DEPARTMENT OF HEALTr ̂ HUMAN SERVICES Public Health ServiceCenters for Disease Control

MemorandumDate . April 11, 1983

From Chief, Superfund Implementation Group, CEH

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Subject Vertac Hazardous Waste SiteJacksonville, Arkansas

To George BuynoskiPublic Health AdvisorEPA Region VI

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At your request, the data you submitted on the above site was reviewed bya committee of the Center for Environmental Health, Centers for DiseaseControl. I hope that you find the comments useful.

Summary of Conclusions

A. Significant amounts of dioxin and other hazardous substances have beenfound to be leaving the site by surface water and air transport.Measures need to be taken to eliminate these 'releases from the site toprevent further environmental degradation. Most of the data on dioxinconcentrations was gathered in 19 7 9 , or was presented withoutinformation on the quality control methods used. Since themeasurement of dioxin is extremely difficult at the low levelsinvolved, and since laboratory techniques for its measurement haveimproved since 1979, consideration shduld be given to re-samplingoff-site areas using improved sampling and analytic methods. Otheralledged sites of dumping should be thoroughly investigated to ruleout more.widespread contamination.

B. Surface water transport of dioxin and other hazardous substances fromthe site has caused contamination of bottom sediments in downstreamareas. These substances are a continuing source of contamination tothe food-chain and edible fish in downstream waters. Sampling of fishhas revealed dioxin levels in fish as high as 800 ppt, but averagelevels in the edible portions of fish are not known. Since this doesnot allow specific evaluation, and since it is reported that fishingis continuing despite the official ban, additional testing of theedible portions of several different Species of fish, including bottomfeeding and predatory fish would help clarify whether this is asignificant threat to public health. I In addition, data on fishconsumption among local fishermen and their families would benecessary to estimate exposure.

C. The use of downstream surface waters for water supply purposes is notdiscussed. Is there reason to believe that contaminated sediment fromthe plant could have contaminated agricultural land downstream duringperiods of flooding? Farm animals eat significant amounts of dirt, sothis could present a possible food chain hazard to humans.

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D. The extent to which leaching from the disposal areas and surface watertransport to recharge areas has contaminated ground water resourceshas not been evaluated or discussed in the data presented. While fiveof the City of Jacksonville's drinking water wells have been testedfor dioxin and none was detected (detection limits were 25 ppt orless), the absence of other hazardous contaminants in these publicwells was not documented.

E. The levels of TCDD found in soils of adjacent residences need to bereviewed (see A above). Levels in the 100 ppt range or less mayrepresent background levels. If leveljs of more than 1 ppb were foundin additional sampling, a detailed assessment of the habitability ofthe nearby housing might become necessary.

F. There have reportedly been complaints by some Jacksonville cityresidents of health effects from the Vertac site. In addition therehave been complaints of bad odors in the area. These would bedifficult to evaluate for the following reasons:

1. Odor threshholds for some of the chemicals present (chlorinatedphenols in particular) are extremely low. A major study of odorproblems resulting from a California toxic waste dump has shownthat some people may be sensitive to the presence of bad odors andmay develop nausea, headaches and ether symptoms ( 5 ) . Howeverthese odor-related symptoms are unrelated to more serious short orlong term toxic effects of the chlorophenols, and are unrelated toexposure to dioxin.2. There is presently no easy method for measuring dioxin levels inhuman tissue.3. The average level in residential soils based on the dataavailable is in the 100 ppt range (essentially a background level),which would not be expected to hav^ any adverse consequences.Since two samples showed higher levels, laboratory quality controlmeasures should be reviewed and additional sampling may benecessary.

G. All analytical data that has been generated, to date, needs to becarefully consolidated. This includes, detailed sampling information,analytical method descriptions, and ai]iy quality control data chat maybe used to statistically define the characteristics of the analyticaldata. Once consolidated a more detailed review of this data may bepossible.

H. Since one study of health effects among self-selected nearby residentswas essentially negative, another survey of health effects among aless exposed population would probably not be justified. A healtheffects study might be justifiable if it were possible to identifyanother high risk group and document their exposure. In thissituation, the next highest risk group would probably be those peoplewho eat large amounts of locally caught fish. If testing of theedible portions of fish confirms high dioxin levels, and if data onfish consumption showed a population group with a high intake ofcontaminated fish, a study might be feasible.

