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The ALCOA (Point Comfort)/Lavaca Bay National Priorities List (NPL) site is in CalhounCounty, Texas, approximately 1.5 miles south of Point Comfort and four miles northeast of PortLavaca. The site includes areas associated with current and former operations of the AluminumCompany of America (ALCOA) Point Comfort plant and a section of Lavaca Bay adjacent toALCOA which has been contaminated with mercury. Fish sampling data indicate that levels ofmercury in fish are elevated. Since eating fish contaminated with mercury at the concentrationsobserved at this site may potentially affect the developing fetus, and the potentially exposedpopulation includes women of childbearing age, we have classified this site as an urgent publichealth hazard.

Because of the levels of mercury found in fish sampled near the ALCOA Point ComfortOperations, a portion of Lavaca Bay was closed to the taking of finfish and crabs by the TexasDepartment of Health in April of 1988. People who ate contaminated fish, crabs and oysters inthe past as well as people who currently eat contaminated fish and crabs from the closure areamay be exposed to excessive amounts of mercury.

Based on the amount of mercury in these fish, pregnant women should not eat more than 5ounces of fish taken from the closure area per month; that is less than one meal of fish from theclosure area per month. Children would experience an increased risk for adverse health effectsfrom eating as little as 1.4 ounces of fish per month caught from the closure area.

ALCOA operated an aluminum smelter at this site from 1948 until 1980; currently, the primaryactivity at the site is bauxite refining. Mercury contamination originated primarily from the chlor-alkali unit at ALCOA which operated from 1965 until 1979. This unit used mercury to producechlorine gas and sodium hydroxide. As a result, approximately 67 pounds of mercury per daywere discharged into the bay prior to 1970.

Mercury has been detected throughout the site in surface soil, shallow groundwater, air, baysediments, fish and crabs. Other contaminants, including volatile organic compounds (VOCs) andlead, have been detected in shallow groundwater. Polychlorinated biphenyls (PCBs) andpolycyclic aromatic hydrocarbons (PAHs) have been detected in a limited number of sediment,fish, and oyster samples; additional sampling is planned.

The Texas Department of Health (TDH) Division of Shellfish Sanitation (recently renamedDivision of Seafood Safety) has sampled fish, crabs, and oysters from this area since the 1970s. In the early 1970s, mercury levels in oysters and crabs were significantly elevated. Based on thesefindings TDH closed parts of Lavaca Bay to the harvesting of oysters; at that time, TDH did nothave the authority to prohibit crabbing or fishing. The Texas Department of Health orderestablishing areas which are prohibited and unsatisfactory for the taking of aquatic life that is unfitfor human consumption (specifically finfish and crabs) was issued in April of 1988.

Based on reports that chlor-alkali unit workers observed pooled mercury in work areas, it is likelythat exposure to mercury vapor via inhalation occurred in the past. Due to the absence of ambientair data collected while the unit was operating, we were unable to quantify this exposure. However, according to ALCOA, biological monitoring results for workers in the chlor-alkali unitwere used to monitor employee exposures and make decisions about removing employees fromthat work unit.

Residents of the Point Comfort area have raised several questions about the potential for adversehealth effects among former ALCOA workers, people engaging in recreational activities atLavaca Bay beaches, and people consuming seafood from the closure area and other parts ofLavaca Bay. The Public Health Implications section of this Health Assessment contains detailedanswers to these questions.

TDH has made the following recommendations: fish and crabs taken from the closure area shouldnot be eaten, maintain the current crabbing and fishing closure which was issued in 1988; improvethe markers which designate the closure area; publicize information on dangers of eatingcontaminated fish as well as the location of the closure area; and provide information to localphysicians on the health effects of mercury exposure. TDH has also recommended conductingadditional site characterization activities and evaluating the potential public health implications ofthe site as additional sampling data become available for review.


The Agency for Toxic Substances and Disease Registry (ATSDR) is a Federal agency within theDepartment of Health and Human Services authorized by the Comprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980 (CERCLA) to conduct public healthassessments for National Priorities List (NPL) hazardous waste sites. In cooperation withATSDR, the Texas Department of Health (TDH) has reviewed available data to evaluate thepublic health significance of the ALCOA (Point Comfort)/Lavaca Bay NPL site. Morespecifically, ATSDR and TDH have determined whether adverse health effects from exposure tosite contaminants could occur and have recommended actions to reduce or prevent such healtheffects.

