BASKET CREEK SURFACE IMPOUNDMENT
AND
BASKET CREEK DRUM DISPOSAL
DOUGLASVILLE, DOUGLAS COUNTY, GEORGIA

1. ATSDR has classified the Basket Creek Drum Disposal and Surface Impoundment sites as Indeterminate Public Health Hazards. That classification was assigned because of the lack of environmental data with which to evaluate, primarily, past exposure pathways of nearby residents. The missing data include 1) surface soil samples collected on or around the sites; 2) past air sampling data; 3) information necessary to determine the source of metals (e.g., lead) found in drinking water; and 4) data characterizing groundwater or drinking water quality before 1990.
2. Based on the currently available data, ATSDR has determined that the Basket Creek sites do not currently represent an apparent public health hazard. ATSDR's recommendation regarding groundwater characterization or the implementation of institutional controls should be carried out to protect public health in the future.
3. People were exposed in the past to contaminants in private well water. One drinking water well had low levels of organic contaminants (trichloroethene and cis-1,2-dichloroethene), not considered to be at levels of public health concern. However, the presence of those contaminants could reflect the migration of site-related pollution. Other drinking water wells were contaminated with metals, which are naturally found in groundwater, and therefore, it can not be determined whether or not metals from the sites have affected water in the private wells in the past.
4. Except for lead, the concentrations of metals in drinking water, when private wells were being used, appear to be below levels of public health concern. Lead is of public health concern because studies indicate that lead-contaminated water can impair the mental and physical development of infants and children.
5. There is a potential pathway for exposure to contaminants in sediment and surface water downgradient of the drum disposal area (Table 6 and 7); contaminant levels in those media suggest that low levels of mercury may have migrated off site, but not at levels of public health concern.
6. High levels of contaminants were found in the subsurface soil at the surface impoundment, particularly for lead, mercury, and solvents (Table 3). The actual level of contaminants that may have existed in the overlying surface soil is unknown. However, because of the past backfilling at the site, surface soil concentrations of contaminants are likely to have been much lower than in the subsurface soil, if they were present at all. The potential exposures and health threats from surface soil prior to backfilling are unknown. After backfilling, it appears unlikely that ingestion of and dermal exposures to contaminants at levels of public health concern occurred. No current or future exposures to site-related contaminants are expected.
7. Primarily due to the lack of air monitoring data, ATSDR can not positively determine whether residents were exposed to site-related VOCs in the past. In terms of recent exposures, the evaluation of test results for VOCs in the blood did not indicate that Basket Creek residents were exposed to site-related VOCs.
8. Because of chemicals migrating from the soil to the ambient air (especially as volatile compounds and suspended particulates), possible health effects, related to exposures at the two disposal sites before remediation took place, may have been of public health concern. However, monitoring data with which to evaluate possible exposures in the past were not conducted.

Data gaps or data inadequacies are data that were needed in order to adequately or more fully evaluate environmental contamination and human exposure. These data inadequacies will be listed although some data are no longer able to be obtained. Data gaps discovered by ATSDR during preparation of this petitioned public health assessment include the following:

1. Groundwater has not been characterized to determine on-site groundwater contamination or flow patterns.
2. No surface soil was sampled prior to cleanup at the drum disposal site, surface impoundment site, downgradient of the surface impoundment, or downgradient of the drum disposal sites (due to removal of the site contaminants, data from the sites are no longer obtainable).
3. The cancer risk evaluation guide (CREG) for beryllium in soil is currently well below background levels commonly found in the environment. The CREG is based on inhalation animal bioassay studies and its relevance for the route of ingestion is questionable and should be reexamined.
4. Comparison values are needed for lead in soil.
5. No air monitoring data are available from the 1975 surface impoundment fire (data are no longer obtainable).
6. Air was monitored during the 1985 drum disposal site fire. Carbon monoxide, trichloroethene, and chloroform were detected, but no concentrations were reported (data are no longer obtainable).
7. Air monitoring data compiled, during the removal action at the drum disposal site, were not totally sufficient for evaluation of its protectiveness of public health (data are no longer obtainable).
8. No indoor air or soil gases have been monitored at or in homes (due to removal of the site contaminants, data are no longer obtainable).