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Laboratory/Analytical Issues

The identity of the laboratory performing the analysis was not given in most cases. However, it appears that several laboratories have been involved in the analyses of the various blocks of samples taken from the Vertac facility and surrounding areas during 1979 to 1982. Laboratories that were named include: Brehm Laboratory at Wright State University, HNB Laboratory in Houston, Texas, NASA/NSTL Laboratory in Bay St.Louis, Mississippi and the ADPC & E Laboratory in Arkansas. Only the method used by the Brehm Laboratory for the analysis of industrial samples for TCDD is given in any detail. No quality control information or data are given with any of the analytical results. No statements concerning the validity of the analytical results can be made.

As for the Brehm Laboratory method, the efficiency of the extraction technique is greatly dependent on the type of material and the length of time the toxicant has been in contact with the material. Subsets of each sample types should have been extracted using the Soxhlet technique to check for adequate extraction of the unknown TCDD.

In the report from the Brehm Laboratory, it is indicated that the "effectiveness of the analytical methodology" was good because analysis of three spiked samples, blindly introduced into the laboratory, gave "good agreement" between the level spiked and the quantity found. The one time analysis of three samples, of unknown type, does n~t define the effectiveness of an analytical system. The report also indicates "good results for most of the samples" were obtained because "good recoveries of the labeled TCDD spike were obtained." Recovery information is only one part of the data file necessary to define the analytical system. It is not a total quality control system. A complete, carefully designed quality control program must be an integral part of any future studies of the dioxin problems in Jacksonville.

Background

Existing and previous owners of the Vertac faility have contributed to the on-site disposal of hazardous wastes including dioxin; 2,4-D; 2,4,5-T; 2,4,5-TP; phenol; and chlorinated phenols. Reasor Hill owned the site from 1948 to 1962 and landfilled their wastes on 13 acres adjacent to Rocky Branch Creek. Dioxin-contaminated 2,4,5-T may have been landfilled during the last few years of their ownership. Hercules, owning the site from 1962 to October, 1971, disposed of their wastes in another 10-acre landfill to the north. After 1971, Transvaal constructed a 10-acre landfill in the same area as the Hercules landfill. Dioxin-contaminated wastes were disposed of in these landfill areas. Maps submitted for evaluation show additional Vertac lanafills. Some landfills were placed on top of older landfills.

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While information is limited, it is stated that no product currently beingproduced at the plant would lead to production of dioxin contaminated wastes.Trichlorophenol synthesis, a process which produces relatively large amountsof dioxin, was done at this site. Wastes from this process have beendisposed of in several ways. They have been transported to two commercialwaste sites outside of Arkansas: the Browning and Ferris Landfill,Louisiana, and to Kansas Industrial Services, Wichita, Kansas; they have beenburied or stored above ground in drums at the site itself; and there areallegations that drums were buried in other locations outside of Vertac'spresent boundaries.

There was an explosion at the plant in 1974.

In 1 9 7 9 , Dr. Marian Moses of the Mount Sinai Medical School's EnvironmentalSciences Unit conducted a health study of about 200 people, including about80 current employees, some former employees and some environmentally-exposed,self-selected individuals. The interviews and physical examinations ofemployees indicated that a number of them had experienced episodes ofchloracne as a result of the 1974 explosion. Final results of the healthsurvey have not been published. In a telephone conversation. Dr. Moses saidchat the only positive finding of the study was a slight decrease in suralnerve conduction velocity among some heavily exposed individuals(employees). The clinical significance of this finding is not wellunderstood. Testing by the EPA in 1979 revealed high level dioxin residuesat the plant and led to its being listed as a Superfund site. It was statedthat 152 of about 3,000 barrels in the drum storage area were leaking at anyone time. Further testing revealed high levels of dioxin in fish downstreamfrom the VERTAC site, and the state subsequently prohibited fishing in LakeDupree, Bayou Hetou, and Rocky Branch Creek.