A. Site Description and History

The ALCOA (Point Comfort)/Lavaca Bay National Priority List (NPL) site is approximately 1.5miles south of Point Comfort and four miles northeast of Port Lavaca in Calhoun County, Texas(Figure 1). The site includes the ALCOA (Point Comfort) plant grounds, the former smelter areapart of which is owned by Formosa Plastics, Inc., the Witco dock area, the dredge spoil islandwest of the ALCOA plant, and a section of Lavaca Bay adjacent to ALCOA (Figure 2).

ALCOA is currently operating; bauxite ore is refined to alumina. ALCOA is in an industrialcomplex just south of the State Highway 35 which connects the towns of Point Comfort and PortLavaca via a causeway over Lavaca Bay. The industrial complex is on the Bay's east centralshore and includes Formosa Plastics, Inc., unloading docks used by ALCOA and Formosa, theE.S. Joslin Power Station, a railroad spur, and numerous facilities currently and formerlyassociated with ALCOA operations. Numerous large lakes and closed hazardous waste landfillsused by ALCOA for processing, storage, and disposal of waste materials are located on theeastern side of the industrial complex.

The dredge spoil island associated with ALCOA is in the Bay approximately 1,200 feet west ofthe plant. The 500-acre island was constructed by ALCOA in 1950 with materials from periodicdredging of the ship channel; it includes a 91-acre lagoon and five smaller lagoons that coverapproximately 50 acres which were used for disposal of gypsum wastewater from ALCOAprocesses [1, 2].

Lavaca Bay is part of the Matagorda Bay system on the middle Texas coast. The Bay averages12.5 miles in length, 4.5 miles in width, and one to seven feet in depth except where it has beendeepened to accommodate ship traffic. Ship channels serving ALCOA and the industrial complexare fifteen and thirty-five feet deep, respectively [3, 4].

ALCOA has been conducting operations at Point Comfort since 1948. The plant originated as analuminum smelter. Primary activities currently include bauxite refining and production ofaluminum fluoride. A carbon plant operates intermittently to produce carbon briquettes. Bauxiterefining began in 1958 [5]. Other operations at ALCOA have included a cryolite (sodiumaluminum fluoride) plant (1962-1979), a chrome plating operation (dates of operation unknown),and the chlorine-alkali (chlor-alkali) plant (1965-1979) [6]. ALCOA also operated the Neumingas plant from 1957 until 1989. In 1989 the Neumin gas plant area and part of the smelter areawere sold by ALCOA and are now owned by Formosa Plastics.

The ALCOA Point Comfort plant includes unloading docks, several inland dredge and wastewaterdisposal lakes, bauxite ore storage lots, numerous storage tanks, towers, buildings, and otherstructures. The industrial complex also contains a power generating station, a vacant buildingformerly owned by Witco Chemicals, and the site of the smelter and the disassembled chlor-alkalifacility formerly operated by ALCOA. The building which housed this process is still standing[7].

Mercury contamination of the site has been attributed to wastewater discharges from the chlor-alkali unit. ALCOA estimated that prior to 1970 at least 67 pounds of mercury per day weredischarged into the Bay and that an additional 89 pounds of mercury per day were released intothe atmosphere. Between 1970 and 1979, mercury discharges to the Bay were reduced toapproximately 13 pounds per day and releases to the atmosphere were reduced to approximately60 pounds per day. During this period, wastewater was discharged to on-shore lakes for re-use inplant processes [4].

In addition to wastewater discharges, mercury-contaminated solids, washdown water, filtermaterials, and equipment were stored or disposed of in various areas of the site, including severalon-shore lakes, the chlor-alkali lagoon, the dredge spoil island, and hazardous waste landfills [8]. The chlor-alkali plant was closed in 1979. In 1986 the chlor-alkali equipment was removed;however, several support buildings and the building that contained the mercury-cells from whichcontaminants originated remain [4].

Anecdotal evidence and historical records suggest that inhalation of mercury vapor by workersmay have occurred while the chlor-alkali unit was operating (1965 -1979); workers sometimeshad to wash down brine and mercury from the floor of the chlor-alkali building [7, 35]. Additionally, in the past, workers reported observing pooled mercury in the chlor-alkali area. During this time, it is possible that workers in the chlor-alkali plant inadvertently transportedmercury to their homes on contaminated clothing. This type of occurrence has been documentedin mercury thermometer manufacture [50]. Former ALCOA employees have anecdotally reported finding mercury in their washing machine drains and traps.

