PUBLIC HEALTH ASSESSMENT
KOPPERS COMPANY INC./FLORENCE PLANT
FLORENCE, FLORENCE COUNTY, SOUTH CAROLINA
Response to Comments Received During the Public Comment Period
The following responses address technical comments submitted by the public during the public comment period of September 26 to October 26, 1992. This Public Health Assessment was prepared in accordance with ATSDR's Public Health Assessment Guidance Manual, March 1992.
1. Concerns were made about the data utilized for presenting this Public Health Assessment (PHA). The data used was the most currently available data to date. After the completion of this Public Health Assessment, an additional well survey was conducted. The survey was conducted in February and March 1992. The data presented from this survey and the sampling conducted, was made available to our office, and information provided by this survey has been incorporated into the applicable sections of this Public Health Assessment.
2. Concerns were presented that the PHA contained 1980 census information. That was the only information available at the time the PHA was written. However, 1990 census data is now available and the demographics section of this PHA has been updated accordingly.
3. A comment was made of the toxicological evaluation presented in the PHA of the effects of Polycyclic Aromatic Hydrocarbons (PAHs). The comment made references to a Toxicological Profile for Polycyclic Aromatic Hydrocarbons that was released in October 1989 by ATSDR to provide toxicological information about PAHs. The Toxicological Profile utilized for evaluation and inclusion into this PHA was released in December 1990 by ATSDR.
4. During the public comment period, our office was presented with a summary of the Community Relations Plan (Koppers Co., Inc. 1987). The information presented in this plan has been added to the PHA.
5. Concerns were expressed about the nature of the fish and crayfish data presented in this PHA. The data was gathered from the August and November 1986 and May 1987 data that were obtained as part of the Stream Characterization Study (Keystone, June 1988). Fish were not evaluated as part of the RFI investigation. The fish sampled and analyzed in the study are whole fish. This data cannot be used to adequately evaluate the potential health effects to humans who consume the fish because no one would be expected to consume whole fish (heads, tails, and viscera). In addition, crayfish tails could be considered edible, although this is considered unlikely. Crayfish could not be adequately evaluated due to insufficient numbers of crayfish gathered for analysis.
In the recommendation's section, this PHA recommends that further sampling of fish and crayfish is needed from the streams adjoining the site to better characterize the extent of contamination in this media. Additionally, the use of these areas needs to be determined to better evaluate human health effects associated with consumption rates of fish and crayfish from these areas.
6. Concerns were expressed about the Pathways Section of this PHA and questions were raised about the methodology used in the discussions incorporated into this section. The pathways sections, as all other sections of this PHA, conform to ATSDR protocol for evaluating data and presenting a PHA for NPL sites. The introductory section of the pathways analyzes explains the criteria needed for a pathway to be classified as completed or potential. In keeping with this protocol, the discussion in this section best describes the analysis of the data presented to the date of the completion of this PHA for this site.
The groundwater pathway was considered to be completed because there is evidence that people were exposed to contamination from utilizing their groundwater - private wells as their potable water source. People were exposed to contamination via ingestion, inhalation, and/or through dermal contact with contaminated groundwater.
The air pathway was presented as a potential exposure pathway because contaminated soil could become airborne. Additional data is needed in order to better characterize these exposure pathways. This PHA recommends surface soil samples from 0" - 3" in depth be collected and analyzed to better characterize the extent of contaminants people may be exposed to. This sampling data will enable us to better evaluate the potential for health effects to occur via the soil and air pathways.
7. Several references were made about the EPA and ATSDR. In comparing an EPA Risk Assessment to an ATSDR Public Health Assessment, it is important to realize that these are two separate agencies with different missions and goals. These agencies have differing definitions for exposure pathways. Contaminants of concern for incorporation into a Risk Assessment and a Public Health Assessment are selected differently by the EPA and ATSDR.
Risk Assessments are used to determine the need for action, help to determine cleanup levels, evaluated ecological risks, and to make comparisons between remedial alternatives. Public Health Assessments determine past, present or future health effects, the significance of past exposures, the need for follow-up studies, and the population effects of non-related sources of exposure in the community.
ATSDR generally uses the maximum concentration of a contaminant found for choosing the contaminant for further evaluation. The contaminant is then evaluated and discussed in the public health implications section of the PHA. This PHA is written by SCDHEC under a cooperative agreement with ATSDR; therefore, it follows the protocol as set forth by ATSDR. If the public is concerned about an exposure pathway or if it is reasonable that a pathway is selected as completed or potential, the pathway is retained for further evaluation and discussion. In addition, if a media is contaminated and people are being exposed, this PHA evaluates and discusses that pathway (even if the contaminants may not be site-related).
8. Comments were made that fishing does not occur in nearby streams, but that it occurs approximately 3 miles from the site at the intersection of Two Mile Creek and Highway 327. The SCDHEC personnel have noted fishing in these streams. SCDHEC district personnel verified that fishing occurs in the nearby streams. Therefore, a potential exposure pathway from ingestion of contaminated fish in these streams exists and the discussion presented in this PHA was not changed. The recommendation for additional fish sampling and consumption rate data was incorporated into this PHA to fill the data gap and provide additional information for incorporation into future evaluations of this site.
9. Comments were made about the TRW recovery system wells and the purpose and effectiveness of these wells. The writer agrees that the purpose of these wells is to prevent potential migration of constituents in groundwater to off-site locations. Further information on the recovery well system was added to this PHA to enable to readers to further understand the system. Comments on the effectiveness of this system are beyond the scope of this PHA.
Currently, groundwater contamination exists on and off the KII-F site. The February 1992 well survey identified that seven off-site private wells are still being utilized within the direction of the groundwater flow. Analyses of these wells did not detect contamination; however, if the recovery system becomes ineffective there is a potential for off-site groundwater contamination to reach the private wells. Therefore, the use of groundwater - private wells is considered a potential exposure pathway by ATSDR protocol.