There have been many complaints about objectionable odors that periodicallyaffect some areas of the city. There has been considerable publiccontroversy and debate about the site, and about the need for a health studyof nearby residents, some of whom have reportedly claimed that toxic wastesare responsible for their illnesses. The site is presently involved inlitigation concerning clean-up of the wastes.

Discussion

Dioxin: ICDD is one of the most toxic man-made chemicals in ourenvironment. Its' animal toxicity has been studied and reviewed in numerouspublications. Data on human toxicity are much more limited. The most commoneffect of acute exposure is chloracne. This is a characteristic form of acnewhich has a different distribution than the usual adolescent form. Dioxinmay also affect hepatic metabolism, producing a form of a disease known asporphyria cutanea tarda. Possible chronic effects of dioxin in man have notyet been well documented. Some researchers have suggested that a number ofcases of soft tissue sarcoma in Sweden among foresters may have been due todioxin-contaminated 2,4,5-1 ( 1 ) . In the United States, NIOSH (NationalInstitute for Occupational Safety and Health) investigators pooled data fromfour studies of heavily exposed workers and found three cases of soft tissuesarcoma among 22 cancer deaths, significantly more than expected ( 2 ) .

Page 5 - George BuynoskiAverage dioxin levels found on site were as high as 111 ppm in the bottomof the toluene still (document C: page 16, EPA sample ̂ DDM-18); 14 ppmin sediment affected by spills from barrels in storage areas (sample ̂DDM-6, page 14); 22.4 ppb and 102 ppb in cooling pond sediment (samples #DDM 15 and 124, pages 15 and 22 respectively); 667 ppb in the sump belowthe equalization basin (DCM-19); 374 ppb in equalization basin bottom mud(sample <t DDM-20); and 3.42 ppb in soil below a seep on Reaeor Hill (Apage 2 and K page 14). This soil and water data reveal the presence andtransport of dioxin in significant quantities. Where surface waterpathways leave the site area, water quality data revealed no detection ofdioxin in Rocky Branch Creek at the south edge of the property, in thecooling pond discharge, or in the east side drainage ditch at MarshallRoad. However, dioxin is found in the Rocky Branch sediments ( 2 . 3 6 to1.09 ppb) at the south end of the property. Based on this data, surfacewater transport is occurring from the site via the Rocky Branch Creek. Nosediment data is given for the east side drainage ditch from Vertac toRocky Branch which runs near a residential area. It should be rememberedthat since dioxin is most likely Co be adsorbed to fine soil particles andis highly insoluble, it may not be detected in surface water samples,particularly if such samples are only being tested for the dissolvedphase. Dioxin is likely to be transported (attached to soil particles)during high runoff periods or flood periods from all uncovered and/orunprotected contaminated areas. Downstream of the Vertac site,examination of EPA's bottom sediment data reveal di,oxin contaminationlevels as high as 1 . 6 ppb in sedments downstream of the Bayou Metouconfluence with Rocky Branch. From the data presented, sediments in RockyBranch from the site to Bayou Metou have been contaminated with dioxin,and sediments in Bayou Metou have been adversely affected as well. Lowlevels of dioxin, 36 ppt and 24 ppt, were found as far as 19 and 74 milesdownstream of Vertac respectively, but were not found at points 33, 45 and60 miles downstream from Vertac (ref A , pages 6 and 7 ) . The low levelsfound downstream in the less than 100 ppt range could well beenvironmental background levels.

Dioxin has also been found in local residential soil samples. The EPA andADPC&E data reveal that transport has occurred sometime in the past.EPA's 1980 data show lower levels of dioxin (ND to 0.085 ppb) than thatfound by the state (less than 0.004 to 4.2 ppb, F page 2 ) . Only one ofthe state's values was above 1.0 ppb. This could be a lab error. Even ifit is not, average values are well below 1.0 ppb based on the samplingdata available. In view of the public health implications associated withlevels exceeding 1.0 ppb, these data should be verified. In determiningthe pathway responsible for these levels, consideration needs to be givento whether these residential sampling stations or any sensitive land usesdownstream of the site may have been or may in the future be subjected Coflood waters carrying contaminants. Are any of the residential sitescomposed of landfill that may have been brought in from the creek or othercontaminated sources?

