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ATSDR - PHA - Alcoa/Lavaca Bay, Calhoun County, Texas (Part 3)

PRELIMINARY PUBLIC HEALTH ASSESSMENT

ALCOA (POINT COMFORT)/LAVACA BAY
POINT COMFORT, CALHOUN COUNTY, TEXAS


CONCLUSIONS

  1. Fish and crabs from the closure area of Lavaca Bay should not be eaten. Evidence indicates that people have been exposed to mercury in the past and that exposure to mercury is occurring at present. The exposed population includes people who ate contaminated fish, crabs and oysters in the past as well as people who currently eat contaminated fish and crabs from the closure area. Since eating fish and crabs contaminated with mercury at the concentrations observed at this site may affect the unborn fetus and the currently exposed population may include pregnant females, we have classified this site as an urgent public health hazard.
  2. Persons who have been exposed in the past may also include on-site workers exposed to mercury vapor. Urine samples collected from workers between 1966 to 1983 showed elevated levels of mercury. Additionally, anecdotal reports of mercury in washing machine traps suggest that former chlor-alkali workers may have brought mercury home on their clothes. Although the likelihood that mercury brought to these homes continues to represent a significant health threat is low, data to eliminate this as a continued source of exposure are not available.
  3. There is no evidence that indicates recreational activities along Port Lavaca beaches should be limited due to mercury contamination. Concentration of mercury in sediment decreases as distance from the dredge spoil island increases.
  4. Migration of mercury-contaminated groundwater may be contributing to further contamination of the Bay. In addition, if sediment in on-site lagoons is contaminated with mercury, this sediment could serve as a continuing source of contamination to groundwater and to Lavaca Bay via groundwater migration.
  5. Limited data suggest that fish, oysters, and sediment in Lavaca Bay also may be contaminated with polycyclic aromatic hydrocarbons (PAHs) and polychlorinated biphenyls (PCBs). We are unable to evaluate the public health implications of these contaminants due to insufficient data.
  6. Over the past fourteen years, levels of mercury contamination in fish have remained relatively constant, implying that mercury in the Bay has remained bioavailable. A continued source of mercury or resuspension of mercury from activities that disturb the sediment, such as dredging and shrimp trawling, could explain these constant levels.
  7. A limited number of fish samples from Keller Bay (which is outside the closure area) indicatethat fish in this area may be contaminated with mercury. However, since all of the fish sampleswere over the Texas Parks and Wildlife Department maximum size limit, we were unable todetermine the public health significance of these contaminated fish.

RECOMMENDATIONS

Cease/Reduce Exposure Recommendations

  1. We recommend that no fish or crabs from the Lavaca Bay closure area be eaten. Increase public awareness of adverse fetal health effects that could occur as a result of pregnant women consuming more than five ounces of mercury-contaminated fish per month or 11 ounces of crabs per month taken from the closure area. Notify the public and local physicians (particularly obstetricians) of the health hazards associated with consumption of mercury-contaminated fish and crabs. Designate a contact person to respond to physicians' questions and to record information about patients experiencing adverse health effects potentially associated with exposure to mercury.
  2. Publicize the areas of the Bay which contain fish and blue crabs with concentrations of mercury at levels that could cause adverse health effects to increase public awareness of the hazard of eating fish and crabs taken from contaminated areas of the Bay. Continue current ban on fish and crabs.
  3. Better delineate the area closed to the taking of fish and crabs. Improve marking of the closure area. Signs describing the closure area of the Bay should be in any appropriate language to reach the exposed population (English and Spanish) and signs should be added at the Point Comfort boat ramp (and the ramp in the Olivia area if it is constructed).
  4. Complete a fish consumption survey of the area.

