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PUBLIC HEALTH ASSESSMENT

KOPPERS COMPANY INC./FLORENCE PLANT
FLORENCE, FLORENCE COUNTY, SOUTH CAROLINA



SUMMARY

Koppers Industries, Incorporated of Florence, South Carolina (KII-F) has operated as a wood-treatment plant since 1946. The site is located north of U.S. Highway 301 and approximately 0.6 miles east of the city of Florence. It is a Resource Conservation and Recovery Act (RCRA) facility. KII-F was added to the Environmental Protection Agency's (EPA) National Priorities List (NPL) in September 1984.

Past practices at the Koppers site have led to contamination of the on-site soil and groundwater. Contaminated off-site media include groundwater, surface water, sediments, and fish. Contaminants identified as being of concern include pentachlorophenol and other chlorinated phenols, polycyclic aromatic hydrocarbons (PAHs), polychlorinated dioxins and furans, mercury, copper, chromium, arsenic, and varied constituents of creosote.

No community health concerns have been expressed in several years. In 1979, plant employees complained about the odor of their potable water supply. The company discontinued use of the wells until the lines were flushed. In 1980, an area resident requested that SCDHEC test his private well water. Creosote contaminants were detected in water samples collected from this well and other neighborhood wells; this led to SCDHEC issuing drinking water advisories. KII-F paid for an alternate water supply for residents wishing to connect to municipal water. KII-F also agreed to pay the water bills for these residences for one year.

In 1988, a Preliminary Health Assessment of the site was released to the public; the document Preliminary Health Assessment expressed concerns about the lack of sampling data for the public water supply wells downgradient of the site. A composite sample of these wells was taken in the same year and all the chemicals reported were below detection limits.

In February 1992, the EPA and SCDHEC conducted a door-to-door well survey in the Day Street and Mustang neighborhoods. The survey indicated that there are seven wells still being utilized in these communities. The wells were sampled and analyzed for metals, purgeable organic compounds, extractable organic compounds, and pesticides and PCBs. Sampling did not detect the presence of site-related contaminants. KII-F is in the process of installing additional monitoring wells south of the facility.

The site is classified as being a public health hazard because there is a potential for human exposure to contaminated groundwater. Ingestion of contaminated fish from the creeks adjoining the site could also lead to human exposures; however, this route of exposure has not been fully characterized.

We recommend that on-site and off-site surface soil samples be collected and analyzed to better determine the potential for human exposures to contaminated soil. ATSDR defines surface soil as soil from 0" - 3" in depth. We recommend that access to the site be restricted, that additional fish and crayfish samples from the adjoining creeks be collected and analyzed, that private wells in the area be periodically sampled, and that continuous monitoring of groundwater be conducted from locations on and off the site.

This public health assessment was reviewed by the ATSDR Health Activities Recommendation Panel (HARP). The review recommended an immediate private well survey in the areas to the southwest, southeast, and south of the site; this survey was performed in February 1992. HARP does not recommend additional actions at this time. ATSDR and SCDHEC will review additional data as they become available.


BACKGROUND

A. Site Description and History

The Koppers Industries, Incorporated plant of Florence (KII-F), South Carolina is an active 145-acre wood-treatment and preserving facility located north of U.S. Highway 301 and approximately 0.6 miles east of Florence, South Carolina (Figure 1). We will refer to the site as KII-F throughout this public health assessment. KII-F was added to the Environmental Protection Agency (EPA) National Priorities List (NPL) in September 1984. The facility is listed as a Resource Conservation and Recovery Act (RCRA) facility because it generates hazardous wastes. The area surrounding the site is zoned residential, industrial, and commercial. Homes, apartments, mobile homes, businesses, agricultural lands, and an airport are all located within a 1-mile radius of the site (Figure 2).

