Health Consuttation Monsanto Company Anniston, Calhoun County, Alabama CERCLIS NO. ALD004019048 Prepared by t Alabama Department of Public HeaIth Under Cooperative Agreement with the Agency for Toxic Substances and Disease Registry B A C K G R O W AND STATETLIENT OF ISSUES This health consultation was prepared to determine whether the polychlorinated biphenyl (PCB)Contamination found both on and off-site the Monsanto Company in Anniston, Alabama presents a public health threat. On March 21, 1995, representatives of the Monsanto Company contacted the Alabama Department of Public Health (ADPH) regarding off-site data. Monsanto discussed the possibility of human exposure to PCBs detected in and around their West-End Landfill (WEL), and in the East Drainage Ditch (EDD)that leads from their landfills to Snow Creek. After visiting the site and consulting with members of the Alabama Department of Environmental Management (ADEM), Site Assessment Unit, both azencies decided that a health consultation was needed to address the possible exposures and health impacts from PCB contamination on and off the Monsanto facility. Other contaminants at the sire will be evaluated in future health consultations. Site Description . The Monsanto Company is located approximatzly one-mile west of downtown Anniston on State Highway 202 in Calhoun County, Alabama (Figure 1). The Monsanto property consists of four tracts of land separated by highways, railroads , and utility right-of-ways’. The main facility is located northwest of the intersection of Highway 202 and Clydesdale Avenue. South of the main facility are Monsanto’s landfills while the area north of the facility contains both residential and industria1 zones. The plant is bordered on the east and west by residential neighborhoods. The WEL is located just west of the main facility. T h e plant is located near the eastern edge of the Alabama Valley and Ridge physiographic province. The general terrain of the area is characterized by northeast-trending valleys paralleled by ridges and mountains. The valley floors range from an altitudt of 500-900 feet mean sea level (msl)and the ridges range from 1000 to 2100 feet rnsl. Regional geologic formations have been extensively folded into northeast-trendins anticlines and synclines complicated by thrust faults that have general northeast-trending strike and a southeast-trending dip‘. The Jacksonville Fault is located north of the facility approximately three-tenths of a mile. The surface geology consists of sandy or silty clays underlain by the Shady Dolomite. Several surface water bodies arc adjacent to the Monsanto Company. The EDD 1 originates in the area of Monsanto's solid waste management units (SWMUs) and migrates along the western edge of the area where Monsanto's South Landfill was located (Figure 2). The EDD flows northward through the Clydesdale community and is joined south of Seventh Street by Monsanto's waste water discharge ditch (The waste discharge ditch originates from an old limestone neutralization bed). The EDD meanders through several residential neighborhoods and eventually empties into Snow Creek. The Northern Drainage Ditch (NDD) consists of a series of ditches that run along the northern boundary of the Monsanto facility (Figure 3). The bottoms and sides of most of the ditches consist of silt and clay, yet some portions are concrete or below ground. The western end of the NDD appears to have some westerly flow. However, the remaining portion of the NDD flows toward Snow Creek. . Snow Creek is a small stream that flows southward through the City of Anniston (Figure 3). A tributary of the creek begins northwest of the Monsanto facility, and flows northeastward until it reaches Boyton Street. The creek begins to flow southward and passes through numerous neighborhoods, severaI recycling centers, and a mall. Portions of the creek flow through concrete channels, yet most of the course is unIined. Snow Creek empties into Choccolocco Creek south of Interstate 1-20 (Figure 4). Choccolocco Creek is part of the Coosa River Basin and flows through Cleburne, Calhoun, and Talladega Counties. Jackson Creek, Hillabee Creek, Dry Branch, Snow Creek, Coldwater Creek, and stveral unnamed tributaries flow into Choccolocco Creek as it meanders westward from Anniston (Figure 5 ) . The creek empties into Lake Logan Martin on the Coosa River. DemoPraDhics According to the 1990 Census data, the total population for the City of Anniston is 26,234. A geographic information system (GIS)was used to estimate the population within one mile.of the Monsanto site. The GIS gives an estimated population of 5,926 people and 1,580 families living within one-mile of the Monsanto facility. Approximately 56% are whitz and 44% are black and other. Children under the age of five comprise 7 % of the population while residents over the age of 65 comprise 15% of the population. 2 GIs was used to estimate the population within a quarter-mile region of the EDD-Snow Creek drainage basin. The program estimates that approximately 2,782 people live within a quarter mile of the drainage basin. This population is divided into approximately 1,534 females and 1,248 males. Approximately 13% of the population is under the age of five, and 37% of the population is over the age of sixty-five. Whites comprise 62% of the popuIation while blacks compose 37% of the population. Site Background and Historv - Operations began at the site in 1917 with the formation of the Southern Manganese Corporation. The Southern Manganese Corporation manufactured ferro-phosphorus, ferro-manganese, ferro-silicon, and phosphoric acid. In 1927, the Southern Manganese corporation began producing biphenyl', which is used as a heat-transfir agent. Southern Manganese corporation became Swam Chemical Company in 1930, and was purchased by Monsanto Company in 1935'. Monsanto Company currently produces biphenyl, polyphenyls (TherminoIs), and p-nitrophenol at the plant and formerly produced PCBs, parathion, phosphorus pentasulfide, and calcium carbide2. Disposal of hazardous and nonhzzardous wastes occurred at several different landfills throughout the history of the plant. The W E L is a six-acre plot located immediately west of the Monsanto facility (Figure 6) that operated from the mid to late 1930's to 1961'. The unlined landfill was used for disposal of all refuse from the facility. AeriaI photographs from 1953 to 1978 revealed that little or no trees surrounded the WEL and that the landfill is larger than actually reported in the Anniston West End Landfill Report. The WEL and the adjacent areas sloped toward First Avenue, and many streets were dirt until the late 1950's. Several dirt roads were seen leading from First Avenue toward the landfill, and houses were observed from 1954 until 1977 on the same land tract as the WEL. The houses were at the junction of First Avenue and Hwy. 202. It was observed in the photos that the property adjacent to the landfill was used as a dirt parking lot, and that part of the property was cultivated. Personal communication with Monsanto representatives revealed that one area resident reported using the land as a garden for many years. This report was confirmed by the aerial photographs. Aerial photographs showed that the landfill was not f a x e d until after 1978. 