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PETITIONED PUBLIC HEALTH ASSESSMENT

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


APPENDICES

APPENDIX A

Figure 1
Figure 1. Site Location Map

Figure 2
Figure 2. Basket Creek Drum Dump

Figure 3
Figure 3. Basket Creek Sites -
Nearest Residents



APPENDIX B

Table 1. Summary of On-site Subsurface Soil Samples at the Drum Disposal Area Prior to Removal Actions

Contaminant Maximum
Concentration
(mg/kg)
Date Reference Comparison Value
mg/kg Source
Aluminum 36,488 3/90 EPA 1990 None
**Acetone 17B 3/90 EPA 1990 5,000 RMEG
Arsenic 20.5 3/90 EPA 1990 0.4 RMEG
Benzene ND 9/91 CWMI 1991b 24 CREG
*Beryllium 1.5 3/90 EPA 1990 0.16 CREG
**DEHP 0.48B 3/90 EPA 1990 50 CREG
Ethylbenzene 4.67 9/91 CWMI 1991b 5,000 RMEG
Iron 49,505 3/90 EPA 1990 None
Lead 40.35 3/90 EPA 1990 None ***
Mercury 0.12 3/90 EPA 1990 100 EMEG
**Methyl Ethyl Ketone 10BJ 3/90 EPA 1990 None
Molybdenum NA

300 RMEG
Aroclor-1242 ND 9/91 CWMI 1991b 0.09 CREG
Aroclor-1248 0.19 9/91 CWMI 1991b 0.09 CREG
Aroclor-1254 0.35 9/91 CWMI 1991b 0.09 CREG
Aroclor-1260 ND 9/91 CWMI 1991b 0.09 CREG
Tetrachloroethene 21.28 9/91 CWMI 1991b 10 CREG
Toluene 61.44 9/91 CWMI 1991b 10,000 RMEG
Total Selenium NA

100 EMEG
Trichloroethene 105.4 9/91 CWMI 1991b 63.6 CREG
Zinc 94.75 3/90 EPA 1990 20,000 RMEG

NOTE: Shading designates the contaminants of concern for this medium
* Beryllium is not evaluated as a contaminant of concern in soil, see the On-site Contamination subsection for additional information
** QA/QC problems associated with these analyses (see QA/QC subsection); invalid results are not highlighted as contaminants of concern
*** EPA/NTP carcinogen (cancer slope factor not available)

    J = Estimated value
    B = Compound was also detected in the associated blank
    NA = Not Analyzed
    ND = Not Detected



Table 2. Summary of On-site Post Sampling, Drum Disposal Area (maximum concentrations reported)

Contaminant Area 1
8/91

mg/kg

Area 2
5/92

mg/kg

Area 3
1/92

mg/kg

Fill
Soil
5/92
mg/kg
Surface
Soil
7/92
mg/kg
Comparison Value
mg/kg Source
Aluminum NA NA NA NA 22000 None
Acetone NA NA ND NA ND 5,000 RMEG
Arsenic ND 89.8 ND ND ND 0.4 RMEG
Benzene NA ND ND ND ND 24 CREG
*Beryllium NA NA NA ND 2.6 0.16 CREG
DEHP ND 2.95 2.66 0.72 ND 50 CREG
Ethylbenzene NA ND ND ND ND 5,000 RMEG
Iron NA NA NA NA 57000 None
Lead 9.76 46.3 23.2 9.58 ND None **
Mercury ND ND ND ND 0.06 100 EMEG
Methyl Ethyl Ketone NA NA ND NA ND None
Molybdenum NA NA NA NA ND 300 RMEG
Aroclor-1242 ND 0.44 ND ND ND 0.09 CREG
Aroclor-1248 ND 0.014 0.184 ND ND 0.09 CREG
Aroclor-1254 ND ND 0.19 ND ND 0.09 CREG
Aroclor-1260 ND ND ND ND ND 0.09 CREG
PCE NA ND ND ND ND 10 CREG
Toluene NA ND ND ND ND 10,000 RMEG
Total Selenium ND ND ND ND ND 100 EMEG
Trichloroethene NA ND ND ND ND 63.6 CREG
Zinc NA NA NA NA 47 20,000 RMEG

NOTE: Shading designates the contaminants of concern for this medium
References: Area 1 = CWMI 1992a; Area 2 = CWMI 1992b; Area 3 = CWMI 1992c;
Fill Soil = CWMI 1992d; Surface Soil = ATSDR 1992
* Beryllium is not evaluated as a contaminant of concern in soil, see the On-site Contamination subsection for additional information
** EPA/NTP carcinogen (cancer slope factor not available)

    PCE = Tetrachloroethene
    NA = Not Analyzed
    ND = Not Detected


Table 3. Summary of On-site Subsurface Soil Samples, Surface Impoundment

Contaminant Maximum
Concentration
(mg/kg)
Date Reference Comparison Value
mg/kg Source
Aluminum 13,693 3/90 EPA 1990 None
Acetone 177,000 10/85 EPD 1985f 5,000 RMEG
Arsenic 11.1 3/90 EPA 1990 0.4 RMEG
Benzene 300 10/85 EPD 1985f 24 CREG
**Beryllium 0.25 3/90 EPA 1990 0.16 CREG
DEHP 210 1/92 EPA 1992a 50 CREG
Ethylbenzene 5,700 10/85 EPD 1985f 5,000 RMEG
Iron 520,000 1/92 EPA 1992a None
Lead 9,400 1/92 EPA 1992a None *
Mercury 3,553 3/90 EPA 1990 100 EMEG
Methyl Ethyl Ketone 62,000 10/85 EPD 1985f None
Molybdenum NA