RECOMMENDATIONS

Cease or Reduce Exposure Recommendations

Advise residents, whose drinking water showed the presence of lead and who are now connected to a public water supply, about additional monitoring and procedures to ensure that household plumbing is not the source of the lead.

Site Characterization Recommendations

Restrict groundwater use on site properties and adjacent downgradient properties until groundwater remediation or characterization is conducted or until some alternative action is taken to ensure the protection of public health from potentially contaminated ground water supplies.

The purpose of the Public Health Action Plan is to ensure that this petitioned public health assessment not only identifies public health hazards but also provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment.

Actions Undertaken

1. Since August 1991, ATSDR has conducted numerous site visits, in addition to, having ATSDR staff on site almost daily for three months during removal activities at the surface impoundment.
2. ATSDR conducted ten health consultations (seven written and three verbal) for EPA and the community.
3. ATSDR conducted a case series (individual medical exams) for residents and former residents of Basket Creek. During this process, ATSDR staff met individually with residents who participated in the exams; once to get consent and again during a follow-up visit to explain the results. Additional questions were addressed through telephone conversations.
4. ATSDR has held or participated in three public meetings, two community meetings, and two public availability meetings to address public health issues and gather community concerns. In addition, ATSDR staff gathered additional information and addressed numerous questions and concerns through telephone conversations and individual meetings with residents, elected officials, involved agencies, and the press.
5. In conducting this Petitioned Public Health Assessment ATSDR provided an opportunity for the public to comment on a draft version. Responses to public comments are included in Appendix E of this document.
6. EPA has conducted site visits, site investigations, environmental sampling, and held public meetings to address health and environmental contamination issues. EPA initiated removal activities conducted at the waste sites. Chem-Nuclear Systems, Inc., the potentially responsible party, completed removal activities at the drum disposal area under the guidance of EPA. EPA completed removal actions at the surface impoundment.
7. EPA has mailed and hand delivered letters and flyers to residents explaining sampling and removal operations.
8. EPA relocated the nearest resident to each site during their respective removal activities. In addition, EPA in cooperation with ATSDR took further measures to protect public health (e.g. establishing and maintaining acceptable cleanup levels, conducting additional sampling, contingency plans, and relocation during the trial burn of the thermal oxidation unit).
9. EPA conducted an investigation, attempting to identify an additional waste disposal site that was suspected to exist by performing a geophysical survey, digging test trenches, and conducting air monitoring.
10. Douglas County, in cooperation with the U.S. Army National Guard, provided a temporary water supply, for approximately one year, to the Basket Creek residents.
11. A permanent water supply was provided to residents of Basket Creek through the cooperative efforts of Chem-Nuclear Systems, Inc., the Douglasville-Douglas County Water and Sewer Authority, the U.S. Army National Guard, and the State of Georgia.

Actions Planned

1. The Division of Health Assessment and Consultation will review new data as they become available or are provided to ATSDR.
2. If any new data provided to ATSDR are found to be of public health concern, the Division of Health Assessment and Consultation will revise or addend the Basket Creek Petitioned Public Health Assessment, as appropriate.
3. ATSDR will provide technical assistance to local, state, or federal agencies or offices that may seek assistance in carrying out actions recommended in this petitioned public health assessment.

ATSDR will reevaluate and expand the Public Health Actions when needed. New environmental, toxicological, or health outcome data, or the results of implementing the recommended actions, may determine the need for additional activities at the site.

