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The Basket Creek Drum Disposal and Surface Impoundment sites are two hazardous waste dump sites in a rural area of Douglas County, approximately 50 miles southwest of Atlanta, Georgia. The Agency for Toxic Substances and Disease Registry (ATSDR) received petitions on the Basket Creek sites in April and June of 1991. ATSDR met with the U.S. Environmental Protection Agency (EPA) in May 1991 to discuss public health issues and actions needed to address concerns regarding the sites. On August 8, 1991, ATSDR completed the first of ten health consultations which were conducted to address public health issues at the sites. In September 1991, EPA initiated removal actions to remove contaminated soil from the area. The removal action was completed at the drum disposal area in August 1992 and in September 1993 removal actions were completed at the surface impoundment site. Groundwater from private wells has in the past been the primary source of drinking water for area residents. Although many private wells in the area have been sampled, the extent of groundwater contamination and flow patterns have not been established. Residents have been connected to the county water system.

ATSDR has classified both sites as indeterminate public health hazards primarily because of insufficient past environmental data. ATSDR has determined that groundwater at the two sites is a past completed exposure pathway. Potentially completed pathways were established for surface soil, sediment, surface water, and air; however, future significant exposures via those pathways are unlikely. Based on current data and the present condition of the sites, the sites are not believed to represent a current public health threat.

Several contaminants at concentrations of concern (lead, mercury, and several volatile organic compounds [VOCs]) were identified in subsurface soil at the two sites. In addition, past use of water from two private wells contaminated with lead (24 and 66 µg/L) is of public health concern. The source of lead in the drinking water has not been determined, although lead used in the plumbing is a suspected source. It is prudent public health practice to reduce exposure to lead from all environmental pathways. The main concern about lead exposure stems from evidence that children and developing fetuses are especially sensitive. Skin contact with and incidental ingestion of soil contaminants are not expected to have been significant routes of exposure because the contaminants were found below the soil surface. The possibility that people came in contact with contaminated subsurface soil seems remote. However, the question of whether incidental ingestion of soil contaminants occurred in the past (particularly before the reported backfilling of sites in 1976) remains unanswered, as does the question of whether people were exposed to airborne contaminants (VOCs and suspended particulates) during that time period. If people have been exposed to VOCs in the air, they may experience irritation of mucous membranes, skin rashes, and some neurologic effects. Cleanup of the sites has eliminated the potential for future exposures (via ingestion or inhalation) to contaminants at the sites.

The immediate community is composed of approximately 30 people living within a 1-mile radius of the sites. This community, as well as people residing outside of the 1-mile radius, have expressed many concerns about their health and quality of life to ATSDR. The Agency has addressed many concerns and questions through several health consultations and, now, through this petitioned public health assessment. The petitioned public health assessment was released for public comment April 17, 1995 through May 28, 1995. Comments received have been listed and addressed in Appendix E.

ATSDR also conducted a case series (individual medical exams) to evaluate the health status of area residents and former residents. ATSDR staff have met with residents on numerous occasions to discuss the results of medical exams, the public health implications of removal actions, and other issues of concern to the residents.

In this petitioned public health assessment, ATSDR recommends actions to identify, reduce, and prevent exposure to contaminants. ATSDR will evaluate any new data or information it receives about this site to determine if additional public health actions are warranted.


Through its petitioned public health assessment process, the Agency for Toxic Substances and Disease Registry (ATSDR) has evaluated the public health significance of the Basket Creek Drum Disposal and Basket Creek Surface Impoundment sites. More specifically, ATSDR has determined whether health effects are possible and has recommended actions to reduce or prevent possible health effects. ATSDR, which is in Atlanta, Georgia, is a federal agency within the U.S. Department of Health and Human Services and is authorized by the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) to conduct public health assessments of hazardous waste sites. ATSDR was petitioned by a private citizen on April 24, 1991, and by a U.S. congressional representative on June 24, 1991, to evaluate the Basket Creek sites.

A. Site Description and History

Two waste disposal sites, Basket Creek Drum Disposal and Basket Creek Surface Impoundment, are on private property in a rural area in the southeastern corner of Douglas County, approximately 15 miles from Douglasville, Georgia. The locations of the sites are shown in Figures 1 and 2 (Appendix A) (EPA 1990). The two sites are approximately 1,000 feet apart, separated by a small ridge, and are the result of nonpermitted waste disposal practices. The Georgia Environmental Protection Division issued an emergency order to stop the nonpermitted dumping in 1976, and the impoundment was closed by backfilling sometime later that year (EPD 1986).