3 In November 1961, the WEL and the adjacent property were exchanged to the Alabama Power Company (APCO)for property immediately south of the landfill’. APCO used the filled property as a utility right-of-way for their Anniston 230 kilovolt transmission line. The power company also built a transmission substation on the crest of the hill immediately adjacent to the landfill area. A section of the northern toe of the landfill was removed and/or redistributed on the property so that an APCO substation and an APCO regional switching station could be built’. In April 1993, the power company notified . state and federal environmental officials that preliminary analyses of material found at the Anniston substation indicated significant concentrations of PCBs. . . The material was found during a routine inspection of the 25-acres of land that APCO received from Monsanto Company. A thin protective covering of soil was placed over the toe of the landfill in late April 19933. In December 1993, Monsanto reacquired the property, and began a thorough investigation of the IVEL‘. The results of the investigation were published in August 1994 in the Anniston West End Landfill Site Investieation Report. . I The South Landfill (SL) was located just east Clydesdale Avenue and near what is now Highway 202 (Figure 7). Monsanto began operations around 1960 with the closure of the WEL. Aerial photographs taken in the area revealed that the landfill was in existence around 1962. Vegetation in the area was light to moderate and access was not restricted. Photos taken during 1953 and 1985 revealed some dirt roads and a stveral large barren areas existed just east of the SL. A records search revealed that old iron pits just south of the SL were used for disposal purposes in the 1920s’. In 1978, the SL was removed by the Department of Transportation and placed in Monsanco’s existing SWh/IUs6. The landfill was removed to allow State Highway 202 to be straightened and widened to four lanes. Previously, the highway curved around the Monsanto plant and joined Tenth Street. J ” SWMU-1E and SWMU-2E were unlined landfill cells that are located south of the main facility and across Hishway 202 (Figure 7)’. The cells were established in former iron ore pits and operated from the 1920’s to the late 1950’s/earIy 1960’s. The area of SWMU-1E are unknown while the size of SWMU-2E was approximately 3.5 acres. The landfills received all disposed refuse from the plant. The refuse includes wastes generated by the phosphorus, arochlor, and chlorination processes’. 4 .... , ., ._ , ~. . t - t - I SWMU-3E is an inactive disposal cell that is located east of SWMU-3-E (Figure 7). The unit was developed in the early 1980’s and covers approximately two acres. The landfill was used for nonhazardous chemical wastes and received approximately 45 tons per yea?. SWMU-lW, 2W, 2WA, and 3W were unlined landfill cells that are located ,- --., south of the main facility and west of SWMU-1E (Figure 7). These cells‘b&mireceiving wastes in the early 1960’s and operated until 1975. Thesize of t l i e - w landfills is unknown, and wastes deposited in the cells include parathion, methyl -parathion, PCBs, asbestos, p-nitrophenol, and biological solids from the waste . water treatment f a c i l i ~ . SWMU4W was an unlined landfill cell that is located southwest of SWMU-3W (Figure 7). The unit was approximately 22 acre feet in size and operated from 1973 to 1983. Initially, the landfill was constructed to receive only organophosphate contaminated sulfur. However, the cell also received parathion, methyl parathion, PCBs, asbestos, p-nitrophenol, and biological solids from the waste water treatment faciliv. Aerial photographs from 1953 to 1978 revealed several potential disposal areas that still require investigation. Dirt roads and several potential disposal areas appear east of Monsanto’s existing SWMUs. Aerial phatos revealed dirt roads leading from Monsanto property to several barren zxas south of the Monsanto property and along the Alabama Power Company utility right-of-way. Possible disposal locations were observed west of blt. View Rd., west of Third Avenue, and north of Emery Street. Several surface water bodies have been impacted by operations at the Monsanto plant. In 1985, the Alabama Attorney General’s Office detected PCBs in sediments in Snow Creek that ranged in concentration from 198 pans per million (ppm) to 400 pprn’. As a result of this investigation, both Monsanto and ADEM did extensive sampling of the EDD and Snow Creek’and found that PCB concentrations ranged from 16 ppm to 1069 ppm. In April 1988, Monsanto removed the contaminated sediments from Snow Creek and the norlhern portion of the EDD. Sediments were removed from the bottom of the channels and placed on the banks for dewatering. The sediments were transferred to a SMWU and tested to determine the best disposal method‘’.’. However, the plan was implemented without approval from the state or the United States Environmental Protection Agency (USEPA). After remediation, soil sampling from the removal a r e s showed PCB concentrations greater than 50 pprn' . In 1970, PCBs were detected in fish in the Coosa River System that ranged in concentration from non-detect to 360 parts per million'. In August 1993, ADEM conducted a sediment and fish study in the Choccolocco Creek watershed after several deformed largemouth bass were caught". Tributaries included in the study were Choccolocco Creek, Jackson Creek, Hillabee Creek, Dry Branch, Snow Creek, and Coldwater Creek. The results of the investigation found 14 of 21 sediment samples had detectable levels of PCBs and that 18 of 19 fish exceeded the Food and Drug Administration's tolerance level of 2 ppm. In November 1993, the ADPH issued a "no consumption fish advisory" for all species of fish caught between the confluence of Snow Creek and Choccolocco Creek south of Oxford, downstream to where Choccolocco Creek flows into Lake Logan Martin". Site Visit In April 1995, ADPH and ADEM staff .visited the Monsanto site and made the fo110wing observations : On-site The team noted a lack of vegetation around the WEL and observed several barren areas. Although the landfill is surrounded by a fence, graffiti was written on the concrete flume at the toe of the landfill. Graffiti at the site was not seen by ADEM personnel during an earlier visit. Several areas along the toe of the landfill were eroded, and evidence that water had seeped out of the landfill was seen on the flume. The SWhfUs Iocated across Hwy. 202 were grassed and restrictzd by a fence. Trees and vegetation around the SWMUs did not appear stressed,.and the underbrush was light to modzrate. The headwaters for the EDD drainage ditch begin on the western edge of the SWMUs and was approximately 2.5 to 3 feet deep. A second drainage ditch was also seen on the eastern side of the sw Mus. 6 . . .