Numerous state and federal agencies have conducted investigations and issued health and safetyrecommendations related to mercury contamination at this site. In 1970, the Texas Water QualityBoard issued an Emergency Order against ALCOA finding them responsible for mercurydischarged to an off-shore disposal lagoon on the dredge spoil island [4]. TDH initiated seafoodsampling in Lavaca Bay in 1970, at which time samples indicated significantly high mercury levelsin oysters and crabs but not in shrimp; finfish were not sampled. In July of 1970, under theauthority of the Shellfish Law, TDH closed the affected areas of Lavaca Bay to the harvesting ofshellfish (i.e. oysters). At that time, TDH did not have authority to close the area to the taking ofcrabs or finfish, but the Department continued to monitor mercury levels in seafood. The ban onoystering was lifted in October 1971 when the levels of mercury dropped below the 0.5 ppm FDAguideline. Mercury levels in blue crab remained high and TDH made a public statement warningthat consumption of blue crab might be dangerous to humans [9].

Based on results of on-going sampling, TDH again issued public health warnings in 1978 and1981 that consumption of seafood taken from parts of Lavaca Bay was dangerous to humanhealth [10]. TDH increased sampling in 1987-88 [4]. On April 20, 1988, the Commissioner ofHealth issued a measure prohibiting the taking of finfish and crabs from a specific part of LavacaBay (Texas Department of Health Aquatic Life Order 1) [11], which remains in effect. Oysteringand shrimping were not prohibited [10].

The closure area is seaward from the Highway 35 Causeway and includes the "area of Lavaca Bayinshore of a line drawn from the southwestern most point of land at Cox Point to channel markerMK #74, thence in a northwesterly direction to Channel MK #12, and thence in a northerlydirection to the last part of land at the northeastern approach of the State Highway 35 Causeway,as outlined on the map dated April 21, 1988 [11]." These boundaries, shown in Figure 3, wereestablished based on a plot map of the locations where fish samples with elevated mercury levelswere caught and the use of structural landmarks that would be readily recognizable by individualswho fished the area [12].

In June of 1990, the National Oceanic and Atmospheric Administration (NOAA) requested thatATSDR investigate the potential human health threats associated with consumption of fish andshellfish harvested from Lavaca Bay. After reviewing sampling data from the TDH Division ofShellfish Sanitation Control, ATSDR concluded that the ban on finfish and crabs should becontinued, access to contaminated areas of the site should be restricted, information about thedangers of mercury exposure should be disseminated, and that fish sampling in the Lavaca Bayregion should be continued [3, 13]. ATSDR also recommended continuing the fishing and crabbing ban in areas that show mercury levels in fish above the revised FDA guideline of 1 ppm [10].

In October of 1990, NOAA expressed concern about elevated levels of polycyclic aromatichydrocarbons (PAHs) in sediments, surface waters and tissues of fish and shellfish [16]. TheTexas Water Commission (TWC) identified Witco Chemical Company as a likely source ofcreosote and its polycyclic aromatic hydrocarbon (PAH) constituents. NOAA recommended thatALCOA should be required to implement a sediment sampling plan to delineate the extent ofmercury and PAH contamination, its potential for migration, and its bioavailability and toxicity. NOAA also recommended that a remedial investigation and feasibility study (RI/FS) leading to aRecord of Decision (ROD) be performed to identify a remediation alternative which would beprotective of the environment [16].

In 1991, TDH and ATSDR provided information on mercury toxicity to physicians in Calhounand Victoria counties and encouraged physicians to inform pregnant patients and parents of youngchildren about the potential health risk associated with consumption of mercury-contaminated fish[14, 15].

In August of 1992, the Mining Safety and Health Administration (MSHA) conducted aninspection of ALCOA in response to an employee's complaint of exposure to mercury. MSHAfound mercury in the soil near the chlor-alkali (R-300) building at levels between 2.6 mg/kg and52 mg/kg. MSHA cited ALCOA for safety violations including: failure to post warning signsidentifying a mercury hazard, failure to label the mercury storage containers, failure to useappropriate personal protective equipment, failure to monitor for mercury [17, 18]. MSHA alsoissued a Section 103(k) Accident Control Order requiring ALCOA to provide personal protectiveequipment, implement decontamination and mercury monitoring procedures, and to clean up thearea [17, 19]. ALCOA complied with abatement actions [18A]; the 103(k) order was contested by ALCOA and was vacated.