300 RMEG
Aroclor-1242 ND 1/92 EPA 1992a 0.09 CREG
Aroclor-1248 ND 1/92 EPA 1992a 0.09 CREG
Aroclor-1254 ND 1/92 EPA 1992a 0.09 CREG
Aroclor-1260 6 1/92 EPA 1992a 0.09 CREG
Tetrachloroethene 2,700 1/92 EPA 1992a 10 CREG
Toluene 220,000 1/92 EPA 1992a 10,000 RMEG
Total Selenium 900 1/92 EPA 1992a 100 EMEG
Trichloroethene 8,600 1/92 EPA 1992a 63.6 CREG
Zinc 550 1/92 EPA 1992a 20,000 RMEG

NOTE: Shading designates the contaminants of concern for this medium
* EPA/NTP carcinogen (cancer slope factor not available)
** Beryllium is not evaluated as a contaminant of concern in soil, see the On-site Contamination subsection for additional information

    NA = Not Analyzed
    ND = Not Detected


Table 4. Summary of the Maximum Concentration of Contaminants Analyzed in Groundwater

Contaminant Maximum
Concentration
(µg/L)
Date Reference Comparison Value
µg/L Source
Aluminum 17,000 10/91 EPA 1992b None
*Acetone 4BJ 3/90 EPA 1990 1,000 RMEG
Arsenic ND ** EPA 1992b 0.02 CREG
Benzene ND ** EPA 1992b 1 CREG
Beryllium 1.2 10/91 EPA 1992b 0.0081 CREG
*DEHP 5BJ 3/90 EPA 1992b 3 CREG
Ethylbenzene ND ** EPA 1992b 700 MCLG
Iron 5,600 10/91 EPA 1992b None
Lead 66 10/91 EPA 1992b 15 MCLA
Mercury 1.45 3/90 EPA 1990 2 MCLG
*Methyl ethyl ketone 6BJ 3/90 EPA 1990 200 LTHA
Molybdenum 12 10/91 EPA 1992b 10 CLHA
Aroclor-1242 ND ** EPA 1992b 0.005 CREG
Aroclor-1248 ND ** EPA 1992b 0.005 CREG
Aroclor-1254 ND ** EPA 1992b 0.005 CREG
Aroclor-1260 ND ** EPA 1992b 0.005 CREG
Tetrachloroethene ND ** EPA 1992b 0.7 CREG
Toluene ND ** EPA 1992b 1,000 MCLG
Total Selenium ND ** EPA 1992b 20 EMEG
Trichloroethene 5 3/90 EPA 1990 3 CREG
Zinc 12,000 7/91 EPA 1992b 2,000 LTHA

NOTE: Shading designates the contaminants of concern for this medium
* QA/QC problems associated with these analyses (see QA/QC subsection); these contaminants not detected in other drinking water samples analyzed and invalid results are not highlighted as contaminants of concern
** Analyzed multiple times since 1990

    J = Estimated value; compound was detected below the detection limit
    B = Compound was also detected in the associated blank
    ND = Not Detected


Table 5. Concentrations of Groundwater Contaminants of Concern for Each Private Well

Contaminant Comparison Value Maximum Contaminant Concentration
µg/L
µg/L
Source
Well Numbers
1 2 3 4 5 6 7 8 9 10
Aluminum None
180 44 117 1500 ND 17000 1100 100 1600 880
Beryllium 0.0081 CREG ND ND ND ND ND 1.2 ND ND ND ND
Iron None
380 62 1016 3400 2400 5600 1000 88 1700 810
Lead 15 MCLA ND ND ND 8.5 13 24 ND 66 ND ND
Molybdenum 10 CLHA 5.6 12 ND ND ND ND ND ND ND ND
TCE 3 CREG ND ND 5 ND ND ND ND ND ND ND
Zinc 2000 LTHA 8700 12000 5.8 34 6.2 32 39 150 47 32

Continued - Table 5.

Contaminant Comparison Value Contaminant Concentration
µg/L
µg/L
Source
Well Numbers
11 12 13 14 15 16 17 18 19
Aluminum None
ND ND 44 101 48 ND ND 43 ND
Beryllium 0.0081 CREG ND ND ND ND ND ND ND ND ND
Iron None
10
31 11 127 17 13 24 14 50
Lead 15 MCLA ND ND ND ND ND ND ND ND ND
Molybdenum 10 CLHA ND ND ND ND ND ND ND ND ND
TCE 3 CREG ND ND ND ND ND ND ND ND ND
Zinc 2000 LTHA 7.5 19 14 85 43 ND 72 30 52

References: EPA 1990, EPA 1992b, and EPD 1985f; data in this table is from all groundwater sampling 1985-91
TCE = trichloroethene


Table 6. Summary of Surface Water Downgradient of the Drum Disposal Area

Contaminant Maximum
Concentration
(µg/L)
Date Reference Comparison Value
µg/L Source
Aluminum 148 3/90 EPA 1990 None
*Acetone 2BJ 3/90 EPA 1990 1,000 RMEG
Arsenic ND 3/90 EPA 1990 0.02 CREG
Benzene NA