The drum disposal site, a steep ravine just off Basket Creek Road, was used from 1975 through 1976 for disposal of drums of liquid waste and was subsequently covered with fill material. Although undocumented, it has been reported that dumping began in the late 1960s. Disposal was first discovered by a Douglas County Sanitarian, who observed the unpermitted dumping activity during the night in March 1976. Approximately 80 fifty-five gallon drums had been unloaded from a tractor-trailer and dumped at the time of the sanitarian's arrival; another 80 drums from a second tractor-trailer remained to be unloaded. Samples from two drums were analyzed and showed ortho-chlorophenol, acetone, tetrachloroethane, and chloroform (EPD 1985a, 1985b). The drum disposal area caught fire in 1985 and burned for about a week, before it was extinguished (EPD 1985c, 1985d). Several contaminant-specific air samples were taken at the time of the fire.

The surface impoundment, approximately a quarter acre in size, is in a natural drainage area that is also just off of Basket Creek Road. Waste oil and solvents (predominantly methyl ethyl ketone, xylene, toluene, and acetone) were dumped at the impoundment in 1975 and 1976. Wastes were left to evaporate or percolate through the soil of the unlined impoundment. Sometime in 1975, the impoundment was reported to have caught fire. The impoundment was backfilled after disposal practices ceased in 1976 (EPD 1986, 1985b, 1985e).

A spring is downslope from each site. The Chattahoochee River, which is approximately a mile away (to the southeast), is also in the surface water drainage basin of both sites. The residence nearest the drum disposal site is 250 feet east of the site; the home was built in 1985. Two wells have been drilled for that residence; one well is approximately 100 feet east of the residence, and the other is 300 feet northeast (downhill from the surface impoundment). The home nearest the surface impoundment is roughly 100 feet to the northwest; the residents used water from a nearby well, which was bored prior to when the current owner established residence (before 1981) (ATSDR 1991a).

The Georgia Environmental Protection Division conducted a site inspection, environmental sampling, and several site visits in 1985. Some of the site visits and sampling were in response to the fire that occurred at the drum disposal area early in that year. The U.S Environmental Protection Agency (EPA) became involved in 1990 by conducting file searches, a site inspection, and a sampling plan. Two private wells, on-site soil, and off-site surface water and sediment, were sampled during March 1990. Following groundwater sampling, of private wells throughout the community during April 1991, EPA sent individual letters that evaluated each resident's drinking water. Additional rounds of groundwater samples were taken and one well revealed contaminants that are believed to be site-related. To protect the community from potential groundwater contamination, temporary drinking water was supplied in July 1991 and a permanent supply was provided in August 1992. EPA initiated removal activities at the sites in September 1991, beginning with removal activities being conducted by the potentially responsible party for the drum disposal site.

Chem-Nuclear Systems, Inc., a potentially responsible party, has completed cleanup activities at the drum disposal area; drums, tires, and contaminated soil were excavated. The actual work area -- the contaminated, or exclusion, zone -- was taped off and only authorized personnel had access to it during the 1991-92 removal activities at the drum disposal area. Excavation continued until pre-established cleanup levels were satisfied (see ATSDR Record of Activity for 10/30/91 and 4/6/92 in Appendix D). Drums containing liquid waste were overpacked or transferred into other drums for proper off-site treatment or disposal. Measures were taken during removal activities to control off-site migration of contaminants (CWMI 1991a). The nearest resident was relocated during the removal operation. The site was covered by backfilling the site with soil to an average depth of 10 feet and reseeded to prevent erosion.

EPA conducted removal actions at the surface impoundment during 1992 and 1993. Before EPA involvement, no remedial actions, other than the initial backfilling, were taken. Preparation for removal of soil from the surface impoundment began in May 1992. EPA actions included the combustion of volatile chemicals in contaminated soil before removal to an industrial waste landfill. The site was fenced to restrict access and was monitored 24 hours a day by personnel. The surface impoundment was enclosed in a building to minimize migration of chemical vapors, while contaminated soil was excavated. The building was kept under negative pressure to capture contaminants volatilizing from the contaminated soil. The vapors were then destroyed by a thermal oxidation unit located north of the building. The nearest resident was temporarily relocated during the operation. Other safety measures were also implemented to ensure the protection of public health during removal activities at the site (see 10/13/92 and 11/18/92 health consultations, Appendix D, for more information). All EPA activity at the Basket Creek Surface Impoundment site was completed on September 16, 1993 (EPA 1993a).

ATSDR's Emergency Response and Consultation Branch has conducted seven written and three verbal health consultations (refer to Appendix D). The series of health consultations began in August 1991 with an overall general evaluation of the possible health threats posed by the two sites. Subsequent consultations evaluated residential well water samples; air monitoring results and site contingency and air monitoring plans; public health implications of removal actions at the surface impoundment and drum disposal area; and proposed clean-up levels. As a result of those health consultations additional well water monitoring was conducted, cleanup levels for the Emergency Removal Phase were established, residents were relocated during test runs of the thermal oxidation unit, and other public health actions and precautions, to be taken during removal actions, were implemented. In addition, the Agency's Division of Health Studies conducted a case series (individual medical exams). The case series began in late 1991 and was published in mid 1993.