- .... 1 * '- '- 1' '-.* T I ' ; .. Off-si te The team nored several residences and a school west of the WEL on First Avenue. The residences and the school are approximately 50 feet from the fence surrounding the contaminated soils. A playground was obszrved on the eastern side of the schooI. Several important features were noted by the team members as they toured the EDD and Snow Creek. Access was not restricted by a fence at any point, and evidence of past human activity was prominent in several areas. The team observed that vegetation was moderate as the EDD flows beneath Hwy. 202, and that the ditch was 2-3 feet deep and approximately 3 feet wide. These dimensions increased to approximately 5 feet wide and about 5 to 6 feet deep in the Spring Street area. A church and severaI homes surrounded the ditch at the junction with Spring Street. Many homes had dirt driveways or yards, and there was evidence of children living in the homes. The EDD was joined by Monsanto's waste water discharge ditch at Seventh Street. At Seventh Street, the drainage ditch was approximately 2 to 3 feet deep and is 5 fzet wide, and surrounded by thick vegetation. N o homes exist in this area. As the EDD nears Eighth Street, the ditch is approximately 2 feet in depth and 5 feet wide. Vegetation has been removed from around the drainase ditch in some areas. A church is located at the intersection of the EDD and Eighth Street. At this point the drainage ditch flows underground and surfaces just before 10th Street. From Tenth Street to the confluence with Snow Creek, the EDD moves through several residentia1 neighborhoods and has little vezetation around it. At the confluence with Snow Creek, several trails were seen aiong the bank of the creek and children's toys were observed in the water. The upstream portion of Snow Creek flows through a concrete liner, while the downstream portion remains unlined. A few empty bait containers were seen in the water, yet it is unlikely that fishins occurred in this area because the water was only 1 to 2 feet deep. An elementary school is located northeast of the confluence by approximately 75 yards and is surrounded by a 5-foot chain-link fence with a Pate on the southwest corner. The gate was open at the time of the site visit and overgrown with vines. Hence, it is probable that the fence had been open for a substantia1 period of time. - 7 , * I. *, .. Drscussr ON The following sections are a review of the environmental data collected for the hlonsanto site. The quality of the data will also be evaluated in the following sections. The review will consist of the frequency of the PCB contamination, the concentration in various media, and the source for the contaminants. The basis for selection of PCBs as contaminants of concern are as follows: 1. concentrations of contaminants are above ATSDR, USEPA, or the Food and Drug Administration (FDA) comparison values; and 2. the sampling design and field and laboratory data quality. In preparing a health consultation, PCB concentrations in specific transport media are compared to established comparison values. If the PCB concentrations are above the established comparison values, the concentrations are used to estimate doses and cancer risks for each exposed or potentially exposed population. These estimated doses are compared to health guidelines. If health guidelines are exceeded, adverse health effects may occur. However, these are only estimates, and do not mean that any adverse health efftcts have or will occur. Scientific literature is used to determine if adverse health effects are likely to result from current or estimated exposure levels. Please refer to Appendix C to see the categories used to evaluate the potential cancer risks. ATSDR has developed Minimal Risk Levels (MRLs) for contaminants commonly found at hazardous waste sites. MRLs were developed for ingestion and inhalation exposure routes, and also take length of exposure into account. Length of exposure is divided into acute (less than 14 days exposure), intermediate (15 to 364 days) and chronic (365 days or more). If an MRL is not available for a specific contaminant, ATSDR uses the USEPA's Reference Dose (RfD). . An RfD is an estimate of a chronic daily human exposure to a Contaminant, below which noncancerous health effects are not likely. Certain assumptions were made in calculating estimated exposure doses. The calculations are based on an adult with an assumed weight o f 7 0 kilosrams (kg) (154 pounds) and a child with an assumed weight of 10 kg (22 pounds). The adult is assumed to ingest two liters of water per day, and a child is assumed to ingest one liter of water per day. We assumed that adults ingested 100 8 I d milligrams of soil each day (rng/day) through inhalation of soil particles in the air, and from incidental ingestion of soil particies on hands pIaced in the mouth. W e also assumed that a child ingested 200 mg/day through inhalation of soil particles in the air, and from incidental ingestion of soil particles on hands placed in the mouth. Adults were assumed to eat 30 mg/day of fish taken from Choccolocco Creek, while children were assumed to eat 10 mg/day". For the purpose of this report, we used multiple exposure durations because each area of contamination has a different history. Therefore, each area of contamination will be addressed as if it were a n operable unit, and a different risk scenario will be provided for each unit. W e s t End Landfill \VEL Soil Soil quality of the WEL and the surrounding property was divided into thret areas of concern: the suspected landfill surface P E L ) , the adjacent area downgradient of the landfill (A-4)' and the fence line adjacent to First Avenue. The WEL and the AA were each divided into four quadrants that were further subdivided into nine subquadrants (Figure 8). A surface soil sample was taken from each subquadrant and compiled to form one composite sample for each quadrant. Surface soil samples were also taken approximately every 100 yards along the western fence line. T h e samples were analyzed for PCBs according to USEPA method 8080'. Table 1 contains the PCB sampling results for the WEL. For residents who live around the WEL, we used the maximum possible exposure duration of 68 years (1927-1995) for adults and 6 years for children to obtain the most conservative estimate of risk. We used the maximum exposure frequency of 104 days per year because the residences are located in close proximity to the landfill and residents were likely to visit the landfill twice a week. For residents who lived on the same land tract as the WEL, the risks for both cancerous and non-cancerous health effects are greater than those who lived around the WEL. However, since the exposure data for these residents is not known, the past exposure risks wili not be estimated. For residents who lived around the WEL, the estimated child and adult exposure from PCBs in surface soil is greater than ATSDR's chronic oral ..