1 CREG
Beryllium ND 3/90 EPA 1990 0.0081 CREG
*DEHP 0.005BJ 3/90 EPA 1990 3 CREG
Ethylbenzene ND 3/90 EPA 1990 700 MCL
Iron 613,000 3/90 EPA 1990 None
Lead ND 3/90 EPA 1990 15 MCLA
Mercury 0.29 3/90 EPA 1990 2 MCLG
*Methyl Ethyl Ketone 5BJ 3/90 EPA 1990 200 LTHA
Molybdenum NA

10 CLHA
Aroclor-1242 NA

0.005 CREG
Aroclor-1248 NA

0.005 CREG
*Aroclor-1254 ND 3/90 EPA 1990 0.005 CREG
Aroclor-1260 NA

0.005 CREG
Tetrachloroethene ND 3/90 EPA 1990 0.7 CREG
Toluene ND 3/90 EPA 1990 1,000 MCLG
Total Selenium NA

20 EMEG
Trichloroethene ND 3/90 EPA 1990 3 CREG
Zinc ND 3/90 EPA 1990 2,000 CLHA
 

Note: Shading designates the contaminants of concern for this medium
* QA/QC problems associated with these analyses (see QA/QC subsection); invalid results are not highlighted as contaminants of concern

    J = Estimated value; compound was detected below the detection limit
    B = Compound was also detected in the associated blank
    NA = Not Analyzed
    ND = Not Detected


Table 7. Summary of Sediment Downgradient of the Drum Disposal Site

Contaminant Maximum
Concentration
(mg/kg)
Date Reference Comparison Value
mg/kg Source
Aluminum 13,693.11 3/90 EPA 1990 None
*Acetone 42B 3/90 EPA 1990 5,000 RMEG
Arsenic 7.1 3/90 EPA 1990 0.4 RMEG
Benzene NA

24 CREG
**Beryllium 0.78 3/90 EPA 1990 0.16 CREG
DEHP 0.28BJ 3/90 EPA 1990 50 CREG
Ethylbenzene 0.004J 3/90 EPA 1990 5,000 RMEG
Iron 32,959.69 3/90 EPA 1990 None
Lead 8.87 3/90 EPA 1990 None ***
Mercury 0.30 3/90 EPA 1990 100 EMEG
*Methyl Ethyl Ketone 32B 3/90 EPA 1990 None
Molybdenum NA

300 RMEG
Aroclor-1242 NA

0.09 CREG
Aroclor-1248 NA

0.09 CREG
*Aroclor-1254 ND 3/90 EPA 1990 0.09 CREG
Aroclor-1260 NA

0.09 CREG
Tetrachloroethene ND 3/90 EPA 1990 10 CREG
Toluene ND 3/90 EPA 1990 10,000 RMEG
Total Selenium NA

100 EMEG
Trichloroethene ND 3/90 EPA 1990 63.6 CREG
Zinc 58 3/90 EPA 1990 20,000 RMEG

NOTE: Shading designates the contaminants of concern for this medium
* QA/QC problems associated with these analyses (see QA/QC subsection); invalid results are not highlighted as contaminants of concern
** Beryllium is not evaluated as a contaminant of concern in soil, see the On-site Contamination subsection for additional information
*** EPA/NTP Carcinogen (cancer slope factor not available)

    J = Estimated value; compound was detected below the detection limit
    B = Compound was also detected in the associated blank
    NA = Not Analyzed
    ND = Not Detected


Table 8. Completed Exposure Pathways

Pathway Name
EXPOSURE PATHWAY ELEMENTS
Time
Source Environmental
Media
Point of
Exposure
Route of
Exposure
Exposed
Population
OFF-SITE
GROUNDWATER
UNDETERMINED GROUNDWATER
(PRIVATE WELL)
RESIDENCE INGESTION
SKIN CONTACT
PRIVATE WELL
WATER USERS
NEAR BASKET
CREEK ROAD
PAST



Table 9. Potential Exposure Pathways

Pathway Name
EXPOSURE PATHWAY ELEMENTS
Time
Source Environmental
Medium (media)
Point of Exposure Route of
Exposure
Exposed Population
ON-SITE SOIL DRUM DISPOSAL
AREA &
SURFACE
IMPOUNDMENT
SOIL DRUM DISPOSAL
AREA & SURFACE
IMPOUNDMENT
INGESTION
SKIN CONTACT
INHALATION
RESIDENTS OF
BASKET CREEK
ROAD AREA
PAST
OFF-SITE SOIL DRUM DISPOSAL
AREA &
SURFACE
IMPOUNDMENT
SOIL SOIL
DOWNGRADIENT
OF AND AROUND
THE SITES
INGESTION
SKIN CONTACT
RESIDENTS OF
BASKET CREEK
ROAD AREA
PAST
PRESENT
FUTURE
FOOD CHAIN SURFACE
IMPOUNDMENT
TOMATOES RESIDENCE INGESTION CONSUMERS OF
POTENTIALLY
CONTAMINATED
TOMATOES
PAST
OFF-SITE
SEDIMENT &
SURFACE
WATER
DRUM DISPOSAL
AREA &
SURFACE
IMPOUNDMENT
SEDIMENT AND
SURFACE WATER
SPRINGS
DOWNGRADIENT
OF THE SITES
INGESTION HUNTERS AND
HIKERS
PAST
PRESENT
FUTURE
AMBIENT AIR DRUM DISPOSAL AREA & SURFACE IMPOUNDMENT AIR AT SITES AND NEARBY RESIDENCES AND YARDS INHALATION NEARBY RESIDENTS PAST
WASTE
REMOVAL
DRUM DISPOSAL
AREA &
SURFACE
IMPOUNDMENT
AIR AND SOIL DRUM DISPOSAL AREA & SURFACE IMPOUNDMENT INGESTION
SKIN CONTACT
INHALATION
ON-SITE WORKERS PAST