Site Characterization Activities

  1. Continue to sample fish inside the closure area for mercury; analyze fish samples for PAHs and PCBs. Sample fish of legal catch size at Keller Bay near Rattlesnake Cove; analyze the samples for total mercury (and methylmercury) and provide results to the Texas Department of Health/ATSDR for evaluation.
  2. If mercury levels in fish (of legal catch size) from Keller Bay near Rattlesnake Cove are elevated, sample crabs and sediment from this area.
  3. Collect additional crab samples from the closure area and analyze for mercury. Based on sampling results, re-evaluate ban on the taking of crabs from the closure area to determine appropriate public health action.
  4. Collect oyster samples inside closure area near the Witco dock and analyze for PAHs and PCBs.
  5. Test the sediment in the lagoons for mercury and other contaminants.
  6. Determine if groundwater contamination on site is contributing to contamination of Lavaca Bay.
  7. Continue to conduct demolition or soil moving activity in the vicinity of the R-300 (chlor-alkali) building in accordance with applicable health and safety regulation (29CFR 1910.120).
  8. Determine if mercury brought into homes by former chlor-alkali workers continues to be asource of exposure.

Health Activities Recommendation Panel (HARP) Recommendations

In accordance with the Comprehensive Environmental Response, Compensation, and Liability Act(CERCLA) of 1980, as amended,the data and information developed in the ALCOA (PointComfort)/Lavaca Bay Public Health Assessment have been evaluated by the Agency for ToxicSubstances and Disease Registry's Health Activities Recommendations Panel (HARP) and TDHfor appropriate follow-up activities. Based on evidence that people have been exposed tomercury in the past and that exposures are continuing to occur at present, HARP recommendedtaking the following actions to identify exposed populations: 1) conduct a fish consumptionsurvey in the vicinity of the site; and 2) determine indoor mercury vapor levels in houses wherepeople who worked in the chlor-alkali unit lived during the time they worked in this unit. HARPrecommended that if exposed populations are identified, TDH should conduct a biologicalindicators of exposure investigation. HARP concurred with TDH that improved warning signs inSpanish and English should be posted and that TDH should provide educational materials to thepublic and physicians (particularly obstetricians) regarding health effects associated withconsuming mercury-contaminated fish and crabs.

Public Health Action Plan

Actions Completed

  1. TDH has maintained a ban on taking fish and crabs from certain areas of Lavaca Bay since1988.

Actions Planned

  1. TDH will notify the public and local physicians of the health hazards associated with consumption of mercury-contaminated fish and crabs. TDH will designate a contact person to respond to physicians' questions and to record information about individuals experiencing adverse health effects potentially associated with exposure to mercury.
  2. TDH will publicize the areas of the Bay which contain fish and blue crabs with concentrations of mercury at levels that could cause adverse health effects (closure area).
  3. TDH will work with ALCOA and EPA to improve the clarity of information and maps posted on the warning signs describing the closure areas of the Bay and will investigate the possibility of improving the markers of the closure area.
  4. ALCOA has contracted with Radian Corporation to complete a fish consumption survey of the area.
  5. TDH will periodically collect additional crab samples from the closure area and analyze them for mercury. TDH will use these data to re-evaluate the current ban on crabs within the closure area and determine appropriate public health actions as necessary.
  6. TDH will recommend that EPA have ALCOA sample additional fish of legal catch size outside closure area (Keller Bay near Rattlesnake Cove), analyze the samples for total mercury, and provide results to the Texas Department of Health/ATSDR for evaluation.
  7. ALCOA will conduct biological monitoring studies on former chlor-alkali plant workers to assess their current exposure to elemental mercury. The results of these tests can be used to indicate whether exposure above normal background is occurring in homes.
  8. TDH will recommend that fish from all parts of Lavaca Bay periodically be analyzed for mercury.
  9. TDH will request to EPA that sediment samples be collected inside the closure area near the Witco dock and analyzed for PAHs and PCBs. Sampling of oysters and fish may be recommended if sediment samples contain elevated concentrations of PAHs and PCBs.
  10. TDH will recommend that EPA test the sediment in the on-site lagoons for mercury and other contaminants.
  11. TDH will recommend that EPA determine the extent to which on-site groundwater contamination is contributing to further contamination of Lavaca Bay.
  12. TDH recommends that demolition and soil moving work in the vicinity of the R-300 (chlor-alkali) building continue to be conducted in accordance with applicable health and safety regulation (29CFR 1910.120).
  13. EPA has requested that the Army Corp of Engineers obtain sediment samples immediatelyprior to and after dredging of the ship channel to determine if mercury is being resuspended.