*. . . .- .. L bfm. However, the MRL is set 1000 times below the level at which PCBs causes adverse health effects in animals. Therefore, PCBs in surface soil in and around the.WEL is unlikely to cause noncancerous adverse health effects in adults and children. PCBs are classified as a probable human carcinogen because cancer has been demonstrated in animals but remains undetermined for humans. For adult residents exposed to PCBs in and around the WEL, the estimated increased risk of cancer is moderate. For children, the estimated risk for cancer is low (Appendix C). ~ For workers who worked on and around thz WEL, risks were estimated using an exposure duration of 32 years and an exposure frequency of 8 hours per day (hrs/day) for 5 days per week (daysheek). The estimated worker exposures to PCBs in surface soil in and around the W E L is greater than ATSDR's chronic oral MRL. However, it is unlikely that this exposure will cause noncancerous adverse health effects because the MRL is set 1000 times below the level at which PCBs cause adverse health effects in animals. For workers exposed to PCBs in surface soil for 8 hrs/day for 5 dayslweek for 32 years, the estimated increased risk for cancer is moderate (Appendix C). WEL Sediment Sediment quality of the WEL and the surrounding property was limited to the drainage ditch that flows around the western edge of the WEL and north toward Norfolk Southern Railroad. Hereaftzr, we will refer to this ditch as the west drainage ditch (WDD). PCB samples were taken from eight locations downgradient of the landfill and a background sample was taken in the ditch just north of the landfill (Figure 8). These sample locations were composited and analyzed for the USEPA Appendix IX List of Constituents'. Table 1 contains the sediment sampling results for the WDD. For residents living near the WEL, an exposure duration of 68 years (19271995) for adults and 6 years for children was used to obtain the most conservative estimatz of risk. An exposure frequency of 104 days per year was used because of proximity to the landfill and the likelihood of visiting the landfill twice a week. For residents living near the WEL, the estimated child and adult doses for PCBs in sediment is greater than ATSDR's chronic oral 10 . ? However, it is unlikely that exposure to contaminated sediments in the WDD will cause noncancerous adverse hc3lch effects because the M U is set 1000 times below the level at which PCBs cause adverse health effects in animals. For adult residents exposed to PCBs in sediment in the WDD, the increased risk for cancer is estimated to be low (Appendix C). For children who were exposed to PCBs in the WDD, the increased risk for cancer is estimated to be very low (Appendix C) For workers who worked in and around the WEL, the estimated exposure to PCBs in sediment is greater than ATSDR's chronic oral MRL. However, it is unlikely that exposure to contaminated sediments in the WDD will cause noncancerous adverse health effects because the MRL is set 1000 times below the level at which PCBs cause adverse health effects in animals. For cancerous adverse health effects, workers that were exposed to PCBs in sediment have an estimated increased risk for cancer that is very low (Appendix C). WEL Groundwater Groundwater quality of the WEL and the surrounding property focused only on the WEL. Four downgradient monitcring wells were installed around the WEL (Figure 8). The wells range in depth from approximately 31 - 47 feet. A background sample was taken from an existing monitoring well that is used as a background sample for the SWMUs'. Table 1 contains the groundwater . sampling results for the WEL. Although residents in the area are currently using municipal water, the municipal water supply (Coldwater Springs) is located approximately two and one-half miles southwest of the facility. In a 1987 report, the U.S.Geological Survey delineated the area surrounding the Monsanto and Coldwater Sprin,0s as an area that was highly susceptible to contamination"'. The report states that the Jacksonville Fault, which is located less than 1 mile northwest of Monsanto, has a significant effect on the storage and movement of groundwater. The fault acts as a conduit along which groundwater reaches the surface. The Coldwater Springs aquifer system is reported to have a recharge area that is not large enough to sustain the discharge of Coldwater Springs". A large amount of recharge is thought to move parallel to the Jacksonville Fault to Coldwater Springs from the Anniston-Fort McClellan area, and some recharge may orisinate from the Jacksonville area? In 1992, a dye tracing study was 11 f T ' - T - performed on area springs and wells by Ewers Water Consultants, Inc., for the AMiStOn Army Depot (Anniston Army Depot is located approximately 4 miles west of the Monsanto facility)''. The results of the study showed that contaminants migrated from the injection point to various locations 360" from that point, and that flow velocities varied from 0.09 to 0.24 miles per day. PCBs have been found in sediments downstream of the Coldwater Springs intake", and no off-site source of contamination is known in that area. One possibility is that contaminants have migrated through groundwater to Coldwater Springs. However, the municipal water supply has not been sampled for PCBs. Therefore, the groundwater pathway will not be evaluated at this time. WEL Waste Material Any tar-like waste material found on the surface of the WEL and the surrounding property was collxted and analyzed as a composite sample'. Although only one sample has been collected, personal communication with the environmental firm that performed the sampling, revealed that numerous samples were collected? Therefore, the waste material will be analyzed as a pathway. The results are listed in Table 1 for the WEL. For residents living near the WEL, we used an exposure duration of 68 years (1927-1995) for adults and 6 years for chiIdren to obtain the most conservative estimate of risk. We used an exposure frequency of 26 days per year because the residences were not likely to come in contact with the waste material during each visit to the landfill. For residents who lived around the WEL, the estimated child and adult doses for PCBs in waste material are greater than ATSDR's chronic oral MRL. However, it is unlikely that exposure to contaminated waste material in and around the W E L will cause noncancerous adverse health effects because the MRL is set 1000 times below the level at which PCBs cause adverse health effects in animals. For adult residents exposed to PCBs in waste material in and around the WEL, the increased risk for cancer is estimated to be moderate (Appendix C). For children who were exposed to PCBs in and around the WEL, the increased risk for cancer is estimated to be