APPENDIX C

Comparison Values

Comparison values for ATSDR public health assessments are contaminant concentrations in specific media used to select contaminants for further evaluation. The values provide guidelines for estimating a dose at which health effects might be observed. Comparison values used in the Environmental Contamination and Other Hazards and the Public Health Implications sections of this petitioned public health assessment are listed and described.

CLHA
CREG
EMEG
LTHA
MCLA
MCLG
MRL
RfD
RMEG
PEL
= Child Longer-Term Health Advisories
= Cancer Risk Evaluation Guides
= Environmental Media Evaluation Guides
= Drinking Water Lifetime Health Advisory
= Maximum Contaminant Level Action
= Maximum Contaminant Level Goal
= Minimal Risk Level
= Reference Dose
= Reference Media Evaluation Guide
= Permissible Exposure Limit

Child Longer-Term Health Advisories (CLHAs) are contaminant concentrations that the Environmental Protection Agency (EPA) deems protective of public health (taking into consideration the availability and economics of water treatment technology) over a lifetime (70 years) using a child's weight and ingestion rate.

Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations expected to cause no more than one excess cancer in a million persons exposed over a lifetime. CREGs are calculated from EPA's cancer slope factors.

Environmental Media Evaluation Guides (EMEGs) are calculated from ATSDR minimal risk levels; they factor in body weight and ingestion rates.

Lifetime Health Advisories (LTHAs) are contaminant concentrations that EPA deems protective of public health (considering the availability and economics of water treatment technology) over a lifetime (70 years) at an exposure rate of 2 liters of water per day.

Maximum Contaminant Level Action (MCLA) are action levels set by EPA under Superfund that trigger a response or action when contaminant concentrations exceed this value.

Maximum Contaminant Level Goals (MCLGs) are EPA drinking water health goals set at levels at which no known or anticipated adverse effect on human health is expected to occur. In addition, allowing a margin of safety, such levels consider the possible impact of synergistic (combined effect of toxins) effects, long-term and multi-stage exposures, and the existence of especially susceptible groups in an exposed population. When there is no safe threshold for a contaminant, the MCLG should be set at zero.

Minimal Risk Levels (MRL) are estimates of daily human exposure to a chemical (in mg/kg/day) likely to occur without an appreciable risk of deleterious effects (noncancer) over a specified duration of exposure. MRLs are calculated using data from human and animal studies and are reported for acute (< 14 days), intermediate (15-364 days), and chronic (> 365 days) exposures. MRLs are published in ATSDR Toxicological Profiles for specific chemicals.

EPA's Reference Dose (RfD) is an estimate of the daily exposure to a contaminant unlikely to cause adverse health effects. However, RfDs do not consider cancer effects.

Reference Media Evaluation Guide (RMEG) is a concentration derived from an EPA reference dose with assumed body and ingestion rates factored into the calculation.

The Occupational Safety and Health Administration's Permissible Exposure Limit (PEL) for air is an 8-hour, time-weighted average developed for the workplace. The level of exposure may be exceeded (for brief periods), but the sum of the exposure levels averaged over 8 hours must not exceed the limit.


APPENDIX D

The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch,
E-56
1600 Clifton Road NE, Atlanta, Georgia 30333


APPENDIX E

Comments Received During the ATSDR Public Comment Period
April 17 - May 28, 1995

Comment 1: The report suggests impacts to several adjacent private wells, particularly relating to metals. Notwithstanding the fact that the metals are naturally occurring, very little (if any) information is provided regarding well construction (e.g., depth, screen intervals, casings, materials).

Response to Comment 1: On page 16, under the "Groundwater" subsection, ATSDR indicates that many of the metals detected occur naturally in the groundwater or have other sources (e.g., lead in household plumbing) and may or may not be site-related. On page 8, under the "Natural Resource Use" subsection, ATSDR discusses the types of wells, casings, and depths of wells in the site area.

Comment 2: Due to the site's proximity to the Chattahoochee River, groundwater flow appears to be steeply graded to the South of the study area. With this in mind, several of the private wells can easily be established as background (including wells 4, 5, and 6). Page 16 of the draft report supports this observation. The report identifies aluminum, iron, and lead as contaminants of concern for soil and groundwater. It should be noted that the average concentrations of these metals are the highest for the background wells (4, 5, and 6) compared to the wells closer to the site (1, 2, and 3) as shown on Table 5. Specifically, private well 6 showed a concentration of 17 ppm for aluminum as well as the presence of lead and high iron. This well location appears among the furthest upgradient locations in the study area. Furthermore, the report states that [m]any of the metals detected occur naturally in the groundwater or have other sources and may not be site-related. The listed metals should not be considered contaminants of concern as they relate to the site especially since they are naturally occurring.