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Since TCDD was measured in particulates blowing across the site in 1979 bythe state at levels of 1.4 ppb ( F , page 1 ) , air transport of TCDD alsoappears to exist and shows a need to take onsite measures to preventinterim windborne erosion of site soils until a final decision has beenmade on remedial cleanup. Periodic monitoring of particulaces may beadvisable to determine the effectiveness of onsite remedial measures.

Phenols and Herbicides: With regard to the notes on the May 16-17, 1979Vertac sample summary ( J ) , phenol was given a "standard" value of 1.0 ppbin the 2nd paragraph. Note that this value is a water quality criterafrom EPA's Quality Criteria for Water, 1976; and it is not a drinkingwater standard, but a drinking water (welfare) criterion based upon odorproduction during the chlorination process. To protect the public healthfrom the toxic properties of phenol, the EPA has derived a water qualitycriterion value of 3.5 ppm in ambient water. To protect the publicwelfare and to control undesirable taste and odor qualities of ambientwater from phenols, the estimated water quality level is 0.3 ppm. Thislevel is based on organoleptic data (odor and taste thresholds) which has" . . . n o demonstrated relationship to potential adverse human healtheffects." (ref. 3 , page 79338 and 79339). The real phenol taste and odorproblem in drinking water comes not from the taste and odor of phenolitself but from the mono- and dichlorophenols produced during routinedisinfection of water supplies. These compounds have threshold odorvalues below 1 ppb and thus the early Public Health Service drinking waterguidance level for phenol was 1 ppb. Phenol taste and odor problems indrinking water can generally be solved by increasing the amount of freechlorine in the water. Examination of the summary ( J ) , revealssignificantly high concentrations of phenols, 2,4-D; 2,4,5-T; and 2,4,5-TPon the site with the capability of entering the local surface flow regimeduring runoff periods. While low levels of phenols (0.18 ppb) were foundin Rocky Branch, the high levels of phenol (22,400 ppb) as well as highlevels of 2,4-D (45,200 p p b ) , 2,4,5-T (42,400 ppb) and 2,4.5-TP (44,060ppb) found in the Reason Hill seepage may be of concern, since seepage maybe representative of ground water quality. The effect that thesecontaminants have had on the overall ground water quality should bedetermined. Additional water quality information could also provide abetter idea of the attenuation characteristics of the cooling pond duringlow flow conditions and the stored levels in the bottom sedimentsavailable for release during high flow periods. Sampling also revealed anumber of chlorinated^ phenols onsice and in the sewer line to theJacksonville Sewage Treatment Plant ( S T P ) . Chlorophenol, dichlorophenolisomers, and trichlorophenol isomers were all found onsice at highlevels. Total phenols in the sewer line to the STP were measured at 92.0ppm.Heavy Metals: While heavy metals are reported to have exceeded EPA'sNIDPDWR in samples onsite, levels in Rocky Branch at the south edge of theproperty have been found to be " . . . g e n e r a l l y below detection limits" ( J ,page 5 ) . A special hazard exists in the sump below the equalization basinsince this area may be subjected to flooding, and the levels are reportedCO be "quite high." In addition, " . . . t h e cooling pond showed relativelyhigh values of lead, zinc, and chromium..." ( A , page 17 - the levels werenot given). Lead and chromium were found in "relatively highconcentration" in the downstream sediments offsite as well.

Page 7 - George BuynoskiFish: Records of fish kills and taste and odor problems with fish inRocky Branch Creek and Bayou Metou date back as early as 1955. Theseproblems appear to have been caused by both the Jacksonville STP and bytoxic pollution problems caused by Reasor Hill and Hercules. Fish andmollusk data were presented ( D , page 1 ) , showing levels of TCDD as high as257 ppt in fish and 157 ppt in mollusks from Bayou Metou. Fish data fromLake Dupree show levels above 800 ppt. Much of this data is from theanalysis of whole fish, or the type of analysis performed is not stated.Levels found by analyzing a homogenate of the whole fish are usuallyhigher than those found in the edible portion. Additional testing of theedible portion of various fish species should be performed. The U . S . Foodand Drug Administration developed a fish standard for dioxin in responseto a request from the Governor of Michigan. Fish containing dioxin in theedible portion at over 50 ppt should not be consumed. At average levelsof less than 25 ppt in the edible portion, the FDA felt there was no causefor concern. At levels between 25 and 50 ppt, a recommendation was madefor people who usually eat large amounts of fish to limit their intake. Athorough explanation of the FDA' reasoning for setting these levels isfound in reference 4. The FDA recommended not lifting the ban untilfurther testing was done of the edible portions of various fish species.

