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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 awood-treatment plant since 1946. The site is located north of U.S. Highway 301 andapproximately0.6 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 PrioritiesList (NPL) in September 1984.

Past practices at the Koppers site have led to contamination of the on-site soil andgroundwater. Contaminated off-site media include groundwater,surface water, sediments, and fish. Contaminantsidentified as being of concern include pentachlorophenol and other chlorinatedphenols, 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, plantemployeescomplained about the odor of their potable water supply. The company discontinued use of thewells until the lines were flushed. In 1980, an area resident requested that SCDHEC test hisprivate well water. Creosote contaminants were detected in water samples collected from thiswell and other neighborhood wells; this led to SCDHEC issuing drinking water advisories. KII-Fpaid for an alternate water supply for residents wishing to connect to municipal water. KII-Falso 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 documentPreliminary Health Assessment expressed concerns about the lack of sampling data for thepublic water supply wells downgradient of the site. A composite sample of these wells wastaken 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 DayStreet and Mustang neighborhoods. The survey indicated that there are seven wells still beingutilized in these communities. The wells were sampled and analyzed for metals, purgeableorganic compounds, extractable organic compounds, and pesticides and PCBs. Sampling did notdetect the presence of site-related contaminants. KII-F is in the process of installing additionalmonitoring wells south of the facility.

The site is classified as being a public healthhazard because there is a potential for humanexposure tocontaminated groundwater. Ingestion of contaminatedfish from the creeksadjoining the site could also lead to human exposures; however, this route of exposurehas notbeen fully characterized.

We recommend that on-site and off-site surface soil samples be collected and analyzed tobetterdetermine the potential for human exposures to contaminated soil. ATSDR defines surface soilas soil from 0" - 3" in depth. We recommend that access to the site be restricted, that additionalfish and crayfish samples from the adjoining creeks be collected and analyzed, that private wellsin the area be periodically sampled, and that continuous monitoring of groundwater be conductedfrom locations on and off the site.

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


BACKGROUND

A. Site Description and History

The Koppers Industries, Incorporated plant of Florence (KII-F), South Carolina is an active145-acre wood-treatment and preserving facility located north of U.S. Highway 301 andapproximately 0.6 miles east of Florence, South Carolina (Figure 1). We will refer to the site asKII-F throughout this public health assessment. KII-F was added to the EnvironmentalProtection Agency (EPA) National Priorities List (NPL) in September 1984. The facility islisted as a Resource Conservation and Recovery Act (RCRA) facility because it generateshazardous wastes. Thearea surrounding the site is zoned residential, industrial, and commercial. Homes, apartments, mobile homes, businesses, agricultural lands, and an airport are all locatedwithin 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 acontainer storage facility (CSF) and a surface impoundment. The CSF previously storedhazardous waste in containers during its operation as an interim facility. The company uses achromated copper arsenate (CCA) process which combines arsenic with copper and chromium toform an aqueous wood preservative. Waste-waters are collected and recycled to the CCAsolution; therefore, they are not generated from the CCA process.

American Lumber and Treating Company first began wood-treatment processes at the site in1946. Since purchasing the plant in 1954, KII-F has operated pentachlorophenol (PCP),creosote, and chromated copper arsenate (CCA) treatments of wood. (This includes variouscorporations such as Koppers Company, Inc., Koppers Industries, Inc., Beazer Materials andServices, and Beazer East).