Response to Comment 2: Wells 3 and 14 are closest to the site and generally show lower maximum concentrations for metals (Table 5) than those for wells 4, 5, and 6. Wells 1 and 2 are among the furthest from the sites at ¾ of a mile to a mile, as indicated on page 17 of the "Groundwater" subsection.

Background wells or locations cannot be determined without site-specific groundwater flow characterization, which has not been conducted. On page 21, under the "Off-Site Groundwater" subsection, ATSDR discusses general groundwater flow for the Basket Creek area, which is described as fractured flow. The direction of groundwater flow and the distance from which water may be drawn to a well is complicated by a fractured flow system. Even in instances where contaminant orgin is not a question ATSDR evaluates and addresses those that may pose a public health threat. ATSDR has recommended restriction of the groundwater use on site properties and adjacent downgradient properties until remediation or characterization is conducted or until some alternative action is taken to ensure the protection of public health from potentially contaminated groundwater supplies.

Comment 3: Appendix D of the subject report includes an October 21, 1991, internal ATSDR memorandum which highlights sampling of 17 private wells. It is unclear as to the extent of laboratory QA/QC provided (including blanks) as well as the instrument detection limits. Furthermore, well number 5 does not list a contaminant corresponding to "none detected."

Response to Comment 3: The private well sampling reported in the October 21, 1991, ATSDR memorandum was conducted by the Environmental Protection Agency (EPA) Region IV Environmental Services Division, Athens, Georgia, and is referenced as such. ATSDR reviewed the sampling data reports for each private well and associated trip blanks. The minimum quantitation limits and other data qualifiers were reported for each chemical listed in the data reports. Copies of this data [April 1991 sampling (project number 91-601) and July 1991 sampling (EPA project number 91-777)] or their associated Data Review Summaries can be obtained directly from EPA.

Table 1 of the ATSDR memorandum, on page D20 of Appendix D, shows a list of only those contaminants detected at concentrations above the laboratory's minimum quantitation limit. The "none detected" shown for well number 5 indicates that no contaminants were detected at concentrations above the laboratory's minimum quantitation limit.

Comment 4: In 1985 my well was tested. It was well #2, not well #1. My well contained PCBs and other compounds.

Response to Comment 4: Because so many different laboratory sheets and sampling identification numbers were used by different organizations, ATSDR developed a separate numbering scheme for the wells listed in this report. The well that was sampled in 1985 was sampled by the Georgia Environmental Protection Division (EPD), and on their laboratory report the well is listed as "W-2." The number ATSDR used for that well is number 14 as shown in Figure 3 (page A3 of Appendix A) and Table 4 and 5 (pages B4 and B5 of Appendix B).

PCBs, volatile organic compounds, base neutral compounds, acid extractable compounds, and seven separate metals were analyzed for that well in 1985, however only barium was detected (20 µg/L). The numbers listed by other metals and groups of compounds are preceded by a "less than" symbol (<), which indicates that those chemicals were not detected when analyzing down to the concentration listed on the lab sheet.

Comment 5: I can not understand how the ATSDR can claim that some of the test results were not available to them. I was able to get all test results from EPA.

Response to Comment 5: ATSDR was unable to find any statement in this document which indicates that some of the test results were not available. ATSDR does, however, indicate in this document some comparison values are not available. Comparison values, which are described in Appendix C, are health guidelines (concentrations) that are established for different chemicals and used to determine whether a contaminant should be evaluated further. Due to the lack of scientific research and data, comparison values are not available for all chemicals.

Comment 6: The blood taken from 34 Basket Creek residents in December 1991 were not taken once, but two times due to improper handling of blood samples.

Response to Comment 6: Some additional blood specimens were collected due to the inability to collect sufficient blood to complete all tests or because of processing difficulties such as the clotting of the blood specimens before analysis.

Comment 7: The full background and history is needed to evaluate the sites. Files on Young Refining Corporation and Arivec Chemicals in Douglasville, Georgia, show the origin of the wastes and how they wound up at Basket Creek.

Response to Comment 7: The lead author of the Basket Creek Petitioned Public Health Assessment reviewed the site files related to Young Refining Corporation and Arivec Chemical Company. ATSDR does not conduct regulatory investigations, therefore ATSDR's "Background" section attempts only to provide a brief overview of the site history. The "Environmental Contamination and Other Hazards" discusses any contamination found at the sites, but focuses on current conditions.

Comment 8: The sites were never 1,000 feet apart (p.3) but approximately 285 to 300 feet.

Response to Comment 8: The exact distance between the two sites may be somewhat closer than the 1,000 feet estimated by Georgia EPD in their 1986 Site Inspection Report.

Comment 9: ATSDR leaves the impression only 80 drums were dumped (p.3) when at the end of the cleanup, out of the drum disposal area alone, 4,800 drums had been pulled.

Response to Comment 9: On page 3, ATSDR is simply reviewing the site history and indicates the approximate number of drums (80) documented as being dumped at the time that the site and disposal activity was discovered. Although ATSDR did not receive any documentation of the exact number of drums ultimately recovered from the site, four thousand drums were reported at one time during the removal action. Soil concentrations following removal operations are well documented and discussed in the "Soil" subsection (page 12) of the "Environmental Contamination and Other Hazards" section.