moderate (Appendix C) 12 s d For workers who worked in and around the WEL, the estimated exposure to PCBs in waste material is greater than ATSDR's chronic oral MRL. However, it is unlikely that exposure to contaminated waste material in and around the WEL will cause noncancerous adverse health effects because the MRL is set 1000 times below the level at which PCBs cause adverse health effects in animals. For cancerous adverse health effects, workers that were exposeh to PCBs in waste material in and around the W E L have an estimated increased risk for cancer that is moderate (Appendix C). Data Gaps for the WEL Several data gaps need to be fiIled in order to correctly assess the WEL: Eight composite surface soil samples does not adequately describe the WEL and the adjacent areas. A composite sample is composed of a mixture of sampIes collected at different locations, and gives average contaminant cor,centration values. For this reason, additional surface samples are needed to delineate areas where contaminants concentrations are high. Surface soil samples were not taken from the adjacent residences and school. Sampling is needed in these areas to insure that no contaminated soil migated beyond the fence line or has been removed by the residents or APCO from the site. Given the history of the facility and landfill, analysis of shallow soil at the WEL and the surrounding residences for metals, pesticides, volatile organic compounds (VOC), and semivolatile organic compounds (SVOC)is appropriate. A composite sample of sediment was tested for pesticides, metals, SVOCs, and VOCs. However, the detection limit for many'of the compounds was above ATSDR comparison values and could not be evaluated at this time. A composite sediment sample does not reveal actual VOC concentrations because mixing of the sediments would have allowed volatilization of the compounds. 13 m Groundwater monitoring wells were only located around the WEL. However, in order to assess the groundwater accurately, the entire area that .is contaminated QVEL and AA) nseds wells surrounding and within it. = Analysis of samples from the municipal water supply for PCBs is needed. B Adequate background samples are needed to characterize surface soils. Quality Assurance/ Oualitv Control All data within the Anniston West End Landfill Report is accepted as valid. However, several inaccuracies have been noted in the report. Sample FL-2A in Table 9-2 of the Anniston West End Landfill Site Investigation Report lists PCB-1248 as 2.9 ppm, yet a rwiew of the analytical reports from Savannah Laboratories shows that the concentration PCB-1248 in sample FL-2A should be 29 ppm. Sample FL-7A in Table 9-2 of the Anniston West End Landfill Site Investigation Report lists PCB-1260 as < 1 ppm, yet a review of the analytical reports from Savannah Laboratories shows that the concentration PCB-1260 in sample FL-7A should be 2.9 ppm. PCB data in the Anniston West End Landfill Site Investigation Reporr should be used with caution. A review of the laboratory data shows that the total PCB concentration may be higher than reported because the detection limit for many of the congeners is much greater than the comparison value. Many contaminants reported for sediment and water also have a detection limit that is higher than the comparison value. Surface soil taken from the W E L and the surrounding property should be used with caution. It is likely that some of these samples do not represent actual site conditions because clean fill may have been placed over them by erosion or during temporary capping. Many of the samples were taken from a depth of 01 inches and contained gravel, debris and roots. Also, some samples were reported to be surface soil, yet no depth was given. 13 c .. East Drainage Ditch EDD Soil The quaIity of soil around the EDD and the surrounding property (Clydesdale community) was recently assessed by Geraghty and Miller, Inc., for the Monsanto Company. Approximately 340 surface soiI samples were field screened for PCBs greater than or equal to 10 parts per miIlion (Figure 9). Approximately ten percent of the field screened samples were submitted to a laboratory for confirmatory analysis of PCBs. Most surface soiI samples were taken from each side of the EDD in 25 feet increments, yet a few areas surrounding the ditch were sampled in 5 feet increments. Samples were also taken along the waste water discharge ditch". The sampling results show that contamination is more widespread aIong the northern portion of the EDD. It is possible that the contamination becomes more widespread because of past cleanup methods for the EDD and Snow Creek. Surface soil sampling around the EDD also indicates that ther2 are multiple sources of contamination. See . Table 1 for the surface soi1 sampling results for the EDD. For residents who live in the Clydesdale Community, an exposure duration of 30 years was used for adults and 6 years for children to obtain the most conservative estimate of risk. An exposure duration of 30 years was used because multiple sources of contamination exist in the area, and each source has a different time constraint. An exposure frequency of 365 days per year was used because many of samples were taktn in close proximity to the residences, and it is likely that residents visited these areas daily. For residents who lived in the Clydesdale Community, the estimated child and adult doses for PCBs in surface soil is greater than ATSDR's chronic oral MU. However, it is unlikely that exposure to contaminated soils in the Clydesdale Community will cause noncancerous adverse health effects because the MRL is set 1000 times below the level at which PCBs cause adverse health effects in animals. For adult residents exposed to PCBs found in the Clydesdale Community, the increased risk for cancer is estimated to be low (Appendix C). For children who were exposed to PCBs found in the Clydesdale Community, the increased risk for cancer is also estimated to be low (Appendix C). 15 EDD Sediment Sediment quality of the EDD \\.as limited to the drainage ditch that flows through the Clydesdale Community and the waste discharge ditch that empties into it. Samples were taken from 66 locations downgradient of the SWMUs, and field screened for PCBs greater than or equal to 10 ppm by the Draft USEPA Method 4020 (Figure 9). However, onIy 16 samples were sent to the Iaboratory for a complete analysis". The results of the sampling shows that the southern portion of the EDD contains higher PCB concentrations. Table 1 contains the sediment sampIing results for the WDD. For residents who live around the EDD and the waste water discharge ditch, we used an exposure duration of 30 years fcr adults and 6 years for children to obtain the most conservative estimate of risk. We used an exposure frequency of 52 days per year because the residents were likely to visit the drainage ditch once a week. For persons that lived around the EDD and the waste water discharge, the estimated child bnd adult doses for PCBs in surface soil is a Oreater than ATSDR's chronic oral MRL. However, it is unlikely that exposure to contaminated sediments in the EDD and the waste water discharze ditch will cause noncancerous adverse health effects because the MRL is set 1000 times below the level at which PCBs cause adverse health effects in animals. For adult residents exposed to PCBs in sediment in the EDD and the waste water discharge ditch, the increased risk for cancer is estimated to be high (Appendix C). For childrtn who were exposed to PCBs in sediment in the EDD and the waste water discharge ditch, the increased risk for cancer is estimated to be moderate (Appendix C). Data Gaps for the EDD Several data gaps need to be filkd in order to correctly assess the EDD: 8 r. 8 Adequate background samples are needed from areas not influenced by activities from the Monsanto Company. 