Chemicals, Inc., Nelson Paint Company, Inc., Gulf Coast Truck and Equipment Company, Inc., Davenport RV Sales, A-L Welding & Industrial Supply, Inc., Victorian Classics, Inc., and Sherman Industries, Inc., are the primary businesses in the immediate area. MAFB is nearby, also.

Other land uses in the area are include public, agricultural, and residential use. Public land use areas include two parks located within a one- to two-mile radius of the THAN site. Some small and large game are hunted west of the site in the agricultural zone. A small portion of the land in the area is used for residential purposes. Families with two or more members make up most of the households near the THAN site. Mobile homes are common, and many dwellings are small and of poor quality.

Natural Resource Use

Most residences in the area are connected to the municipal water supply. Water for industrial and domestic use is provided by four main aquifers beneath the THAN site and the surrounding area. Domestic well water is drawn from the Alluvial/Terrace aquifer while municipal water comes from wells sunk into the Eutaw, Gordo and Coker aquifers. The City of Montgomery West Well Field is approximately 1.3 miles south of the THAN site.

The Alabama River is the major surface water body in the area. Catoma Creek, located 1.5 miles west-southwest, is a major tributary of the Alabama River. The West-End Ditch located along the western edge of MAFB is a tributary of the Alabama River. Several Publicly Owned Treatment Works (POTW) also discharge into the Alabama River.

Water resources in the area are used for recreation, transportation and to supplement food sources. The surface water and wetlands are important bird and wildlife habitats. Most of the open water areas are used for fishing, boating, swimming, and water skiing. Hunting does occur west of the site and is an additional food source.

Commercially important resources in Montgomery County include agricultural lands, timber, sand, gravel, and clay. Some abandoned gravel pits are also being used as ponds for fishing.

D. Health Outcome Data

The State of Alabama does not maintain a cancer registry, but the ADPH compiles an annual report on cancer mortality rates. Rates are published by state and by county. The ADPH maintains a database on infant mortality and reports statistics annually. Mortality rates are listed for the state and for each county, but not for municipalities. This information will be discussed in the section on Public Health Implications, Health Outcome Data Evaluation.

COMMUNITY HEALTH CONCERNS

Persons living in the area surrounding the THAN site voiced several health concerns regarding exposure to contaminants from the site. People voiced these concerns at the Public Availability Meeting (PAM) held November 30, 1993, and by mail or telephone. These concerns will be addressed in the Public Health Implications, Community Health Concerns Evaluation section.

A. Air Exposure Health Concerns

  1. Some former plant workers are interested in health effects that may be caused by breathing in contaminated dust or air pollution.
  2. Several former employees were concerned about inhaling high doses of chlorine gas. Some feel that this may be the cause of their current sinus problems.
  3. Residents are worried about contaminants that the prevailing north winds may blow off the THAN site.

B. Ingestion Exposure Concerns

  1. Citizens are troubled that fish in the Twin Lakes community ponds may be contaminated.
  2. Several people have concerns about current drinking water supplies. Some residents and former workers are concerned about health effects that may be caused by drinking domestic water supplies in the past.
  3. Some residents are concerned about health effects that may affect pets and children who are exposed to surface water in the Twin Lakes community ponds.

C. Other Health Concerns

  1. Citizens are concerned about possible health effects that may affect children who play in soil in the Twin Lakes community.
  2. Several people are concerned about health effects that may affect those who do yard work.
  3. Several citizens are concerned about health effects that may affect infants, and are worried that exposure to contaminants from the site may cause miscarriages.
  4. Citizens expressed concerns that the community shows high rates of cancer.
  5. Other complaints from residents in the Twin Lakes Community include sores that will not heal, red splotches on the skin, watery eyes, sinus and nasal problems, and bronchitis.

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