Jeffrey A. Church, REHS, MPH
Environmental Health Specialist
Petition Response Branch
Division of Health Assessment and Consultation

R.J. Dutton, PhD
Toxicologist
Petition Response Branch
Division of Health Assessment and Consultation

ATSDR Regional Representative

Robert Safay
Environmental Health Specialist
EPA Region IV

ATSDR. 1988. Toxicological profile for beryllium, DHHS publication no. (PHS)TP-88-07. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989a. Toxicological profile for arsenic, DHHS publication no. (PHS)TP-88-02. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989b. Toxicological profile for zinc, DHHS publication no. (PHS)TP-89-25. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989c. Toxicological profile for benzene, DHHS publication no. (PHS)TP-88-03. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989d. Toxicological profile for di(2-ethylhexyl)phthalate, DHHS publication no. (PHS)TP-88-15. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989e. Toxicological profile for mercury, DHHS publication no. (PHS)TP-89-16. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989f. Toxicological profile for methylene chloride, DHHS publication no. (PHS)TP-88-18. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989g. Toxicological profile for polychlorinated biphenyls, DHHS publication no. (PHS)TP-88-21. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989h. Toxicological profile for selenium, DHHS publication no. (PHS)TP-89-21. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989i. Toxicological profile for trichloroethylene, DHHS publication no. (PHS)TP-88-24. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1989j. Toxicological profile for toluene, DHHS publication no. (PHS)TP-89-23. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1990a. Toxicological profile for lead, DHHS publication no. (PHS)TP-88-17. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1990b. Toxicological profile for tetrachloroethylene, DHHS publication no. (PHS)TP-88-22. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1991a. Health consultation on Basket Creek surface impoundment site and Basket Creek drum disposal area site, August 8, 1991. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1991b. Trip report by Lynn Wilder, August 22, 1991. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1991c. Toxicological profile for aluminum, DHHS publication no. (PHS)TP-91-01. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992a. Record of activity for telephone communication with the Douglas County Planning and Development Office, February 26, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992b. Record of activity for telephone communication with the Douglasville-Douglas County Water and Sewer Authority, February 26, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992c. Record of activity for telephone communication with Southwire Corporation, April 16, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992d. Record of activity for telephone communication with the Georgia Department of Natural Resources, February 26, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992e. Record of activity for telephone communication with Price Well Drillers, March 5, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992f. Record of activity for telephone communication with resident, April 13, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992g. Facsimile response from Don Rigger, EPA OSC, September 1, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992h. Record of activity for telephone communication with Don Rigger, April 9, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992i. Record of activity for telephone communication with Milton Henderson, EPA, April 9, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992j. Record of activity for telephone communication with Curtis Little, Douglas County Emergency Management, April 15, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992k. Record of activity for telephone communication with Terry Cole, Douglasville-Douglas County Water and Sewer Authority, August 17, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992l. Record of activity for telephone communication with resident, April 13, 1992. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.

ATSDR. 1992m. ATSDR Public Health Assessment Guidance Manual. Lewis Publishers: Chelsea, Michigan.

CWMI. 1991a. Removal action plan for the Basket Creek drum disposal site. Chemical Waste Management Inc., Environmental Remedial Action Division, Marietta, GA.

CWMI. 1991b. Soil analyses for the Basket Creek drum disposal site, September 1991. Chemical Waste Management Inc., Environmental Remedial Action Division, Marietta, GA.

CWMI. 1991c. Air Monitoring Report sheets. Chemical Waste Management Inc., Environmental Remedial Action Division, Marietta, GA.

CWMI. 1992a. Soil analyses for the Basket Creek drum disposal site confirmation samples for area one. Chemical Waste Management Inc., Environmental Remedial Action Division, Marietta, GA.

CWMI. 1992b. Soil analyses for the Basket Creek drum disposal site confirmation samples for area two. Chemical Waste Management Inc., Environmental Remedial Action Division, Marietta, GA.

CWMI. 1992c. Soil analyses for the Basket Creek drum disposal site confirmation samples for area three. Chemical Waste Management Inc., Environmental Remedial Action Division, Marietta, GA.

CWMI. 1992d. Soil analyses for the Basket Creek drum disposal site fill dirt. Chemical Waste Management Inc., Environmental Remedial Action Division, Marietta, GA.