Comment 10: Had ATSDR bothered to read the full files, they would have found that the wastes came from across the Southeast. They were supplied either directly, or via various routes to Young Refinery to get rid of the waste or recycle it for further sale. The waste was buried, burned illegally onsite in downtown Douglasville at Young Refining Corp, and some was recycled. It should be noted that the wastes delivered to Young Refining, a lot of which was dumped at Basket Creek over time, came from the following places, among others: Monsanto, Rohm and Haas, Jennat Corp., research labs/hospitals across the South, Chem-Nuclear Services of Barnwell South Carolina, the Charleston Naval Nuclear Submarine Base and countless other places. Arivec wastes also came from Lockheed. Torpedo fuel was also dumped down there at Basket Creek according to local residents. Among the bills of lading were many deadly radioactive contaminants with the notation next to some "buried" although where was uncertain, though some was buried at the refinery according to an eyewitness and some may have been buried at Basket Creek according to another County resident. One barrel at the pit area was of a type formerly used to bury radioactive waste in.

Response to Comment 10: ATSDR reviewed all the files available from EPA and Georgia EPD relating to Basket Creek, Young Refining Corporation, and Arivec Chemical Company. Despite those reviews, ATSDR has no documentation of torpedo fuel or radioactive wastes being dumped at Basket Creek. ATSDR understands that EPA was made aware of some of those concerns during site sampling and investigations. EPA data indicates that only background radiation levels were detected.

Comment 11: It is not true (p.6) that there is a lack of information on groundwater flow patterns. The files show that the groundwater flows in four different directions, that there was also a surficial aquifer at the site and that the contamination definitely went all over the place and also to the creeks and Chattahoochee River.

Response to Comment 11: Site specific groundwater characterization has not been conducted, and based upon ATSDR's file reviews, only limited information regarding groundwater flow was available. ATSDR discusses surface water flow and contamination in the "Surface Water" subsection (page 17) of the "Environmental Contamination And Other Hazards" section. Although some metals were detected in surface water at levels exceeding comparison values, as discussed in the "Toxicological Evaluation" subsection (page 28), they were not at levels of public health concern.

Comment 12: In the past there have been a number of reports of environmental impacts from the site, including corroded culverts from site runoff; dead, dying, and weakened trees; a stinking fog that would rise up from the area; deformed and/or dying animals (domestic and wild); ulcerated fish; dead earthworms during the cleanup; and denuded areas near the site.

Response to Comment 12: In this Petitioned Public Health Assessment, ATSDR has evaluated the available site-related data and information to determine the potential public health impacts. ATSDR has little or no information documenting adverse impacts on the environment and wildlife at the sites. Due to the lack of information regarding site conditions and contaminant concentrations in the past (largely prior to 1990), ATSDR is unable to determine what potential human health or environmental impacts may have resulted from the sites during that time period.

Comment 13: Excavations and transport of soil have occurred in areas near or at the sites in the past. For example, a dam for a pond was constructed on one property, a garden had soil added and a man helped dig a pipe line on the property where the surface impoundment was located. That man later died. Because of the fact that the soil had been moved around the area EPA was repeatedly asked to test the soil at other sites, they would not, nor would they test water in a pond from which horses refused to drink. Reportedly, other areas around the sites may be contaminated.

Response to Comment 13: Again ATSDR has limited information and ability to evaluate impacts from past activities at the sites. It is ATSDR's understanding that EPA did hear and address concerns regarding other sites and/or contamination in the Basket Creek area. ATSDR discusses off-site sampling and EPA's efforts to identify other dump sites under "Soil" (page 14-15) in the "Off-site Contamination" subsection.

Comment 14: It is not true that little fishing occurs/is likely on the Chattahoochee in that area, many poor people fish there, all along 166 there are more toxic dumps going east that have not been cleaned up that drain to the Chattahoochee. Many people can not read any advisories as they are illiterate. Others fish anyway as they do not understand the danger and/or are hungry. There is not one (p.8) but two tributaries/creeks down from the sites.

Response to Comment 14: As referenced in the "Natural Resource Use" subsection (page 7-8), ATSDR obtained information regarding fishing and fishing advisories on the Chattahoochee River from the Douglas County Planning and Development Office and the Georgia Department of Natural Resources. Although ATSDR did not attempt to further substantiate the accuracy of that information, the levels of surface water contamination potentially resulting from the sites, as discussed above in the "Response to Comment 11," do not represent a public health threat.

Based upon the 1982 photorevised United States Geological Survey topographical map (Rico quadrangle), the springs downgradient of each site (i.e., surface impoundment and drum disposal area) form creeks that combine downstream into one tributary of the Chattahoochee River.

Comment 15: Residents had medical samples taken after they had been removed from the site, therefore certain toxics will have decreased in samples. Some urine tests were thrown out according to reports. I even wrote to ATSDR about all this. Blood tests were lost.

Response to Comment 15: As discussed in the "Health Outcome Data Evaluation" subsection (page 30), medical testing was conducted on 25 current residents and 12 former residents of the Basket Creek area (i.e., within ½ a mile from the sites). Seven of the former residents had lived in the area within the past 6 months and the other five within the past year. In the "Health Outcome Data Evaluation" subsection, ATSDR acknowledges that some compounds rapidly metabolize and are eliminated from the bloodstream and uses this in the evaluation of the data.

