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U.S. Environmental Protection Agency
Office of Inspector General
At a Gl
2005-P-00022
September 26, 2005
Why We Did This Review
The Glynn Environmental
Coalition, a nonprofit community
organization whose goal is to
have a safe and healthy place to
live and raise a family, brought
several concerns to the
Ombudsman's attention
regarding the Hercules 009
Landfill site near Brunswick,
Georgia, in EPA Region 4.
Background
Between 1975 and 1980,
Hercules Incorporated operated
the Hercules 009 Landfill to
dispose of waste material from
producing toxaphene, an
agricultural pesticide. The site
became part of EPA's Superfund
program in 1984. Construction
on the cleanup was completed in
1999, but some contaminants
remained at the site, so every 5
years the site must be reviewed to
ensure that the cleanup is
functioning as intended and it
does not adversely affect human
health and the environment.
For further information, contact
our Office of Congressional and
Public Liaison at (202) 566-2391.
To view the full report and
addendum, click on the following
links:
www.epa.qov/oiq/reports/2005/
20050926-2005-P-00022.pdf
www.epa.qov/oiq/reports/2005/
20050926-2005-P-00022A. pdf
Catalyst for Improving the Environment
Appropriate Testing and Timely Reporting Are
Needed at the Hercules 009 Landfill
Superfund Site, Brunswick, Georgia
What We Found
The testing method that EPA uses to monitor for the presence of toxaphene in
groundwater is inadequate. Toxaphene degrades overtime, changing into
other products (toxaphene breakdown products). EPA's testing method does
not identify and measure the amount of toxaphene that has degraded, only
toxaphene that has not degraded.
The available toxicity data on the toxaphene breakdown products are not
specific as to what constitutes a safe, acceptable level of exposure. Because
toxaphene breakdown products may pose a risk to human health, they should
be monitored. A different analytical method, one that monitors toxaphene
breakdown products, should be used rather than the conventional EPA
method.
EPA's report on the 5-year review of the Hercules 009 Landfill is over a year
late, because
•	Region 4 was gathering additional data to reduce uncertainty about
how much toxaphene was present in the groundwater.
•	The U.S. Army Corps of Engineers took longer to prepare the first
draft report than expected.
•	The EPA manager for the site changed twice during the review period.
•	EPA and others made extensive comments on the draft reports.
What We Recommend
We recommend that EPA Region 4:
•	use an analytical method that monitors both toxaphene and its
breakdown products in the groundwater at the Hercules 009 Landfill
and take appropriate action if toxaphene breakdown products are
found.
•	issue the report on the Hercules 009 Landfill 5-year review.

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