The site consists of wood treatment cylinders located in the central portion of the site (Figure 3). The treated wood is stored in the northern, northeastern, and southern portions of the property. Two RCRA regulated units are located in the northwest portion of the site. These units include a container storage facility (CSF) and a surface impoundment. The CSF previously stored hazardous waste in containers during its operation as an interim facility. The company uses a chromated copper arsenate (CCA) process which combines arsenic with copper and chromium to form an aqueous wood preservative. Waste-waters are collected and recycled to the CCA solution; therefore, they are not generated from the CCA process.

American Lumber and Treating Company first began wood-treatment processes at the site in 1946. Since purchasing the plant in 1954, KII-F has operated pentachlorophenol (PCP), creosote, and chromated copper arsenate (CCA) treatments of wood. (This includes various corporations such as Koppers Company, Inc., Koppers Industries, Inc., Beazer Materials and Services, and Beazer East).

In 1971, a letter from the State Board of Health, now the South Carolina Department of Health and Environmental Control (SCDHEC), informed KII-F that it had to apply for a wastewater discharge permit. KII-F contracted a representative of Monroeville Research Center (the Koppers Company, Inc. Research and Technology Center) to evaluate the existing system and recommend improvements to satisfy permit requirements. This representative reported in May 1971, that creosote waste entered a lagoon through a 2.5 inch pipe leading from the creosote cylinders. The overflow and seepage from the lagoon then flowed into a ditch at an approximate rate of 2,000 gallons per day. He recommended that a spray irrigation system be implemented in an area northwest of the creosote lagoon. Although soil tests of the selected area indicated that it was too permeable to allow adequate time for biodegradation, he stated that if wastes were sprayed over the two-acre tract at a rate of 4,000 gallons per day, most of the applied water would evaporate. Drainage from this system would flow toward the Pye Branch of Jeffries Creek. Wastes described as penta-oil were pumped to four unlined lagoons where water dissipated by evaporation and seepage. The reviewed documents did not provide a definition of "penta-oil." On the basis of the information provided by KII-F and this individual, the State Board of Health evaluated and approved the spray irrigation field operation.

In December 1974, the EPA issued a National Pollutant Discharge Elimination System (NPDES) permit to KII-F which specified the parameters for wastewater discharge from the site. All parameters were based on 1971 data collected and analyzed by KII-F and Keystone Laboratory. The permit became effective in February 1975. In September 1975, the EPA issued an Administrative order because the site's discharge violated NPDES permit conditions. The Administrative order required that KII-F conduct a study to devise a method to control runoff. As a result of this 1976 study, KII-F proposed to close the four penta-oil lagoons, the creosote lagoon, and the existing spray-field in the southwestern portion of the site. The company proposed to construct three concrete-lined solar oxidation ponds to replace the old systems. Effluent from the final lagoon was to be sprayed on a 12-acre field located in the northern portion of the site. SCDHEC approved the new system which began operation in the summer of 1977. The NPDES permit was reissued to address storm-water runoff.

Early in 1979, the plant's potable water well system was reported to have a naphthalene odor. Analysis, performed by a KII-F affiliated laboratory, of water from the service building indicated a naphthalene concentration of 2,300 micrograms per liter (µg/L). KII-F representatives believed that a back-flow condition in supply lines caused this contamination. KII-F flushed and re-sampled the water system. Keystone Environmental Resources, Inc. reports that facility water supply wells were then analyzed for volatile aromatic compounds, PAHs, acid extractable phenolics, arsenic, chromium, copper, and mercury. Phenol was detected at approximately 8 µg/L. Naphthalene was not detected.

In November 1979, KII-F submitted a "Notification of Hazardous Waste Activity" to SCDHEC and EPA. The notification listed creosote, PCP, and inorganic salt wastes as hazardous substances generated on-site.