PREPARERS OF THE REPORT

Susan L. Prosperie, M.S., R.S.
Environmental Quality Specialist
Health Risk Assessment & Toxicology Program

John F. Villanacci, Ph.D.
Director
Health Risk Assessment and Toxicology Program

Kathryn A. Evans, M.P.H.
Epidemiologist
Health Risk Assessment and Toxicology Program

Nancy B. Ingram
Public Health Technician
Health Risk Assessment and Toxicology Program

Laurie B. Wagner
Administrative Technician
Health Risk Assessment and Toxicology Program

ATSDR Regional Representative

George Pettigrew, P.E.
Senior Regional Representative
ATSDR - Region 6

ATSDR Technical Project Officer

William Greim
Environmental Health Scientist
Division of Health Assessment and Consultation

CERTIFICATION

The ALCOA (Point Comfort)/Lavaca Bay Preliminary Public Health Assessment was prepared bythe Texas Department of Health under the a cooperative agreement with the Agency for ToxicSubstances and Disease Registry (ATSDR). It is in accordance with approved methodology andprocedures existing at the time the Assessment was initiated.


William Greim, M.S., M.P.H.
Technical Project Officer
Division of Health Assessment and Consultation
ATSDR

The Division of Health Assessment and Consultation, ATSDR, has reviewed this PreliminaryPublic Health Assessment and concurs with its findings.


Robert C. Williams, P.E., DEE
Director, DHAC, ATSDR


REFERENCES

1. EPA NPL site description dated June 1993.

2. Federal Register. Promulgation of Lavaca Bay to the National Priorities List. February 23,1994.

3. Agency for Toxic Substances and Disease Registry. Consultation: Lavaca Bay, PointComfort, Texas. From Martha D. Kent, ATSDR to Carl Hickam, ATSDR Region 6. July 2,1990,

4. Natural Resource Damage Assessment Pre-Assessment Screening Document, Lavaca Bay -Segment 2453. By Bob Trebatoski and Jim Gooris. July 27, 1990. Texas Water commission.

5. Woodward-Clyde. Chlor-Alkali Site Investigation Plan Summary. Field Sampling Plan. Prepared for Aluminum Company of America. September 1992.

6. Expanded Site Inspection Report. Lavaca Bay. Point Comfort, Calhoun County, Texas. TXD988000600 Revision 1. Prepared for the U.S. Environmental Protection Agency, Region VIby Roy F. Weston, Inc. April, 1993.

7. Texas Department of Health Record of Communication. Susan L. Prosperie, Program ofHealth Risk Assessment and Toxicology to John Mayfield, ALCOA. March 16, 1994.

8. RCRA Facility Assessment, Aluminum Company of America, Point Comfort, Texas. Submitted to EPA Region VI by A.T. Kearney, Inc. and Science Applications InternationalCorporation. September 1988.

9. Texas Department of Health, Division of Shellfish Sanitation. Mercury Concentrations inMarine Organisms of Lavaca Bay. A Report Compiled by the Division of Shellfish SanitationControl of Texas Department of Health. Undated document.

10. HRS documentation record cover sheet. ALCOA (Port [sic] Comfort)/Lavaca Bay. March 19, 1993.

11. Texas Department of Health. Order No. AL-1. Aquatic Life Order issued by Dr. RobertBernstein, Commissioner of Health. April 20, 1988.

12. Texas Department of Health. Record of Communication Files. To the File from Susan L. Prosperie Health Risk Assessment and Toxicology Program. Subject: EPA Open House ALCOA/Lavaca Bay NPL site and Tour of ALCOA facility. April 20, 1994.

13. Agency for Toxic Substances and Disease Registry. Letter To Carl Hickam from Martha D. Kent and Allan S. Susten. Health Consultation Follow-up: Lavaca Bay Site, Point Comfort, Texas. December 31, 1990.