EPA. 1990. Final report, Basket Creek drum disposal site. From Phil Henderson to Shane Hitchcock, Technical Direction Document no. 04-9003-10-3110. Atlanta, GA: Environmental Protection Agency, Technical Assistance Team.

EPA. 1991a. Memorandum to Donald Guinyard from R. Donald Rigger, Jr., April 11, 1991. Atlanta, GA: Environmental Protection Agency.

EPA. 1991b. Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation Manual. Supplemental Guidance - Standard Default Exposure Factors (Interim Final). OSWER Directive: 9285.6-03. Environmental Protection Agency.

EPA. 1992a. Soil analyses for Basket Creek surface impoundment. Atlanta, GA: Environmental Protection Agency.

EPA. 1992b. Basket Creek private well analytical results from 1990-92. Athens, GA: Environmental Protection Agency.

EPA. 1993a. Formal Report Basket Creek Surface Impoundment Site, April 1, 1993. Technical Direction Document Number 04-9210-0025. Atlanta, GA: Environmental Protection Agency.

EPA. 1993b. Surface water analyses for Basket Creek Surface impoundment, March 29, 1993. Athens, GA: Environmental Protection Agency.

EPD. 1976. Memorandum to John D. Taylor, Jr., from Moses N. McCall. Atlanta, GA: Georgia Department of Natural Resources, Environmental Protection Division.

EPD. 1985a. Preliminary assessment. Basket Creek drum burial/site (GAD980843833). Atlanta, GA: Georgia Department of Natural Resources, Environmental Protection Division.

EPD. 1985b. Trip report by Jeff Williams, March 13, 1985. Atlanta, GA: Georgia Department of Natural Resources, Environmental Protection Division.

EPD. 1985c. Trip report by Claude Goodley, March 29, 1985. Atlanta, GA: Georgia Department of Natural Resources, Environmental Protection Division.

EPD. 1985d. Trip report by Claude Goodley, April 9, 1985. Atlanta, GA: Georgia Department of Natural Resources, Environmental Protection Division.

EPD. 1985e. Preliminary assessment. Basket Creek burial pit/site (GAD980844849). Atlanta, GA: Georgia Department of Natural Resources, Environmental Protection Division.

EPD. 1985f. Soil and water analyses for Basket Creek Road burial pit/site (GAD980844849). Atlanta, GA: Georgia Department of Natural Resources, Environmental Protection Division.

EPD. 1985g. Emergency Response Team report no. 03218505. Atlanta, GA: Georgia Department of Natural Resources, Environmental Protection Division.

EPD. 1986. Site inspection report. Basket Creek buried pit/site (CERCLIS No. GAD980844849). Atlanta, GA: Georgia Department of Natural Resources, Environmental Protection Division.

HSDB. 1992. Hazardous Substance Data Bank. National Library of Medicine, National Toxicology Information Program, Bethesda, MD. April 7, 1992.

OHM. 1992. Operations Contingency Plan. Basket Creek Surface Impoundment; D.O. No: 4001-F4-025; October, 1992. Norcross, GA: OHM Remediation Services Corporation.

Weston. 1992a. U.S. EPA Region IV Site Health and Safety Plan for the Basket Creek Surface Impoundment Site (undated). Atlanta, GA: Roy F. Weston Inc., Technical Assistance Team.

Weston. 1992b. EPA Technical Assistance Team Air Sampling Log(s) for the Basket Creek Surface Impoundment. October 20-22, 1992 & November 20, 1992-end of project. Atlanta, GA: Roy F. Weston Inc., Technical Assistance Team.

Weston. 1992c. Memorandum to Don Rigger from Timothy B. Neal, August 20, 1992. Atlanta, GA: Roy F. Weston Inc., Technical Assistance Team.

TRI. 1992. Toxic Chemical Release Inventory database for 1989. Bethesda, MD: National Library of Medicine, Toxicology Data Network (TOXNET), March 1992.

U.S. Bureau of the Census. 1991. Census of population and housing, 1990: Summary tape file 1 (Georgia) prepared by the Bureau of the Census. Washington, D.C.

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