On October 14-15 1992, investigators from the National Institute of Occupational Safety andHealth (NIOSH) conducted urinalyses for workers thought to have the greatest potential formercury exposure. These tests found that workers tested had not had mercury exposure aboveusual background levels within the previous two to four months [20]. ALCOA performed airsampling and urinalysis of workers. These analyses indicated that mercury exposures above usualbackground exposures were not occurring.

ALCOA (Point Comfort)/Lavaca Bay, Calhoun County, Texas was proposed for the SuperfundNational Priorities List in the Federal Register of June 23, 1993, under the Proposed update #15[21]. The site was added to the General Superfund Section effective March 25, 1994 [2].

B. Site Visit

On January 19 and 20, 1994, Texas Department of Health representatives John F. Villanacci,Ph.D., and Kathryn A. Evans, M.P.H., of the Health Risk Assessment and Toxicology Program,along with Kirk Wiles of the Shellfish Sanitation Program, conducted a site visit at the ALCOA(Point Comfort)/Lavaca Bay National Priorities List (NPL) site. During this site visit, we metwith EPA and ALCOA representatives for approximately two hours and spent three to four hoursconducting a limited survey of the ALCOA facility, the nearby residential neighborhood in PointComfort, and the surrounding areas of Point Comfort and Port Lavaca. An additional two tothree hours were spent touring the Bay around ALCOA by boat. Kirk Wiles, who has worked onfish consumption safety issues in the Lavaca Bay area since the 1970s, guided the boat tour andwas available to answer questions about both the physical layout and history of the site. KirkBarringer and Patrick Cruz, representatives of the TDH Region 8 office of the Seafood SafetyDivision, also were available to answer questions.

The ALCOA plant complex is surrounded on the south and west by Lavaca Bay. The landnortheast of the complex, adjacent to the disposal lakes, is used for cattle grazing. HuisacheCreek flows from north to south across this cattle field and contains areas of ponded water. Theextensive industrial facilities of Formosa Plastics Corporation are across the street from this openland, on the north side of Highway 35.

Two roads from Highway 35 connect to a main road which provides access to ALCOA. Onlyemployees are allowed to access most areas of the industrial complex. The general public's accessis limited by both the natural geography and by fences around most of the operational facilities.

Several, large, uncovered piles of bauxite ore were stored at the southern end of the site. Equipment used to unload the ore from ships in the Bay is located in this area. A large barge wasbeing unloaded when we toured the Bay by boat on January 20, 1994. We noticed that mostoutdoor surfaces of the on-site buildings, fences, and equipment on and around ALCOA werecoated with a layer of reddish dust similar in color to the bauxite ore.

The area of Lavaca Bay in which the taking of finfish and crabs is banned is easily accessible tothe general public by boat. Part of this closed area is accessible along the south side of the StateHighway 35 Causeway on the side facing the ALCOA plant; it is possible to drive a car along theold causeway at the water's edge. It was raining and very cold during our visit and we did not seeanyone fishing, but we did see fishing lines, bait containers, and other evidence that people fish inthis area.

We found a line of approximately ten crab traps in the Bay within the restricted area and a trapthat contained live crabs. Mr. Barringer and Mr. Cruz indicated that fishing and crabbing withinthe restricted area is common. Mr. Wiles explained that many areas within the area closed to thetaking of fish and crabs are especially attractive for winter fishing because their deep waterssupport extensive fish populations in cold weather. Summer is the primary season for crabbing.

A shrimp boat was dragging a shrimp net along the bottom of the Bay in the closure area. Although shrimping is not prohibited, it was obvious that this activity was disturbing the sediment. While mercury contamination has not been found in oysters in recent years, we were told thattaking oysters from the Bay is sometimes prohibited due to bacteriological contamination. TheTDH Division of Shellfish Sanitation routinely monitors the bacteriological quality of the oystersin the Bay.