Problems encountered with some of the blood specimens are discussed in the "Response to Comment 6." Problems with or loss of urine specimens were not reported by ATSDR's Division of Health Studies.

Comment 16: The reported TRI site (p.10) in Douglasville is Young/Arivec.

Response to Comment 16: Young Refining Corporation is among the companies reporting releases to the Toxic Chemical Release Inventory (TRI) for Douglasville, Georgia.

Comment 17: To say there are no wells on either site is ludicrous. Well #3 was getting the runoff of both sites to some extent, the surface impoundment had water flowing across it every time it rained and the same thing happened at the barrel dump.

Response to Comment 17: ATSDR acknowledges the potential for contamination of well number 3 from the sites, however, a site is not defined by the areas where contamination may migrate. No wells are located within the designated site boundaries.

Comment 18: I will give just one example of report discrepancies: in the various test results in and around the surface impoundment I counted 29 chemicals, 11 metals, PCBs, 3 pesticides. Old tests, which were preliminary, had found 18 chemicals, 2 metals, and PCBs. But the ATSDR summary for the surface impoundment can only come up with 9 chemicals and 7 metals. To add insult to injury, ATSDR decides not only to not consider some contaminants (beryllium) as "contaminants of concern." This rural area, isolated even today, is measured against ranges for U.S. soil. Such a range would include what one would find next to a chemical saturated area in New Jersey or Detroit.

Response to Comment 18: ATSDR summarizes in this report only those contaminants that exceeded a comparison value (or where comparison values were not available) in at least one media (e.g., soil, water, air). Other contaminants detected during sampling that did not exceed comparison values were not summarized in this report.

Further evaluation of beryllium as a contaminant of concern was not necessary based upon the fact that low concentrations were detected, concentrations are well within background soil concentrations for the eastern U.S., beryllium is a naturally occurring metal, and the highest beryllium concentration was found in local fill soil.

Comment 19: Improper analyses were conducted by EPA for radiation and in other sampling.

Response to Comment 19: Invalid samples and problems or limitations of sampling or analyses identified by ATSDR during the review of site-related data have been discussed in the "Quality Assurance and Quality Control" subsection. EPA or Georgia EPD should be contacted in order to address any specific concerns regarding sampling analyses that have not been addressed in this document.

Comment 20: During cleanup at the drum disposal site only the nearest resident was relocated. The next closest resident had toxic dust blow across her property all the time. Her eyes would run and she was once taken to the hospital.

Response to Comment 20: Those specific concerns and symptoms/illnesses were not reported to ATSDR during removal activities at the drum disposal area. Air sampling was conducted during the drum removal operation, and although a limited number of contaminants were analyzed, no contaminants were detected at elevated levels.

Comment 21: EPA filled up the drum dump area with soil which they got from below the site. The other people stuck in the area said it smelled as bad as when the stuff was hauled out. No wonder the fill dirt ranged up to 46.3 mg/kg lead and they found beryllium. I've got news for ATSDR, Douglas County is not the beryllium capital of the world, nor is it the lead capital, except up around Young Refining and similar contaminated areas.

Response to Comment 21: The fill material was supplied from an adjacent property, but is unlikely to have been impacted by migration of site contaminants. The metals detected are naturally occurring in soil and were not considered to be at levels of public health concern. Sampling results from the fill soil were not indicative of site-related contamination.

Comment 22: After having been promised EPA would constantly monitor for dioxins during the incineration at the pit site, EPA then said it was too expensive.

Response to Comment 22: Dioxins were sampled and evaluated during the three test burns that were conducted prior to regular operation of the thermal oxidation system. Based upon the results, the thermal oxidation unit showed efficient operation and destruction of chemicals. Chemical compounds, including dioxins, were not detected at levels of public health concern, therefore dioxins were not sampled during removal activities.

Comment 23: They took no advance lead samples, even though the lead samples were staggering during the test burn. They took no radiation readings and they did not analyze mercury vapors. They did a bunch of computer modelling about the test burn and not the real amounts of what came out of the stack in parts per million during the burn. A five year wind rose pattern was used instead of a thirty year one.

Response to Comment 23: The contaminated soil was not heated or burned. The volatile and semi-volatile compounds released from the excavated soil was captured, filtered through a baghouse filter, and incinerated. The baghouse filter was designed to capture particulates, which would include metals such as lead. A mercury vapor analyzer was used to monitor soil samples and air inside the temporary building to ensure that mercury vapors were not present.

Real-time air monitoring was conducted to measure concentrations of gases prior to and after incineration. The concentrations at the stack were modelled based upon the wind patterns of the last five years to indicate worst case ambient concentrations. In addition, ambient air was sampled at three off-site locations. Further information regarding the trial burn is provided in the November 18, 1992, health consultation (page D44 of Appendix D).

Comment 24: Children played for years across the contaminated sites and on top of them. The people in the area told EPA that years before when one area caught fire, the fumes were terrible.

Response to Comment 24: Potential exposure to site-related contaminants is documented under "On-site Soil" (page 22) and "Ambient Air" (page 24) in the "Potential Exposure Pathways" subsection.

Comment 25: On page 27 ATSDR says there is no evidence beryllium causes cancer, yet ATSDR well knows that it is a deadly toxic.