1 Many soil and sediment samples.taken near the EDD and the wastz water discharge ditch wer? only reported as greater than or less than ten parts per million. Actual concentrations are necessary to delineate areas with hish concentrations and to accurately assess the 16 human health impacts. Surface soil samples were not taken from the yards of the residences adjacent to the EDD. Samples from these residences are needed to insure that no contaminated sediment has migrated onto these properties. Groundwater in the area of the EDD and the Clydesdale community has not been monitored for PCBs. Given the history of the facility and landfills, analysis for metals and pesticides is appropriate for surface soil and sediment samples from areas surrounding the EDD. Given the history of the facility and landfills, surface water analysis for PCBs, pesticides and metals is appropriate. \ Ouality Assurance/ Oualitv Control Data in the East Drainage Ditch Report should be used with caution. A review of the laboratory data shows that the total PCB concentration may be higher than reported because the detection limit is much greater than the comparison value. Northern Drainage Ditch NDD Sediment Sediment quality of the NDD was recently assessed by Geraghty and Miller, Inc., for the Monsanto Company. Sediment samples were taken from eight locations along the NDD and analyzed only for PCBs (Figure 3)". The sampling results indicate that PCBs have migrated off-site. Table .1 contains the sediment sampling results for the NDD. For residents who live around the NDD, an exposure duration of 30 years was used for adults and 6 years for children to obtain the most conservative estimate of risk. We used an exposure frequency of 52 days per year because the residents were likely visit the drainage ditch once a week. For persons that lived around the NDD, the estimated child and adult doses for PCBs in surface 17 soil is lower than ATSDR's chronic orarh.IRL. Therefore, PCBs in sediment in the NDD are unlikely to cause noncancerous adverse health effects in adults and children. For adult residents exposed to PCBs in sediment in the NDD, the increased risk for cancer is estimated to be insignificant (Appendix C). For children who were exposed to PCBs in sediment in the NDD, the increased risk for cancer is estimated to be insignificant (Appendix C). Data Gam for the NDD: Several data gaps need to be filled in order to correctIy assess the NDD: rn Given the history of the facility and landfills, metals and pesticides should be tested in the NDD. rn Surface soil samples shouId be taken around the NDD to insure that contamination has not migrated beyond the ditch. Ouality Assurance1 Oualitv Control All data in the'Off-Site Sediment Samplinz Report and the Choccolocco Creek Watershed Study are assumed to bz valid. However, some caution should be used with the PCB data in the Off-Site Sediment Sampling Report. A review of the laboratory data shows that the total PCB concentration may be higher than reported because the detection limit is much greater than the comparison value for some congers. Snow Creek Snow Creek Sediment Sediment quality of Snow Creek was first assessed by AGO in 1985, and later that year by ADEM and Monsanto. ADEM also assessed the sediment quality in Snow Creek in 1993''. In April 1995, Geraghty and Miller, Inc. sampled Snow Creek to delineatz the extent of off-site contaminationls. Because the number of samples taken in the 1995 study is limited, samples taken during ADEMs 1993 study will be used to fill data gaps where samples were not taken. In areas where samples from 1993 and 1995 were taken, samples from thz 1995 study will be used to give present day conditions. 18 , ' Table 1 contains the sediment sampling results for Snow Creek. Samples were taken from three locations upstream of thexonfluence of Snow Creek and the NDD, and from several locations downstream until the confluence of Snow Creek and Choccolocco Creek. The sampling results suggest that another source of PCBs exist in the area, or that contamination has migrated into the western tributary of Snow Creek via the western portion of the NDD. For residents who live around Snow Creek, we used an exposure duration of 30 years for adults and 6 years for children to obtain the most conservative estimate of risk. We used an exposure frequency of 52 days per year because the residents were likely to visit the creek once a week. For persons living around Snow Creek, the estimated child and adult doses for PCBs in sediment is lower than ATSDR's chronic oral MRL. Therefore, PCBs in sediments in Snow Creek are unlikely to cause noncancerous adverse health effects in adults and chiIdren. For adult residents exposed to PCBs in sediment in Snow Creek, the increased risk for cancer is estimated to be low (Appendix C). For children exposed to PCBs in sediment in Snow Creek, the increased risk for cancer is estimated to be low (Appendix C). Data Gaps for Snow Creek Several data gaps need to be filled in order to correctly assess Snow Creek: Surface soil samples were not reported for the banks of Snow Creek. Sampling of these areas is necessary to insure that no contaminated sediment has been placed in these areas by past cleanup practices. m Monitoring of surface water in Snow Creek for PCBs,metals and pesticides is needed. Given the history of the facility and landfills, analysis of sediment from Snow Creek for metals and pesticides and analysis of surface soil for metals and pesticides in areas where past cleanup occurred is needed. 1 Information on levels of PCBs in fish from Snow Creek is needed. 