The channel just outside the closure area was being dredged under the authority of the ArmyCorps of Engineers. A barge, using a cutting tool and a system of pipes with hydraulic suction,was dredging sediment from the bottom of the channel and depositing it at the end of a pipelineapproximately 300 yards away. Several spoil piles were visible at the water's surface behind thepipeline.

Large warning signs explaining the ban on taking of fish and crabs from the area were posted atfour (originally five) locations near boat ramps and fishing areas. The signs state, "Catch andrelease for fish and crabs from the prohibited area shown on the map. Fish and crabs may becontaminated by mercury. Consumption of fish or crabs from the prohibited area may bedangerous to your health. Retaining fish or crabs from the prohibited area punishable by a fine ofup to $500.00. Texas Department of Health Shellfish Sanitation Division (512) 458-7510." TheDivision is now called the Division of Seafood Safety and the phone number is (512) 719-0215. A large color map of the Bay designating the restricted area is posted on each sign. The warningsigns are posted on state property at Chocolate Bay, Keller Bay, Port Lavaca Causeway StatePark, and the northeastern end of the causeway. The sign formerly posted at the Harbor ofRefuge boat ramp blew down in a storm approximately one and a half years ago and has not beenreplaced. Signs have not been posted at several boat ramps that provide access to the Bay,including the popular boat ramp northeast of the causeway near Formosa and the boat rampnorthwest of the causeway in Port Lavaca.

Port Lavaca Causeway State Park, with facilities for approximately 30 recreational vehicles, is atthe southwestern end of the causeway. The park was approximately 50% occupied by in-stateand out-of-state vehicles. A long fishing pier extends from the park area into the Bay beneath thecauseway next to the Noble Point boat ramp. A long boardwalk with a gazebo is situated in theBay to the south of the state park. We saw no evidence of fishing from the pier or the boardwalk,but we were told that the pier is a popular fishing area. Neither location is in the closure area.

The Town of Point Comfort is centralized in an area approximately one mile north of ALCOA,just north of Highway 35. The town is laid out on a grid of primarily residential secondary streetswith modest, single-family dwellings. We also saw a church, a school, and a day care center. Apark with a swimming pool, playground, and boat ramp is on the northwest side of town withinwalking distance from most of the houses.

Formosa's permitted discharge point is in the Bay several hundred yards from the Point Comfortneighborhood. The discharge point is designated by two buoys (each marked with an "x").

On April 19, 1994 Kathryn Evans, M.P.H., and Susan L. Prosperie, M.S., R.S., of TDHconducted a second site visit which included a tour of ALCOA facilities and attended an InformalOpen House sponsored by EPA at the Bauer Community Center in Port Lavaca. While in thearea, we saw a man fishing in the closure area from the old causeway and spoke with two menwho told us they had been fishing. TDH's fishing advisory warning sign was posted and readilyvisible at the entrance to this area.

An Environmental Professional, employed by ALCOA, guided our 2.5-hour tour of ALCOAfacilities and answered questions. We drove or walked through most of the major productionareas of the plant. We also observed facilities and stained areas associated with ALCOA's pastproduction of carbon briquettes, caustic soda, chlorine gas, and other materials.

We saw the area where bauxite ore imported by ALCOA from various parts of the world isunloaded from ships onto a conveyor system. The ore is stored in huge, uncovered piles and thenblended. Workers in this area were driving heavy equipment with enclosed cabs. Ore also isstored in large buildings in this area until it is processed.

The refining process includes crushing and digesting (heating to a high temperature with caustic)the bauxite mixture. The alumina is separated from mud and other undissolved residue usingclarifiers or thickeners, which are large tanks with arms that turn slowly, collecting the solids. The mud waste product from this process is stored in the Mud Lakes on the eastern edge of thesite. The supernatant which contains the alumina is precipitated to remove the liquid from thealumina which is then "calcined" by heating at a high temperature in a rotary kiln. Machinescalled shakers are used to separate the alumina fines from larger particles. We saw one shaker ina partially-enclosed building; alumina covered the concrete floor and the area was full of finewhite dust. This process is partially automated and we did not see any workers.

Many of the other processes also are automated and most of the process areas were noisy, dusty,and hot. We observed several workers in the outdoor areas, most of whom were using earplugsand eye protection. We also went into one of the control rooms where workers monitor plantprocesses; this room was quiet, cool, and free of dust.