In 1971, a letter from the State Board of Health, now the South Carolina Department ofHealthand Environmental Control (SCDHEC), informed KII-F that it had to apply for a wastewaterdischarge permit. KII-F contracted a representative of Monroeville Research Center (theKoppers Company, Inc. Research and Technology Center) to evaluate the existing system andrecommend improvements to satisfy permit requirements. This representative reported in May1971, that creosote waste entered a lagoon through a 2.5 inch pipe leading from the creosotecylinders. The overflow and seepage from the lagoon then flowed into a ditch at an approximaterate of 2,000 gallons per day. He recommended that a spray irrigation system be implemented inan area northwest of the creosote lagoon. Although soil tests of the selected area indicated that itwas too permeable to allow adequate time for biodegradation, he stated that if wastes weresprayed over the two-acre tract at a rate of 4,000 gallons per day, most of the applied waterwould evaporate. Drainage from this system would flow toward the Pye Branch of JeffriesCreek. Wastes described as penta-oil were pumped to four unlined lagoons where waterdissipated 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 StateBoard 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. Allparameters 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 anAdministrative order because the site's discharge violated NPDES permit conditions. TheAdministrative 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 creosotelagoon, and the existing spray-field in the southwestern portion of the site. The companyproposed 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 northernportion of the site. SCDHEC approved the new system which began operation in the summer of1977. 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 buildingindicated a naphthalene concentration of 2,300micrograms per liter (µg/L). KII-Frepresentatives 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 detectedat approximately 8 µg/L. Naphthalene was not detected.

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

A resident living southwest of the site reported to SCDHEC in 1980 that his well water had acreosote odor and a foul taste. Other residents in the area voiced the same complaints. Privatewell water analyses by SCDHEC confirmed the presence of creosote constituents. As a result ofthe contamination found in these residential private wells, SCDHEC issued a Consent Orderrequiring KII-F to conduct extensive groundwater studies to determine the extent ofcontamination. 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 forthe Day Street community.

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

In 1982 and 1983, LBG conducted two phases of Groundwater Quality Investigation. In1985,LBG initiated a groundwater quality assessment following the detection of additional RCRAgroundwater quality indicator parameters in RCRA quarterly monitoring samples.

KII-F's August 1983 groundwater study included a recommendation that 14 recovery wellsand apre-treatment wastewater system be constructed at the plant. The recovery wells are intended toslow migration of contaminants off-site; the recovered water is to be processed in thepre-treatment facility and discharged to public sewer. The wells and wastewater system wereconstructed before SCDHEC approval. SCDHEC approved the system for operation in May1988. A January 6, 1989, memorandum from SCDHEC personnel confirmed that the system isnow in operation.

The 1983 groundwater study for KII-F was performed prior to its inclusion into the NPL in1984and, therefore, did not meet all criteria for a Remedial Investigation/Feasibility Study (RI/FS) ora RCRA Facility Investigation/Corrective Measures Study (RFI/CMS). EPA's WasteManagement Division, Residuals Management Branch, has entered into a Consent Order withKII-F to submit a RFI/CMS work plan. Under this Consent Order, the company must fullycharacterize the site, including determining the extent of the groundwater contaminationemanating from the site. ATSDR has provided KII-F with OSWER Directive 9285.4-02,"Guidance for Coordinating ATSDR Health Assessment Activities with the Superfund RemedialProcess"; 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 SCDHECDivision of Health Hazard Evaluation, in cooperation with ATSDR, prepared a preliminaryhealth assessment for the site in 1988.

On June 16, 1988, BNS, Beazer Materials and Services, Inc., a Delaware Corporation andwholly-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. ThisPublicHealth Assessment is based on the data contained in the RFI.

In February 1992, representatives of SCDHEC and EPA Region IV performed adoor-to-doorwell survey of the areas southeast, south, and southwest of the KII-F site. This included the DayStreet and Mustang Drive neighborhoods. On March 3, 1992, EPA Region IV EnvironmentalServices Division collected water samples from several private wells identified by the February1992 survey.