19 Oualitv Assurance/Oualitv Control All d3ta in the Off-Site Sediment Sampling Report and the Choccolocco Creek Jyatershed Study are assumed to be valid. However, some caution should be used with the PCB data in the Off-Site Sediment Sampling Report. A review of the laboratory data shows that the total PCB concentration may be higher than reported because .the detection limit is much greater than the comparison value for some congeners. Choccolocco Creek Choccolocco Sediment Sediment quality in the Choccolocco Creek Watershed was assessed by ADEM in 1993". -Several samples were taken in upstream and downstream tributaries of Choccolocco Creek. However, only one sample was taken in ChoccoIocco Creek upstream of the confluence with Snow Creek. Likewise, only one sample was taken in Choccolocco Creek downstream of the confluence with Snow Creek. The results of the sampling shows that there are other sources of PCB contamination which have not been discovered. However, sediment quality in Choccolocco Creek cannot be asstssed at this time because there is an insufficient amount of samples. Choccol occo Fish Fish quality in the Choccolocco Creek was assessed by combining past investigations of Choccolocco Creek7.I 1.19-33 . Samples were taken from various locations downstream of the confluence of Snow Creek to the confluence with the Coosa River. The samples were analyzed as composite wholz body samples for a variety of contaminants. The sampling results indicate that fish in Choccolocco Creek and the Coosa River have PCB concentrations that are above the Food and Drug Administration recommended allowance. Table 1 contains the fish sampling results for Choccolocco Creek. For residents livinz around Choccolocco Creek, an exposure duration of 30 years for adults and 6 years for children was used to obtain the most conservative estimate of risk. Adults were assumed to eat 30 mg/day of fish taken from Chocco.locco Creek, while children were assumed to eat 10 mg/day. For persons that ate fish from Choccolocco Creek, the estimated child and adult doses for PCBs in sediment is lower than ATSDR's chronic oral MRL. t 20 .. Therefore, PCBs in sediment in Snow Creek are unlikely to cause noncancerous adverse health effects in adults and children. For adult residents exposed to PCBs in fish in.the Choccolocco Creek, the increased risk for cancer is estimated to be high (Appendix C). For children who were exposed to PCBs in fish in the ChoccoIocco Creek, the increased risk for cancer is estimated to be moderate (Appendix C). Data G a y for Choccolocco Creek: Several data gaps need to be filled in order to correctly assess Choccolocco Creek: More samples are needed to adequately assess sediment in Choccolocco Creek. Analysis of surface water samples from Choccolocco Creek for 1 PCBs is needed. 5 Oualitv Assurance/Oualitv Control AI1 data in the Choccolocco Creek Watershed Study are assumed to be valid. CONCLUSIONS 1. After reviewing the data, we have classified the WEL, EDD, Snow Creek, and Choccolocco Creek as a public health hazard. The classification is based on evidence that individuals living around the WEL, EDD, Snow Creek, and fishing from Choccolocco Creek could have adverse health effects from exposure to contaminants in sediment, soil, fish, and water. 2. Exposure to PCBs in surface soil at the WEL may lead to a moderate increased risk for cancer in aduIts and a low increased risk for cancer in children. 3. Exposure to PCBs in sediment at the WEL may lead to a low risk for cancer in adults and a very low increased risk for cancer in children. I t 21 4. Exposure to PCBs in groundwater at the WEL may cause noncancerous adverse health effects. Exposure to PCBs in groundwater may lead to a very high risk for cancer in adults and a high increased risk for cancer in children. 5. Exposure to PCBs in surface soil around the EDD and the waste water discharge ditch may lead to a low increased risk for cancer in adults and a low increased risk for cancer in children. 6. Exposure to PCBs in sediment in the EDD and the waste water discharge ditch may lead to a high increased risk for cancer in adults and a moderate increased risk for cancer in children. 7. The increased risk for cancer from exposure to PCBs in sediment in the NDD is insignificant in adults and children. 8. Exposure to PCBs in sediment in Snow Creek may lead to a low increased risk for cancer in adults and a low increased risk for cancer in children. 9. Exposure to PCBs in fish in Choccolocco Creek may lead to a high increased risk for cancer in adults and a moderate increased risk for cancer in chiIdren. 1. Perform an exposure investigation to determine the impact of offsite contamination on area residents. 2. Conduct additional surface soil sampling and analyses to delineate areas where contaminant concentrations are high. 3. Conduct additional surface soil sampling and analyses from the residences and school adjacent to the WEL. The sampling would allow us to determine if contaminated soil from the site has migrated beyond the fence line or has been removed by the residents or APCO. 22 4. Conduct additional sampling and analyses of shallow soil at the WEL and the surrounding residences for metals, pesticides, volatile organic compounds WOC), and semivolatile organic compounds (SVOC). 5. Test individual sediment samples for pesticides, metals, SVOCs, and VOCs. In addition, lower the detection limit for many of the compounds. 6. Do not use composite sediment samples to determine VOC concentrations. 7. Groundwater monitoring wells were only located around the WEL. However, to accurately assess groundwater, the entire area that is contaminated (WEL and AA) needs wells surrounding and within it. 8. Take adequate background samples to characterized surface soils and sediment. 9. Surface soil samples were not taken from the yards of the residences adjacent to the EDD. These residences should be sampled to insure that no contaminated sediment has migrated onto these properties. 10. Monitor groundwater in the area of the EDD and the Clydesdale community for PCBs. 11. Test surface soil and sediment surrounding the EDD for metals and pesticides. 12. Test surface water from EDD for PCBs, pesticides and metals. 13. Test sediment in the NDD for metals and pesticides. 14. Take surface soil samples around the NDD to insure that contamination has not migrated beyond the ditch. , 23 -- . 15. Surface soil sampIes were not reported for the banks of Snow Creek. Sample these areas to insure that no contaminated sediment has been pIaced on the banks by past clean-up practices. 16. Monitor surface water in Snow Creek for PCBs, metals and pesticides. 17. Test sediment from Snow Creek for metals and pesticides. 18. Sample fish in Snow Creek for PCBs. 19. Take more sediment samples from Choccolocco Creek to better assess it. 20. Take PCB samples from the Coldwater Springs Municipal Water Supply during different times of the year to insure that PCBs have . not migrated into the mu3icipal water supply. 