We drove along roads atop the berms of Mud Lakes #1, #2, #3, and #4. We were able to see theMud Lakes as well as Clear Lake, Recycle Lake, and Dredge Lake, which also have been used inALCOA processes. The lakes had varying water levels with reddish mud visible at the bottom ofsome of the drier lakes. The berms are above the 100-year flood plain, but the lakes are unlined. The ALCOA representative noted that at least one closed hazardous waste landfill is located nearthe lakes.

We drove through the area formerly associated with the chlor-alkali facility. The only remainingbuilding was R-300, which formerly housed the mercury cathodes. The entrances to this buildingwere barricaded and marked with signs stating "NOTICE: Mercury can collect at this location. Ifobserved, notify supervisor." We walked around this area and did not notice any mercury. (Wehave viewed a videotape prepared during the September 27, 1993 site visit by NOAA and EPAthat shows visible droplets of mercury on concrete in the chlor-alkali area). We saw two menworking to break up the concrete pad adjacent to the building. One man was using a forklift, theother was using a backhoe with an open cab; neither man was using respiratory protection. ALCOA indicated that surveillance monitoring conducted in accordance with the Health andSafety plan indicated there was no need for respiratory protection during these activities.

We drove by the old Witco dock area where raw materials came in for production of carbonbriquettes from coal tar pitch and coke. The carbon was used for smelting pots once operated byALCOA at the site.

From 5:30 to 7:00 pm, we attended EPA's Informal Open House at the Bauer Community Centerin Port Lavaca. Representatives from EPA, Texas Natural Resource Conservation Commission(TNRCC), NOAA, and TDH attended. Approximately 35 people from the community includingPort Lavaca city officials, a county judge, and former ALCOA employees also attended. Oneretired ALCOA employee, who attended the open house, reported that he had been diagnosedwith a neurological disorder of unknown cause.

C. Demographics, Land Use and Natural Resources Use


According to the 1990 census [22], 19,053 individuals live in Calhoun County in 7,666households. The two major population areas are the towns of Port Lavaca and Point Comfort. Sixty-one percent of the population have lived in the same house since 1985. Persons 18 years ofage and under comprise 29.5% of the population; persons 65 years and over comprise 11.0% ofthe population. Approximately 4,002 women (41.6%) are of childbearing age (15-45 years). Theracial make up of Calhoun County is 77.8% white, 2.9% African American, 0.2% Indian, 2.9%Asian or Pacific Islander, and 16.2% other races. Persons of Hispanic origin make up 36.2% ofthe total population.

Port Lavaca, which is four miles southwest of the site, has a population of 10,886 people who livein 3,783 households. Approximately 31% of the total population are 18 years of age andyounger; approximately 10% are 65 years and over. The racial make up of Port Lavaca is 71.3%white, 4.7% African American, 0.2% Indian, 3.0% Asian or Pacific Islander, 20.8% other races. Approximately 47% of the total population are of Hispanic origin.

Point Comfort, which is 1.5 miles northeast of the site, has a population of 956 people who live in360 households. Approximately 27% of the total population is comprised of people 18 years ofage and younger; approximately 12% of the total population is made up of people 65 years of ageand older. The racial make up of the Point Comfort population is 92.7% White, 0.2% AfricanAmerican, 0.1% Indian, 1.8% Asian or Pacific Islander, and 5.2% other races. Approximately12% of the total population are of Hispanic origin.

In Calhoun county eight percent of employed persons age 16 and over are employed in agricultureand fisheries. Approximately 19% of the population lives in a household with an income belowthe federal poverty level. The ALCOA plant has 1,080 employees, not all of whom live inCalhoun county.

Point Comfort has two licensed day care centers, the United Methodist Church (licensed for 40children, with 26 enrolled as of August 1993) and Village Daycare (licensed for 12 children, with10 enrolled as of March 1993). The county has one nursing home, which is across the Bay fromFormosa Plastics in the City of Port Lavaca [23].

Land Use and Natural Resources Use

The nearest residential area from the site is the City of Point Comfort with a population of 956people. The nearest recreational areas are the beaches along the western side of Lavaca Bay atPort Lavaca. In addition there is a boat ramp to the Bay in Point Comfort. The area in theimmediate vicinity of the site is industrial. ALCOA employs approximately 1,080 people [25];Formosa Plastics Corporation employs at least 1,000 people. Rice and cotton farming, cattlegrazing, and commercial fishing also are economic factors in the county [24]. The climate inCalhoun county is warm and humid with a total rainfall of approximately 39.4 inches per year;temperatures range from 47 to 92oF [24].