Response to Comment 25: On page 27, under the heading "Trace Elements and Metals - Private Well Water," ATSDR indicates that beryllium is a health hazard from inhalation, but that evidence does not support toxic effects through ingestion of the contaminant (i.e., through soil, water, or food).

Comment 26: During the medical evaluations, I called up the lead Emory Doctor. He knew virtually nothing about the background of the site, he did not know where it had come from. He told me, that after talking to me, he had learned more than all the things provided to him by EPA which turned out to have been very little.

Response to Comment 26: ATSDR's Division of Health Studies initiated the case series (medical evaluations) and developed the final report. Emory University School of Public Health was only contracted to (1) obtain the medical records of each participant; (2) construct a record of past illnesses, hospitalizations, and laboratory results; (3) record a medical history and review of systems; (4) perform a physical examination and laboratory tests on each participant; and (5) provide a complete medical report to each participant and to ATSDR.

Comment 27: On page 31 ATSDR says how the residents health was protected during cleanup, this is rubbish, the stuff was blowing all over the neighborhood. The "sites" as ATSDR so blithely refers to, that families were removed from being near during cleanup was/were in their front yards and it almost took an act of God to get EPA to move them out during cleanup. People up the road could smell the vapors from the burning incinerator a lot, and it was dumping ash type stuff on their cars and made them choke sometimes. On page 32, as a lot of the soil had been washed off the sites over the years, the people must have been constantly breathing low levels of escaping vapors in the sites. It is not true that drinking/ingesting high levels of iron are not harmful, it can kill some people.

Response to Comment 27: Actions completed by ATSDR, EPA, and other organizations, to protect public health, are summarized under "Actions Undertaken" (page 36) of the "Public Health Action Plan."

Air sampling conducted during removal operations did not indicate exposure to contaminants at levels of public health concern or significant contaminant migration. ATSDR staff were at the surface impoundment site during most of the removal activities, and neither strong odors nor ash deposition was reported by staff members.

Iron can be harmful and even cause fatalities, however such severe toxicity is generally due to an overdose of an iron-containing medicine. As ATSDR has stated in this document, iron toxicity from drinking water is not known to occur. This is mainly believed to be due to the fact that iron imparts a strong and unpleasant taste to water, and a large volume of highly contaminated water would have to be ingested.

Comment 28: Page 35 says to restrict groundwater use on site properties and properties downgradient from the sites. Poorer people in the area may fish, the crap is going into the Chattahoochee ultimately and besides, Southwire is still wanting to put housing or something down there and/or lakes, and there are wildlife all over which drink that water crossing the sites. If Southwire puts housing in children could play in the creeks, etc.

Response to Comment 28: ATSDR has recommended restriction of groundwater use until groundwater remediation or characterization is conducted or until some alternative action is taken to ensure the protection of public health from potentially contaminated groundwater supplies. The environmental data obtained for off-site surface water and sediment, prior to remediation, and post-sampling data from the sites, following remediation, does not indicate that the site currently poses public health threat.

Comment 29: The temporary drinking water supplied (p.6) was supplied after massive public outcry as neither the county, the state, the federal government or anyone would supply water and school children and citizens were trying to do water drives. It was supplied in a tanker, and supplied for a few weeks only.

Response to Comment 29: ATSDR evaluated (August 8, 1991, health consultation on page D1 of Appendix D) preliminary well water samples (conducted in April and June of 1991) for six residences. Based upon detectable levels of lead in three wells, recommendations were made to either reduce lead levels in the potable well supplies or provide an alternative supply. As discussed in a second health consultation (dated October 21, 1991, on page D16 of Appendix D), additional sampling conducted July 8-9, 1991, did not reveal any contaminants at levels of public health concern. ATSDR recommended periodic private well sampling to ensure that contaminant levels do not increase to levels of public health concern. Temporary water was supplied in July 1991, and it is ATSDR's understanding that temporary water was available until permanent lines were laid to supply public water in August 1992. The extent to which this water was used by residents is not known.

Comment 30: EPA could not even get the wind directions right, therefore ATSDR has them wrong too, see page D30 for example. The prevailing wind is from the northwest to west. I showed that with my dispersion model for the air toxics and how they would fall to the ground and why people should be evacuated during the burn and cleanup of the surface impoundment and drum disposal sites.

Response to Comment 30: The wind rose for Atlanta, Georgia, does indicate that winds are frequently from the northwest and west. Locally the wind patterns could vary or the topography, as discussed on page D30 of the November 19, 1991, health consultation, may affect the winds. Local air monitoring report sheets indicated that wind was predominantely out of the north/northeast. Nonetheless, Perimeter monitoring was conducted around each site on an hourly basis during removal activities in addition to ambient air sampling. Sampling and monitoring is specifically discussed under "Ambient Air" (page 13-14) in the "On-Site Contamination" subsection.

Comment 31: On page D29 ATSDR does not understand the reason for EPA selecting target compounds for air sampling. Those target compounds were probably chosen as they were among ones that Young Refining had dumped at Basket Creek according to the files.

Response to Comment 31: ATSDR is not aware of whether or not EPA used background information to assist in the selection of air analytes for that sampling plan. ATSDR's concern regarding the target compounds, as discussed in the November 19, 1991, health consultation (page D29 of Appendix D), is that some of the compounds detected in the soil were not among the listed air sampling analytes.



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