A resident living southwest of the site reported to SCDHEC in 1980 that his well water had a creosote odor and a foul taste. Other residents in the area voiced the same complaints. Private well water analyses by SCDHEC confirmed the presence of creosote constituents. As a result of the contamination found in these residential private wells, SCDHEC issued a Consent Order requiring KII-F to conduct extensive groundwater studies to determine the extent of contamination. On November 5, 1981, KII-F retained Leggette, Brashears & Graham, Inc. (LBG) to perform the hydrogeologic study. KII-F also agreed to arrange public water access for the Day Street community.

SCDHEC issued notices to local residents expressing concern about the safety of private wells in this community; however, not all residents agreed to connect to the public water supply. One such person, owner of a small business, informed SCDHEC that his well water would be used only for "washing hands, etc." Few, if any, private well owners in the area have abandoned their wells in accordance with SCDHEC regulations.

In 1982 and 1983, LBG conducted two phases of Groundwater Quality Investigation. In 1985, LBG initiated a groundwater quality assessment following the detection of additional RCRA groundwater quality indicator parameters in RCRA quarterly monitoring samples.

KII-F's August 1983 groundwater study included a recommendation that 14 recovery wells and a pre-treatment wastewater system be constructed at the plant. The recovery wells are intended to slow migration of contaminants off-site; the recovered water is to be processed in the pre-treatment facility and discharged to public sewer. The wells and wastewater system were constructed before SCDHEC approval. SCDHEC approved the system for operation in May 1988. A January 6, 1989, memorandum from SCDHEC personnel confirmed that the system is now in operation.

The 1983 groundwater study for KII-F was performed prior to its inclusion into the NPL in 1984 and, therefore, did not meet all criteria for a Remedial Investigation/Feasibility Study (RI/FS) or a RCRA Facility Investigation/Corrective Measures Study (RFI/CMS). EPA's Waste Management Division, Residuals Management Branch, has entered into a Consent Order with KII-F to submit a RFI/CMS work plan. Under this Consent Order, the company must fully characterize the site, including determining the extent of the groundwater contamination emanating from the site. ATSDR has provided KII-F with OSWER Directive 9285.4-02, "Guidance for Coordinating ATSDR Health Assessment Activities with the Superfund Remedial Process"; data requirements outlined in these guidelines must be included in the work plan.

In December 1986, the EPA prepared a RCRA Facility Assessment (RFA). The SCDHEC Division of Health Hazard Evaluation, in cooperation with ATSDR, prepared a preliminary health assessment for the site in 1988.

On June 16, 1988, BNS, Beazer Materials and Services, Inc., a Delaware Corporation and wholly-owned subsidiary of Beazer PLC, acquired 90% of the Koppers Company, Inc. stock. On December 28, 1988, the Florence facility was sold to Koppers Industries, Inc. Sampling for the RFI occurred from August 1989 through February 1990. In December 1990, Beazer East, Inc. released the Final Interim RCRA Facility Investigation Report. This Public Health Assessment is based on the data contained in the RFI.

In February 1992, representatives of SCDHEC and EPA Region IV performed a door-to-door well survey of the areas southeast, south, and southwest of the KII-F site. This included the Day Street and Mustang Drive neighborhoods. On March 3, 1992, EPA Region IV Environmental Services Division collected water samples from several private wells identified by the February 1992 survey.

B. Site Visit

On April 18, 1988, project staff consisting of Douglas Carver, Gail Godfrey, and Edward Gregory were accompanied by plant personnel on a site visit. All observations were made from KII-F vehicles at the request of the plant's assistant manager. This represents the most extensive on-site visit made by the project staff. Subsequent visits have been confined to the perimeter of the site and have yielded similar data.

The site was composed primarily of sandy soil with little vegetation. Unbound stacks of treated and untreated lumber were located in most areas of the site. Drums were stored among the stacks of wood (Figure 3). Project staff saw the building that houses the CCA treatment process was seen along with the old NCX fire retardation process building. (NCX is a fire retardant treating solution which includes melamine, formaldehyde, and phosphoric acid.) KII-F representatives stated that the NCX treatment has been discontinued.