14. Texas Department of Health, Dr. Diane M. Simpson, State Epidemiologist and Associate Commissioner Disease Prevention letter to physicians practicing in the area of Lavaca Bay. Physician education letter regarding dangers of methylmercury and the closure order on part ofLavaca Bay. May 16, 1991

15. The Department of Health and Human Services, Agency for Toxic Substances and Disease Registry. Patricia H. Price, D.O. Division of Health Education, ATSDR and Dr. Michael F.Kelley, M.D., M.P.H. Chief, Bureau of Disease Control and Epidemiology, Texas Department ofHealth to Physicians in the vicinity of Lavaca Bay. near Point Comfort. September 1992.

16. U.S. Department of Commerce, National Oceanic and Atmospheric Administration. October 30, 1990. Issues Regarding Protection of the Lavaca Bay Environment, Texas. JointlyDeveloped by The Natural Resource Trustee Agencies: NOAA, Texas Water Commission andU.S. Dept. of the Interior.

17. U.S. Department of Labor. October 21, 1992. Memorandum for Lavaca Bay Trustees from Gretchen Lucken, Mine Safety and Health Division. MSHA Enforcement Action at ALCOA's Point Comfort Facility.

18. Department of Labor, Mine Safety and Health Administration, Chemical Health HazardEvaluation Point Comfort Alumina Plant. Aluminum Company of America (ALCOA); August25-26, 1992. George W. Weems, Industrial Hygienist. Report is dated September 9, 1992.

18a. ALCOA comments dated February 6, 1995 on draft Public Health Assessment titledALCOA (Point Comfort)/Lavaca Bay NPL site.

19. Federal Mine Safety & Health Review Commission. Dated 10/16/92. Aluminum Company of America, contestant v. Secretary of Labor, Mine Safety & Health Administration (MSHA),respondent. Roy J. Maurer Administrative Law Judge.

20. NIOSH, Health Hazard Evaluation Report. HETA 92-402-2283. Aluminum Company ofAmerica, Point Comfort, Texas. February 1993. NIOSH Investigators: Douglas B. Trout, MD,MHS, Anthony Zimmer, CIH.

21. EPA letter from Allyn M. Davis to Texas Department of Health, Dr. David SmithCommissioner of Health. June 22, 1993. EPA notification that ALCOA (Point Comfort)/LavacaBay, Calhoun County, Texas was proposed for the Superfund National Priorities List in theFederal Register of June 23, 1993 under the Proposed update #15.

22. U.S. Census Bureau. 1990 Census Of Population And Housing Summary Tape File 1A. U.S. Government Printing Office, Washington, D.C., 1990.

23. Texas Department of Health. Record of Communication File. Susan L. Prosperie, TDH to Bill Miller, Calhoun County Health Department. February 9, 1994.

24. Texas Almanac and State Industrial Guide. Eds. Mike Kingston and Mary G. Crawford.1994-1995.

25. Texas Department of Health. Record of Communication File. Susan L. Prosperie, TDH to Ron Weddell, ALCOA. February 24, 1994.

26. Record of Communication File. Texas Department of Health to Texas Parks and Wildlife. Subject: Monthly Marine Products Report for Lavaca Bay. February 17, 1994.

27. Letter from Richard K. Donelson, M.D.; Director, Epidemiology Division TDH to Dr. KirbyJ. Smith, M.D. of Port Lavaca, TX. Letter describing blood mercury results. June 30, 1978.

28. Letter from Charles R. Webb, Jr. M.D., Chief of the Bureau of Communicable DiseaseService, TDH. In response to request from Dr. James P. Parker of LaMarque. Dated May 10,1979.

29. Guidelines--Medical Surveillance and Hygiene Monitoring Practices for Control of WorkerExposure to Mercury in the Chlor-Alkali Industry. Edition 1, October 1977. Partial documentwith attachment: Point Comfort (Chlor Alkali) employee urine mercury test results 1966-1983.

30. ALCOA letter from Mr. Ray Scott to Mr. Ray Austin, Mine Safety and HealthAdministration. February 3, 1994. Third Quarter sampling results for air and urine mercuryconcentrations at the Point Comfort ALCOA Operations.