Newspaper reports suggest Chat the ban on fishing in the Bayou Metou isnot being respected. The Cask of assessing the average levels of dioxinin edible portions of various species of fish and preventing theconsumption of large amounts of contaminated fish should be given highpriority.

No information was available in the package about Lake Dupree, or aboutthe hydrogeology of the regional ground flow system, and past andpotential impact of the Vertac site upon that flow system. A ground waterquality study to determine the impact and the extent of contaminantmigration upon ground water resources is necessary before any decision ismade to propose long term remedial measures.Other known off-site contamination: The integrity of the two out-of-statedisposal sites where waste was shipped should be reviewed to assure thatproper hazardous waste handling practices are being followed. Mud androck fron the equalization treatment ponds, catch basin sludge, anddiatomaceaous earth filter material was sent to the Kansas IndustrialEnvironmental Services facility, Wi.chi.ta, Kansas; and 2,4-D processsludge was sent to the Browning & Ferris Landfill, Louisiana.

In the Jacksonville STP oxidation pond, levels as high as 8.37 ppb of TCDDhave been found (EPA sample ̂ 115, page 2 1 ) . Assuming the pond site isproperly designed, and the STP is operating properly, the TCDD in thissediment should not pose a hazard Co human health until efforts are madeto remove it.

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Other alledged sites of dumping should be thoroughly investigated to ruleout more widespread contamination. The source of some of the odorproblems reported by Jacksonville residents may come from another factory,the U . S . Steel Polyester Unit, known locally as USS Chemicals, which isjust northwest of Vertac. Complaints of odors from the plant are said tobe related to occasional styrene spills. The plant makes plastic partsfor boats.

Documents Reviewed on Vertac Package

A. Categories of Observations and Conclusions

B. "VERTAC, Jacksonville, Arkansas," a summary of site history and storage.

C. "Analyses of Industrial Samples for Tetrachloro dibenzo-p-dioxins(TCDDs)", U . S . EPA, Final Report, Contract No. 68-03-2830 prepared byWright State University, April 1, 1980 (page 17 uas missing).

0. Summary of Sampling - Arkansas Department of Pollution Control and Ecology

E. "Vertac Samples from September and October, 1979 where phenols were foundabove detection limits." ' ' ' '

.0F. EPA's "Proposed Additional offsite soil sampling at VERTAC," February 23,

1983 memorandum form Kelly Nash to Dwight Hoenig.

G. July 11, 1979 Soil Samples Analyzed for TCDD, residential sites a to f. ^"

H. Dioxin Sample Locations and Sample Results, May 1 6 , 17, and 29, 1979.I. "Air Emission Sources near Vertac Site, Jacksonville, Arkansas," EPA

February 24, 1983 memorandum from Kelly Hash to Messrs. Guild and Buynoski.

J. "Notes on the May 16-17, 1979 Vertac Sample Summary."

K. Arkansas Department of Health, memorandum dated July 13, 1979 from PhillipPeters to Bernie Sheets.

L. EPA letter dated July 6 , 1979 to Mr. Soutwall, Arkansas Department ofPollution Control and Ecology.

References

1. Hardell L, Sandstrom A. Case-control study: soft-tissue sarcomas andexposure to phenoxyacetic acids or chlorophenols. Br. J. Cancer, 1979;39: 711-17.

2. Honchar PA, Halperin WE. Letter to the editor. Lancet, 1981; i: 268-9.

3. EPA's Water Quality Criteria, Federal Register, November 28, 1980.

4. Cordle F. The use of epidemiology in the regulation of dioxins in thefood supply. Regulatory Toxicology and Pharmacology 1981; 1: 379-387.

5 . Preliminary report. Presentation given at CDC, Atlanta, February, 1983,by Dr. Raymond Neutra, California Department of Health.