Evidence of soil contamination was detected in the closed creosote lagoon area and in the operational spray-field. The operational spray-field was used to treat/dispose of waste-waters that had gone through an oil/water separation process. These waste-waters could have contained some waste oils. Vegetation in the spray-field appeared to be stressed. Soil at the drip area adjacent to the creosote injection building appeared to be stained black. Three boiler stacks were seen. (SCDHEC has issued permits to KII-F for combustion of non-contaminated waste oils in these boilers). Heavy equipment was operating in most areas. Employees were not wearing respirators or dust masks when operating this equipment or when working near the spray-field.

The plant's assistant manager related that the spray-field will continue operation until the new wastewater treatment facility is functioning. Three lined solar lagoons were operating. The holding tank for the new wastewater treatment process was located near a dirt road at the northeast perimeter of the site. The area surrounding the tank was fenced. Recovery wells and monitoring wells were distributed near the closed creosote lagoon area. Recovery wells were also located near the southeastern storm-water run-off ditch.

The western border of the site adjoined a cultivated field was unrestricted. Two mobile homes were located within 100 feet of this property line: one occupied and one vacant. Plant representatives stated that the site's railroad switching yard is active.

Residential areas were located within 0.25 mile west and south of the plant. Private wells, gardens, and livestock were visible in many yards throughout the communities. Two of the city's public water supply wells are located within one mile southwest of the site.

On September 4, 1991, project staff consisting of Doug Blansit, surveyed the neighborhoods around the site. No on-site visit was made at that time. Mr. Blansit noted a few changes from previous visits. The trailers immediately northwest of the site appeared uninhabited. While the Mustang Drive neighborhood shows water meter boxes, the road immediately east consists of approximately ten house trailers with a centrally situated building. (The February 1992 survey found that these trailers also use municipal water.) A new elementary school is located approximately 2 1/2 miles southeast of the site. Water meter boxes were not observed in the Old Mars Bluff Road neighborhood (multiple well houses were observed).

The spray-field and wastewater lagoons are no longer in use. Waste-waters from the 14 operational recovery wells are pre-treated and discharged to the Florence sewer system. Soils in the drip track area have been removed and stockpiled on the site for future treatment. A concrete pad with run-on/run-off control has been installed in the drip track area. Drippage is now collected and handled as a hazardous waste by KII-F.

C. Demographics, Land Use, and Natural Resource Use

Demographics

KII-F is located in eastern Florence, South Carolina (Figure 1). Forests form the northern and eastern borders of KII-F. Four communities are located within a 1-mile radius of the site: the Day Street, Hyman Street, Old Mars Bluff Road, and Mustang Drive communities (Figure 3). The rental rates and property values for these communities are indicative of low-income status. Table I summarizes demographic features of these communities. Private wells were observed in all of these communities. No current well survey data were available for review.

TABLE 1
KOPPERS - FLORENCE SITE DEMOGRAPHICS (FOR 1-MILE RADIUS)

A*. Day Street Neighborhood
        Total Population       246

B*. Old Mars Bluff Neighborhood
        Total Population       1239

C+. Hyman Street Neighborhood
        Total Population       1181

D+. Mustang Street Neighborhood
        Total Population       98


%
White
%
Black
%
Other
%
<10
yrs
%
65+
yrs
%
Rental
Units
<$120/
month
++
%
Houses
<$25,000
%
Renter-
Occupied
A* 38 62 0 14 13 67 68 50
B* 7 93 0 20 8 79 67 31
C+ 1 99 0 22 10 4 3 11
D+ 85 14 1 16 9 2 1 18
* - Based on 1980 Census data.
+ - Based on 1990 Census data.
++ - Percentages include all rentals; some subsidized housing includes those who pay no cash rent.

E. City of Florence
        Total Population (1990)       29,813

F. Florence County
        Total Population (1990)       114,344

Land Use

Railroad tracks, scrub-lands, and forests border areas south and southwest of the plant. An unpaved road runs along the eastern side of the facility. A paved road leads to the plant entrance on the southeast side of the site. A steel fabrication and distribution company is located east of this entrance.