31. ALCOA letter from Mr. Ray Scott to Mr. Ray Austin, Mine Safety and HealthAdministration. October 26, 1993. Second Quarter sampling results for air and urine mercuryconcentrations at the Point Comfort ALCOA Operations.

32. ALCOA letter from Mr. Ray Scott to Mr. Ray Austin, Mine Safety and HealthAdministration. August 17, 1993. First Quarter sampling results for air and urine mercuryconcentrations at the Point Comfort ALCOA Operations.

33. Letter from Jean Brender, R.N., Ph.D., TDH Director of Environmental EpidemiologyProgram to Ms. Diane Wilson regarding Ms. Wilson's concern about children with mentalretardation in her area. Letter dated April 19, 1991.

34. Texas Department of Health. Record of Communication. Susan L. Prosperie, Program of Health Risk Assessment and Toxicology, TDH to Mr. C.J. Webster, City Manager, City of Port Lavaca, Texas. March 4, 1994. Regarding citizen health concerns associated with the mercury contamination in Lavaca Bay.

35. Memorandum from the Texas General Land Office to John F. Villanacci, Ph.D., DirectorHealth Risk Assessment & Toxicology Program, Bureau of Epidemiology, Texas Department ofHealth. From Ingrid K. Hansen and Leah Tunnell, Legal Services Program, Texas General LandOffice (GLO). Subject: Health information relating to Aluminum Company of America, PointComfort, Texas Facility National Priorities List Site (ALCOA). Undated document.

36. Geochemical and Environmental Research Group, Texas A&M University. Conducted for Formosa Plastics Corporation. An Investigation into Chemical Contamination of Cox Creek andCox Bay, Point Comfort, Texas. Water, Sediment, and Organism Analyses, June 1990. August14, 1990.

37. Woodward-Clyde Consultants. Lavaca Bay Sediment Sampling Data Report Point Comfort, Texas. Draft Report Volumes I and II. Prepared for Aluminum Company of America. November 1992.

38. Woodward-Clyde. Groundwater Data Report. June 1992 Sampling. ALCOA Point Comfort Operations, Point Comfort, Texas. Prepared for Aluminum Company of America. September1992.

39. Woodward-Clyde Consultants. Groundwater Database Report Updated Through February 26, 1993. ALCOA, Point Comfort, Texas. Prepared for Aluminum Company of America. May1993.

40. Department of Labor, Mine Safety and Health Administration, Continuation of Health Hazard Evaluation, Point Comfort Alumina Plant. Aluminum Company of America (ALCOA); September 22-23, 1992. George W. Weems, Industrial Hygienist. Report is dated October 26, 1992.

41. Record of Communication File. Texas Department of Health. Crab Meat Plant Samples for Mercury Analysis and Finfish Market Samples for Mercury Analysis. Two undated tables from the Division of Shellfish Sanitation.

42. Woodward-Clyde. Biological Data Summary Report 1992, Lavaca Bay, Texas. Volumes I and II. Prepared for Aluminum Company of America, Point Comfort, Texas. December 1993.

43. National Library of Medicine. Toxicology Data Network, Toxic Release Inventory 1987,1988, 1989, 1990, 1991. Bethesda, Maryland; NLM, March 1994.

44. Hazardous Substance Data Base: METHYLMERCURY. World Health Organization;Environmental Health Criteria: Mercury p.90-107 (1976).

45. Nordberg, G.F., editor. "Dose Response Relationship of Methylmercury" in Effects and Dose Response Relationships of Toxic Metals. 1976.

46. Clarkson, Thomas. W., Laman Amin-Zaki and Sa'Doun K. Al-Tikriti. An outbreak ofmethylmercury poisoning due to consumption of contaminated grain. Federation ProceedingsVol. 35, No. 12. October 1976. pp 2395-2399.

47. United States Environmental Protection Agency. Guidance for Assessing ChemicalContaminant Data for Use in Fish Advisories. Volume 1. Fish Sampling and Analysis. August1993.