B. Site Visit

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

The site was composed primarily of sandy soil with little vegetation. Unbound stacks oftreatedand untreated lumber were located in most areas of the site. Drums were stored among thestacks of wood (Figure 3). Project staff saw the building that houses the CCA treatment processwas seen along with the old NCX fire retardation process building. (NCX is a fire retardanttreating 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 theoperational spray-field. The operational spray-field was used to treat/dispose of waste-watersthat had gone through an oil/water separation process. These waste-waters could have containedsome waste oils. Vegetation in the spray-field appeared to be stressed. Soil at the drip areaadjacent to the creosote injection building appeared to be stained black. Three boiler stacks wereseen. (SCDHEC has issued permits to KII-F for combustion of non-contaminated waste oils inthese boilers). Heavy equipment was operating in most areas. Employees were not wearingrespirators 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 newwastewater treatment facility is functioning. Three lined solar lagoons were operating. Theholding tank for the new wastewater treatment process was located near a dirt road at thenortheast perimeter of the site. The area surrounding the tank was fenced. Recovery wells andmonitoring wells were distributed near the closed creosote lagoon area. Recovery wells werealso located near the southeastern storm-water run-off ditch.

The western border of the site adjoined a cultivated field was unrestricted. Two mobilehomeswere located within 100 feet of this property line: one occupied and one vacant. Plantrepresentatives 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 thecity'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 neighborhoodsaround the site. No on-site visit was made at that time. Mr. Blansit noted a few changes fromprevious visits. The trailers immediately northwest of the site appeared uninhabited. While theMustang Drive neighborhood shows water meter boxes, the road immediately east consists ofapproximately ten house trailers with a centrally situated building. (The February 1992 surveyfound that these trailers also use municipal water.) A new elementary school is locatedapproximately 2 1/2 miles southeast of the site. Water meter boxes were not observed in the OldMars Bluff Road neighborhood (multiple well houses were observed).

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

C. Demographics, Land Use, and NaturalResource Use

Demographics

KII-F is located in eastern Florence, South Carolina (Figure 1). Forests form the northernandeastern borders of KII-F. Four communities are located within a 1-mile radius of the site: theDay 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 inall 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 Population246

B*.Old Mars Bluff Neighborhood
Total Population1239

C+.Hyman Street Neighborhood
Total Population1181

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 cashrent.

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. Anunpaved road runs along the eastern side of the facility. A paved road leads to the plant entranceon the southeast side of the site. A steel fabrication and distribution company is located east ofthis 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 mobilehomes are located less than 100 feet from KII-F's northwestern property line.

Many mobile homes, cultivated agricultural areas, an airport, light industrial facilities, andcommercial businesses are located within a 1-mile radius of the site. A day-care center, regionalmedical 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 cannotbequantified. Similarly, staff have gathered anecdotal reports of hunting in the forested area northof 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 thesite. Available hydrogeologic data indicate that these wells are located downgradient of groundwaterflow. 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 dealingwith health effects in the vicinity of the KII-F site.


COMMUNITYHEALTH CONCERNS

The first known complaint by an area resident concerning plant operations is documented in a1948 lawsuit against American Lumber and Treating Company. In addition to monetarycompensation for property damages, the plaintiff requested a permanent restraining order beplaced against the company to prevent further "throwing of creosote or other chemicals injuriousto life into Two-Mile Branch [Creek]."

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

In 1980, an area resident requested that SCDHEC test his water. Confirmation ofcontaminationin his and other area private wells led to SCDHEC's issuing drinking water advisories. Asagreed to under a 1983 SCDHEC Consent Order, KII-F paid for an alternative water supply forany persons in the Day Street community wishing to connect to the system and also agreed topay 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 DayStreet neighborhood have done so. The plan states:

    While the level of citizen concern in the affected community is high, the level of action islow. This was evident in discussions with State, County, and local officials who saidthey have heard little, if any, concern expressed about the site from residents of theaffected community or people living elsewhere in the area. Most people interviewedwere unaware of any problems at the site and no one reported the existence of anycommittees formed or meetings held to address the problem of groundwatercontamination in the area around the site.

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

The 1988 preliminary health assessment expressed concerns for residences that utilizedprivatedrinking wells as their potable water source. SCDHEC personnel have expressed concern overthe lack of sampling data for the public water supply wells downgradient of the site. (Acomposite sample of the city's wells was analyzed for 59 volatile organic chemicals in February1988. All chemicals were reported as below detection levels. The Pine Street and Ballard Streetwells were included in the composite sample but were not sampled independently.)

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



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