B. Site Visit

The initial site visit was conducted on June 17, 1991, by an Environmental Scientist and a Medical Officer, from ATSDR headquarters, and an ATSDR Regional Representative for EPA Region IV. They met with the EPA On-Scene Coordinator during their visit. Observations about the two sites and the physical layout, as well as the local geographic features and residences, were noted. The surface impoundment encompasses approximately 400 square feet and is relatively level, resting at the head of a ravine that slopes sharply to the east. Approximately 1,000 feet south of the impoundment is the larger drum disposal area. That site is in what was once a steep ravine; eventually, the drums were covered with fill material. Surface runoff appears to flow in different directions; however, runoff from both sites eventually flows to the Chattahoochee River. The lack of information on groundwater flow patterns and on-site groundwater contamination creates uncertainty about whether private well contamination is directly linked to the Basket Creek sites, or is a result of other contaminant sources or natural groundwater quality.

The residences nearest the surface impoundment and the drum disposal area are both topographically upgradient of the sites. Sixteen other residences are within 1 mile of the sites. All of the homes within the 1-mile radius used private wells in the past for drinking water. Temporary drinking water was supplied in July 1991 and in August 1992 residences were connected to the Douglasville-Douglas County Water and Sewer Authority water system. The sites and local residences are shown in Figure 3 of Appendix A (ATSDR 1991b).

Various ATSDR staff have made subsequent site visits to meet with residents, EPA representatives, contractor representatives, and elected officials to discuss site-related issues and community concerns. Various site-related information and data have been gathered from EPA and the Georgia Environmental Protection Division.

C. Demographics, Land Use, and Natural Resource Use


The 1990 census reports a total population of 71,120 for Douglas County. The Basket Creek sites are in the Fairplay Division of Douglas County (census tract 804), an area of roughly 43 square miles. According to the 1990 census, the tract had a total population of 3,914. The majority of the residents are white (98.3%); less than 2% are African-American or other races. Hispanics constitute less than 1% of the population in the census tract. Age distribution in the tract is similar to the overall county age distribution; in both areas, approximately 15% of the population are younger than 10 years, and slightly more than 7% are 65 or older.

The people who live in the census tract in which the Basket Creek sites are located appear to be more stable (less transient) compared with Douglas County overall. Of the total number of occupied homes in census tract 804 (1,272), 91.5% are owner occupied. In contrast, only 77.8% of the homes in Douglas County are owner occupied. The median value of homes in the Basket Creek sites' census tract area is slightly greater than that for Douglas County ($77,600 and $73,400, respectively) (U.S. Bureau of the Census 1991). Those figures suggest that the census tract population is nontransient and of middle socioeconomic status. In the immediate Basket Creek Road area, 18 homes are within about a mile of the sites. From visual observations, the homes along Basket Creek Road near the sites appear to represent moderate income housing.

Land Use

The Basket Creek area of Douglas County is zoned for large lot, single-family residences and agriculture. Agriculture in the area, historically timber, cattle, and crop farming, has greatly diminished. The area is primarily wooded and is characterized as rural. Most of the farms of the 1920s and 1930s have grown over with pines and hard wood trees. The area experienced considerable growth in the 1950s and 1960s, especially following development of the interstate. The county is largely residential, with little industry. The Basket Creek Road area, in particular, has no industry or commerce.

The Chattahoochee River, and land within 2,000 feet of the river on either side, is protected by the River Protection Corridor. The land is regulated by the Atlanta Planning Commission, which controls development within the Corridor (ATSDR 1992a).

Natural Resource Use

The Douglasville-Douglas County Water and Sewer Authority is currently building a reservoir on the Dog River, which is a few miles north of Basket Creek Road. The reservoir will back up into the low lands almost to Highway 166 (which runs east to west, approximately 1.5 miles north of Basket Creek Road); it will cover 225 surface acres and contain 1.2 billion gallons of water. Homes in the area connected to the public water supply receive their drinking water from a station on the Dog River (ATSDR 1992b). Plans for recreation at the reservoir include docks along the shore line, nonmotorized boating, and, possibly, picnic areas. The reservoir, which is in a drainage basin separate from the sites in question, is the nearest facility of its type. There are no parks in the area.