48. Agency for Toxic Substances and Disease Registry. U.S. Public Health Service. Toxicological Profile for Mercury. December 1989 and May 1994.

49. Agency for Toxic Substances and Disease Registry. Department of Health & Human Services. Public Health Service. Memorandum. Issues, Final Toxicological Profile for Mercury. ATSDR Minimal Risk Level (MRL) and EPA Reference Dose (RfD). Richard A. Canady, Ph.D. July 5, 1994.

50. Hudson PJ, Vogt RL, Brondum J, et al., Elemental Mercury Exposure Among Children of Thermometer Plant Workers. Pediatrics, Vol. 79 No. 6: 935-938. June 1987.

SELECTED BIBLIOGRAGPHY REFERENCES
REVIEWED BUT NOT CITED

Agency for Toxic Substances and Disease Registry. U.S. Public Health Service. ToxicologicalProfile for Polycyclic Aromatic Hydrocarbons. December 1990.

Biological Data Summary Report 1992 (DRAFT): Condensed Version, Lavaca Bay, Texas. Prepared for Aluminum Company of America, Point Comfort, Texas. January 1994. Prepared byAquatic Resources Center, Franklin, Tennessee.

Clayton, G. D. and F. E. Clayton (eds.). Patty's Industrial Hygiene and Toxicology: Volume 2A,2B, 2C: Toxicology. 3rd ed. New York: John Wiley Sons, 1981-1982. 1777 pp.

Ecology and Environment, Inc. Memorandum to Ed Sierra, EPA, Region VI RPO, from W.T.Baldwin, FIT Chemist. Status Report, Preliminary Assessment Report Lavaca Bay, PointComfort, Calhoun County, Texas (TXD988000600). December 5, 1990.

Palmer, S.J. Mercury Bioaccumulation in Lavaca Bay, Texas. August 1992. Masters Thesis. Texas A & M University.

Reigel, D.V. The Distribution and Behavior of Mercury in Sediments and Marine Organisms ofLavaca Bay, Texas (December 1990) Masters Thesis. Texas A & M University.

Texas Department of Health. Fish Tissue Sampling Data. 1980-1993. 224pp.

Texas Department of Health Record of Communication File. Susan L. Prosperie, Bureau ofEpidemiology to John Theis, Texas Mental Health Mental Retardation (MHMR). RegardingMHMR numbers for Calhoun County. March 11, 1994.

Texas Department of Health Record of Communication File. Letter to the Texas Department ofHealth from Mr. Lyman T. Mereness. April 21, 1989.

Texas Department of Health Record of Communication File. Letter to Mr. Lyman T. Merenessfrom Mr. Richard E. Thompson, R.S., Director of the Division of Shellfish Sanitation Control. May 31, 1989.

Texas Department of Health Record of Communication File. Letter to John Villanacci, PhD. from Sharon Williams-Fleetwood, Ph.D., Department of Health & Human Services, Agency forToxic Substances and Disease Registry, Division of Health Assessment and Consultation. Regarding Lavaca Bay site visits and preliminary public health assessment. August 31, 1993.

Texas Department of Health Record of Communication File. Videotape from Ron Gouguet ofNOAA to the Texas Department of Health, Program of Health Risk Assessment and Toxicology. Site visit to ALCOA plant and the dredge spoil island. September 27, 1993.

Texas Water Commission. Letter from Clyde E. Bohmfalk, Director of the Water QualityDivision of the Texas Water Commission to Colonel John A. Tudela, District Engineer of theGalveston District SWGCO-RP, Corps of Engineers. Re: Maintenance Dredging of theMatagorda Ship Channel. November 22, 1988.

U. S. Environmental Protection Agency. Superfund Site Strategy Recommendation. Approvedby Betty Williamson 1/10/92. Preliminary Assessment of Lavaca Bay (TXD988000600) PreparedBy W.T. Baldwin, FIT Chemist, Ecology and Environment, Inc. Region VI. To Ed Sierra,Region VI, RPO From W.T. Baldwin, FIT Chemist. March 6, 1991.

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