A cultivated field, approximately 1 acre in size, adjoins the western perimeter or the facility. SCDHEC project staff have observed soybeans growing in this field. Two uninhabited mobile homes are located less than 100 feet from KII-F's northwestern property line.

Many mobile homes, cultivated agricultural areas, an airport, light industrial facilities, and commercial businesses are located within a 1-mile radius of the site. A day-care center, regional medical center, middle school, and two elementary schools lie within 3 miles of the site.

Natural Resource Use

Project staff have observed fishing within the nearby creeks. However, observations cannot be quantified. Similarly, staff have gathered anecdotal reports of hunting in the forested area north of KII-F. The extent of either activity is unknown.

Two of the 16 water supply wells for the city of Florence are located within one mile of the site. Available hydrogeologic data indicate that these wells are located downgradient of groundwater flow. Approximately 30,000 persons are served by this municipal water supply.

D. Health Outcome Data

The State of South Carolina does not currently have an implemented database or registry dealing with health effects in the vicinity of the KII-F site.


COMMUNITY HEALTH CONCERNS

The first known complaint by an area resident concerning plant operations is documented in a 1948 lawsuit against American Lumber and Treating Company. In addition to monetary compensation for property damages, the plaintiff requested a permanent restraining order be placed against the company to prevent further "throwing of creosote or other chemicals injurious to life into Two-Mile Branch [Creek]."

In 1979, plant employees complained about the odor of their potable water supply. The company discontinued use of the company's potable wells until the lines were flushed and naphthalene was not detected in the water sample collected from the well.

In 1980, an area resident requested that SCDHEC test his water. Confirmation of contamination in his and other area private wells led to SCDHEC's issuing drinking water advisories. As agreed to under a 1983 SCDHEC Consent Order, KII-F paid for an alternative water supply for any persons in the Day Street community wishing to connect to the system and also agreed to pay their water bills for one year.

As documented in the November 12, 1987, "Community Relations Plan, Koppers Company, Inc., Florence County, South Carolina," residents who were financially able to leave the Day Street neighborhood have done so. The plan states:

    While the level of citizen concern in the affected community is high, the level of action is low. This was evident in discussions with State, County, and local officials who said they have heard little, if any, concern expressed about the site from residents of the affected community or people living elsewhere in the area. Most people interviewed were unaware of any problems at the site and no one reported the existence of any committees formed or meetings held to address the problem of groundwater contamination in the area around the site.

    Although several articles have been published in the local newspaper, few people outside the affected community were aware of the site's hazardous waste problems. Most elected officials stated that they were unaware of the fact that the site was on the NPL or that there was any Federal involvement at the site.

The 1988 preliminary health assessment expressed concerns for residences that utilized private drinking wells as their potable water source. SCDHEC personnel have expressed concern over the lack of sampling data for the public water supply wells downgradient of the site. (A composite sample of the city's wells was analyzed for 59 volatile organic chemicals in February 1988. All chemicals were reported as below detection levels. The Pine Street and Ballard Street wells were included in the composite sample but were not sampled independently.)

The KII-F Public Health Assessment was available for review and public comment from September 26, 1992 until October 26, 1992. Copies of the Public Health Assessment were available to the community/interested parties at the Florence City Hall, the Florence County Library, the Timmonsville County Library, and the South Carolina Department of Health and Environmental Control, Division of Health Hazard Evaluation. Additionally, news releases were sent to all the weekly and daily newspapers in the state, all television networks in the state, the Associated Press, and the South Carolina Radio network. This comment period was intended to give the public and/or interested parties an opportunity to voice additional concerns or make comments pertaining to the KII-F Public Health Assessment. The office of Health Hazard Evaluation of the South Carolina Department of Health and Environmental Control received comments during this period and have incorporated these comments into Appendix B.

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