Hunters of large and small game use the Basket Creek area. No official game lands are in the area, but some private landowners allow hunting on their property. Southwire Corporation owns a large tract of land near the sites that is used as a private hunting club and retreat facility; activities there include gatherings of Boy Scout troops and horse shows (ATSDR 1992a, 1992c; EPA 1990). In addition, Southwire Corporation is currently constructing some lakes to be used for recreational purposes.

Very little fishing or recreation is likely on the Chattahoochee in that area of Douglas County due to the aesthetically unpleasant characteristics of the water (ATSDR 1992a). The Georgia Department of Natural Resources released advisories in 1991, warning against eating largemouth bass caught from the river in the vicinity of Highway 92 (12 miles north of the Basket Creek area) and against eating carp, hybrid fish, and catfish taken from the Chattahoochee River between Highway 92 and West Point Dam. Those advisories were issued because chlordane levels in the river (unrelated to the Basket Creek sites) exceed permissible levels set by the U.S. Food and Drug Administration (ATSDR 1992d). The tributary downslope of the sites may be too small for fishing, but uses of the stream are not known.

For the 18 homes within a 1-mile radius of the sites, groundwater from private wells has in the past been the predominant source of drinking water and water used for most domestic purposes. The private wells in the area are primarily drilled wells with steel casings, ranging from 150 to 400 feet in depth (ATSDR 1992e). Two private wells are relatively close to the surface impoundment. A 75-foot-deep bored well is roughly 75 feet uphill of the site. Approximately 200 feet downhill from the site is a drilled well measuring 272 feet in depth (ATSDR 1992f). Bored wells are larger in diameter (typically about 30 inches), but are shallow (usually fewer than 100 feet deep) compared with drilled wells, which range up to 400 feet deep and are typically 6 inches in diameter. The bored wells tap into the upper water-bearing zone or the weathered zone; the deeper drilled wells draw water from the bedrock zone.

D. Health Outcome Data

To assess community health concerns and health conditions that could be related to contaminants from the Basket Creek sites, ATSDR investigated the availability of health information sources or health outcome data. Possible sources of health outcome data included state and local vital statistics, registries (birth defects, cancer-related), medical records, and health studies.

The Georgia State Health Department and local public health officials were contacted for existing aggregate, tabulated, or computerized health information sources (health outcome data). The state and local health departments collect certain vital statistics, including birth, miscarriage, and abortion data and data on the most common causes of death (such as neoplasms, diseases of the respiratory system, and congenital anomalies). However, the smallest geographic units for the health outcome data sources are at the county and city levels. As was stated in the Demographics section of this petitioned public health assessment, the 1990 census reported a total population of 71,120 in Douglas County and a total population of 3,914 in the Fairplay Division (census tract 804) of Douglas County. The resident population of the Basket Creek community is estimated to be less than 30. Thus, no computerized or tabulated health outcome information have been identified that exclusively addresses the very small resident population of the Basket Creek community.

On December 8, 1991, the ATSDR Division of Health Studies, through a contract with Emory University (DHS/EU), provided medical services including physical examinations and blood testing to 37 former and current residents of the Basket Creek community. However, due to sampling problems, not all the tests were completed on all of the participants. This data and information offer an opportunity to examine health data related to contaminants found on site. The results of the DHS/EU testing are reviewed in the Health Outcome Data Evaluation section of this petitioned public health assessment.


ATSDR has gathered information about community health concerns from members of the community who live near the sites and from the District's Congressional Office. Concerns have been expressed during public availability sessions, site visits, telephone conversations, and public and community meetings with ATSDR staff. An estimated 30-40 people have been contacted by ATSDR staff. The following community health concerns have been brought to ATSDR's attention:

  1. Is the water currently safe to drink?
  2. Will the water be safe to drink in the future?
  3. Would the residents' health be affected during cleanup?
  4. Could mouth sores, rashes, and respiratory problems be related to the site?
  5. Do children in the neighborhood have high blood lead levels resulting from the sites?
  6. Could residents' health problems over the years be a result of the two sites?
  7. Did the previous fires adversely affect the residents health?
  8. Will children, pets, or hunters be affected by potential future spring water contamination?
  9. Has waste been buried in the Basket Creek area, other than that being removed from the surface impoundment and drum disposal area?

Two residents expressed concern about an unusual discoloration of their water that would periodically occur. ATSDR responded to these concerns by meeting with some of the residents and investigating this concern (see 2/24/92 ATSDR Trip Report in Appendix D for more information).

Some of the questions have already been addressed through health consultations prepared by ATSDR. All of the concerns are discussed in the Community Health Concerns Evaluation section.

During conversations with ATSDR staff, residents expressed concern about illnesses and other health problems; the most common being: skin rashes, watery eyes, headaches, general sickness, mouth sores, depression, and learning disabilities.

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