In the past the City of Point Comfort and ALCOA obtained drinking water from water wellslocated eight miles east of Point Comfort. These wells are screened in the Chicot aquifer atdepths of approximately 500 to 1,200 feet. According to the Hazard Ranking System, these wellsare the closest potable groundwater wells to the NPL site [10]. In February of 1995 the City ofPoint Comfort began using surface water from Lake Texana (Lavaca-Navidad River Authority). The City of Port Lavaca obtains drinking water downstream of the confluence of the Guadalupeand San Antonio Rivers [10]. A well inventory is available; however, current well usage shouldbe determined.

Shallow groundwater is approximately 14 to 20 feet below the surface in most areas of Calhouncounty, but is of poor quality primarily due to high levels of sodium (3,000-6,000+ ppm) andchlorides (6,500 to 40,500 ppm) [6]. Groundwater generally flows from east to west from thesite into Lavaca Bay, but also may flow south and east into Cox Bay and Cox (Huisache) Creek[6].

People fish the area both commercially and for recreation. Commercial seafood dealers (who mayhave their own fleet of fishing boats or who may buy fish from independent fishermen) arerequired to submit a monthly marine products report of pounds of seafood harvested from coastalbays to Texas Parks & Wildlife Department (TPWD) [26]. For 1991, reports to TPWD for all parts of Lavaca Bay included no finfish, 308,754 pounds of blue crabs, and 20,109 pounds ofoysters. In 1992, TPWD records included reports of no blue crabs, no finfish, and 56,562 poundsof oysters.

During the Expanded Site Inspection sampling event conducted in April 1993, EPA's contractorobserved both recreational and commercial fishing near the ALCOA plant and near the arearestricted to the taking of fish and crabs [6].

D. Health Outcome Data

TDH staff reviewed historical records and made numerous requests to determine whether humanbiological monitoring had been conducted among individuals who may have been exposed tomercury from this site. TDH staff obtained and reviewed records from TNRCC, EPA, MSHA,ALCOA, and the Texas General Land Office, as well as TDH's Bureau of Epidemiology andDivision of Shellfish Sanitation. In addition, TDH staff conducted a library literature search forinformation related to this site and requested information from the local health department and themedical officer for Calhoun county.

The only available medical data include TDH records of serological surveys conducted in 1978and 1979 [27, 28; ALCOA's historical records of employee urine mercury tests [29]; andALCOA's recent quarterly reports of employee urine mercury test results to their MercurySurveillance Program [30, 31, 32]. These limited data and their relevance to the site will be presented and discussed in the Health Outcome Data Evaluation section of this report.


In an effort to determine community health concerns, we contacted ATSDR, Region VI, UnitedStates Environmental Protection Agency (U.S. EPA), the Texas Natural Resource ConservationCommission (TNRCC), the Calhoun County Health Department, Texas Parks and WildlifeDepartment, Mining Safety and Health Administration, and the Texas General Land Office. Wespoke with the principal of the Point Comfort Elementary School, representatives from ALCOA,a Sierra Club member, a representative from the Calhoun County Resource Watch group, the CityManager of the City of Port Lavaca, the Marine agent for the Texas Agricultural ExtensionService, staff from the TDH Divisions of Occupational Health and Shellfish Sanitation (SeafoodSafety), a former worker at ALCOA, and citizens attending the EPA Open House on April 19,1994.

The following health-related concerns, which will be addressed in the Public Health Implicationssection of this health assessment, were obtained:

  1. Is the number of children with mental retardation in the area higher than would be expected [33]?
  2. Is the number of miscarriages in the area higher than in other areas?
  3. Are the Port Lavaca beaches: Lighthouse Beach and Magnolia Beach, safe to take our children to for water-based recreation [34]?
  4. Could the reported worker health problems be due to exposure to site contaminants [35]?
  5. How was the restricted fishing area defined?
  6. Is it okay to eat fish caught just outside the restricted area?
  7. Why would contamination in fish be limited to that area?
  8. Maps on closure signs are too hard to read. Can you describe the closure area more clearly?

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