24 HEALTH ACTIVITIES RECOMMENDATION PANNEL STATEMENT The data and information developed in the health consultation of the Monsanto Company site has been evaluated by the ATSDR Health Activities Recommendation Panel (HARP) for the follow-up activities. Members of the HARP panel concurred with the designation of Public Health Hazard because residents are being exposed to high IeveIs of Contamination which may cause adverse health effects over a long time period. The panel made the following recommendation for the Monsanto site: Community health education should be provided to the potentially exposed populations on the health effzcts possibIe from exposures to PCBs from the Monsanto site. PUBLIC HEALTH ACTION PLAN The following Public Health Action Plan (PHAP) for the Monsanto site contains a description of actions to be taken by ADPH and/or ATSDR at and in the vicinity of the site subsequent to the completion of the health consultation. The purpose of the PHAP is to ensure that the health consultation not only identifies public health hazards, but provides a plan of action designed to mitigate and prevent adverse health effzcts resulting from exposure to hazardous substances in the environment. The following public health actions will be implemented by ADPH and/or ATSDR:' 1. ADPH, in cooperation with ATSDR, will evaluate the feasibility of a community education program designed to acquaint the community with the possible health effects caused by being exposed to contaminants from the Monsanto site. I 25 -, ____ . T r--' -' 'T " References 1. Geraghty.and Miller, Inc. Anniston West End Landfill, Site Investisation, Monsanto Company, Anniston, Alabama. August 1, 1994. 2. Monsanto Company. RCRA Part-B Post-Closure Permit Application, Monsanto Company, Anniston, Alabama. December 1994. 3. Alabama Power Company. Fact Sheet on the Discovery of Contamination at the Anniston Transmission Substation. April 23, 1993. 4. Jones, Robert. Letter to Sue Robertson (ADEM) on reacquisition of the West End Landfill. January 31, 1995. 5. United Statzs Environmental Protection Azency. Remedial Feasibility Assessment. August 199 1. 6. Personal communication with Robert Jones during the April 1995 site visit. April 1995. 7. AIabama Department of Conservation and Natural Resources. Letter to Ms.Janice Gilliland (ADPH)concerning past fish sampling data for Choccolocco Creek. January 1993. 8. Alabama Attorney General Office. Letter to Joe Broadwater, Director of ADEM, on Snow C x e k sediment samplin,o results. February 26, 1985. 9. Monsanto Company, Dayton Laboratory. Report No. MDA7636, Analyses for PCB's in soil samples. July 1985. 10. Brown, Jerry. Letter to James Moore (ADEM) outlining the Snow Creek Sediment Removal Protocol. May 15, 1986. 11. Alabama Department of Environmental Management. ChoccoIocco Creek Watershed Fish Tissue and Sediment Analyses. January 1994. 12. Alabama Department of Environmental Management. ADEMNews Press Release, Choccolocco Fish Study Yields Elevated Levels of PCBs. 26 - November 2, 1993. 13. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Selected PCB’s. April 1993. 14. United States Geological Survey. Geohydrology and Susceptibility of Coldwater Spring and Jacksonville Fault Areas to Surface Contamination in Calhoun County, Alabama. 1987. 15. Ewers Water Consultants, Inc. Draft Final Groundwater Tracing Studies, Anniston Army Depot, Anniston, Alabama. February 7, 1994. 16. Telephone communication with Ms. Leslie Herd of Geraghty and Miller, Inc., Project Manager for the Monsanto Site. August 1995. 17. Geraghty and Miller, Inc. Soil Samplin,o Results for Area A, Monsanto Company, h n i s t o n , Ahbama. June 1995. 18. Gerazhty and Miller, Inc. Field Report, Off-Site Sediment Sampling, Monsanto Company, Anniston, Alabama. July 1995. 19. Alabama Department of Conservation. Letter to Sam Spencer @ept of Conservation, Fisheries Section) concerning fish collection iogs. May 24, 1971. 20. Alabama Department of Conservation. Letter to Sam Spencer @ept of Conservation, 45Fisheries Section) concerning pesticide analyses of fish. April 1973. 2 1. Alabama Department of Conservation. Letter to Dan Catchings @ept of Conservation, Fisheries Section) concerning fish samples analyzed for PCBs. April 1976. 22. Alabama Department of Conservation. Letter to James W. Cooper (ADPH) containing fish analysis. from various locations in North Alabama. October 21, 1986. 23. Alabama Department of Environmental Management. Letter to Brian J. 27 Hughes (ADPH)concerning fish tissue data analyses from Choccolocco Creek. March 1995. 24. Fishery Information Management Systems and Auburn University, Department of Fisheries and Allied Aquacultures. Estimation of Daily Per Capita Freshwater Fish Consumption of Alabama Anglers. 1995. 9 . 1 I 28 Appendix A Figures . a c 29 Figure 1. Regional Location Map for the Monsanto Company site. ANNISTON. ALABAMA r i '1 , # 30 Figure 2. Area Location Map showing Snow Creek and the East Drainage Ditch. 31 - - 4- ---AiT--’ ! z.+.cn _... 3 -I b3’’~I --- * . .. T e . . - - a v) t c 35 CALHOUH COUUTY SECTION 12 WH-16-5. RUG-07-E K-12 acnooi \o - FlmAvanue Figure 6. Site Location M a p for the )Vest-End landfill. 35 I ' \ I 36 \ Q for the West End Landfill. 37 m m m =.1'...... .. a:*\ .,........ .. * . ,..+ ... .* ,. .-... . .. .. *..... :ii: .*-..:.---.. -.=='-..-' :: --.-*a;. . :e= I . I . '.:.:I, a. 1.2 a. .*.I -. .: :: Figure 9. Locution of sediment and surface soil samples in the Clydesdale Community. a. 38 -. ... . _"_ Appendix B Tables d , I 39 I - L .- 2- .-u = e cv In I s I - .-. Appendix C Evaluation of Health Risks 41 PROCEDURE FOR EVALUATING POTENTIAL MEALTH RISKS FOR CONTAMINANTS OF CONCERN The Alabama Department of Public Health, Risk Assessment Branch, uses the following classifications to evaluate the potential cancer risks associated with contaminants of concern at the Monsanto Company site. Increased cancer risks were estimated by using site-specific information on exposure leveIs for the contaminants of concern and interpreting them using cancer potency estimates derived for those contaminants by the USEPA. This qualitative ranking of cancer risk estimates is used to rank the risk from insignificant to very high. Excess Lifetime Cancer Risk Risk RatiQ Oualitative Describtor Ione per million insignificant risk \ one per hundred thousand very low risk one per ten thousand low risk one per thousand moderate increased risk one per hundred high increased risk 2 one per ten very high increased risk An increase in cancer risk is not a specific number of expected cancers. It is a conservative *estimate of the probability that addition cancers may develop within a population following long-term exposure to that contaminant. The exact knowledge of cancer mechanisms is insufficient to decide if persons can be exposed to low levels of cancer-causing agents without increasing the risk of cancer. Therefore, even an extremely small exposure to a cancer-causing compound is assumed to be associated.with an increased risk. 4 CERTIFICATION This Health Consultation was prepared by the AIabama Department of Public Health under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the Health Consultation was initiated. r, SPS, S S A B , DHAC The Division of Health Assessment and Consultation, ATSDR, has reviewed this HeaIth Consultation and concurs with its findings. Chief, SSAl3, DHAC, ATSDR- 43 -. -. , . ___. f "7- - - ' '-I-- ' - '
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