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PUBLIC HEALTH ASSESSMENT

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



ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

The tables in this section list the contaminants of concern. We evaluate these contaminants in the subsequent sections of the public health assessment and determine whether exposure to them has public health significance. This public health assessment selects and discusses these contaminants based upon the following factors:

  1. Concentrations of contaminants on and off the site.

  2. Field data quality, laboratory data quality, and sample design.

  3. Comparison of on-site and off-site concentrations with background concentrations, if available.

  4. Comparison of on-site and off-site concentrations with public health assessment comparison values for (1) noncarinogenic endpoints and (2) carcinogenic endpoints.

  5. Community health concerns.

In the data tables that follow under the On-site Contamination and the Off-site Contamination subsections, the listed contaminant does not mean that it will cause adverse health effects from exposures. Instead, the list indicates which contaminants will be evaluated further in this Public Health Assessment. When selected as a contaminant of concern in one medium, that contaminant will be reported in all media.

The data tables include the following acronyms:

  • CREG
  • = Cancer Risk Evaluation Guide
  • EMEG
  • = Environmental Media Evaluation Guide
  • RMEG
  • = Reference Dose Evaluation Guide
  • MCLG
  • = EPA Maximum Contaminant Level Goal
  • MCL
  • = EPA Maximum Contaminant Level
  • PMCLG
  • = EPA Proposed MCLG
  • PMCL
  • = EPA Proposed MCL
  • RfD
  • = EPA Reference Dose
  • LTHA
  • = EPA Lifetime Health Advisory
  • PPM
  • = Parts Per Million
  • PPB
  • = Parts Per Billion

    Comparison values for public health assessment are contaminant concentrations in specific media that are used to select contaminants form further evaluation. These values include EMEGs, CREGs, and other relevant guidelines. CREGs are estimated contaminant concentrations based on a one excess cancer in a million persons exposed over a lifetime. CREGs are calculated from EPA's cancer slope factors. EPA's MCLG is a drinking water health goal. EPA believes that the MCLG represents a level that no known or anticipated adverse effect on the health of persons should occur which allows an adequate margin of safety. PMCLGs are MCLGs that are being proposed. MCLs represent contaminant concentration that EPA deems protective of public health (considering the availability and economics of water treatment technology) over a lifetime (70 years) at an exposure rate of 2 liter water per day. While MCLs are regulatory concentrations, PMCLGs and MCLGs are not. EPA's RfD is an estimate of the daily exposure to a contaminant that is unlikely to cause adverse health effects.

    A. On-site Contamination

    All data in the On-Site and Off-Site Contamination sections are derived from the December 1990 RCRA RFI, unless otherwise noted.

    Toxic Chemical Release Inventory Data (TRI)

    Project Staff conducted a search of EPA's Toxic Chemical Release Inventory (TRI) for the years 1988 and 1989. The search included a 2-mile radius from the site. TRI recorded seven compounds for KII-F: anthracene, dibenzofuran, naphthalene, pentachlorophenol, phosphoric acid, arsenic, chromium, and copper. TRI lists the disposal for many of these compounds to Two Mile Creek by stormwater run-off.

    Groundwater

    The RFI reports sampling of on-site groundwater in August, November, and December of 1989. In August 1989, groundwater samples were collected from all existing on-site and off-site monitoring wells and all recovery wells. The Keystone laboratory analyzed these samples for total arsenic, dissolved arsenic, total chromium, dissolved chromium, hexavalent chromium, total mercury, dissolved mercury, volatile aromatic compounds, acid extractable phenolics, total phenols, and polycyclic aromatic hydrocarbons (PAHs) (19).

    Seven monitoring wells were installed in September 1989. In November 1989, the monitoring wells and selected other wells were sampled for the same compounds as in August and for copper and mercury. In December 1989, the RFI re-sampled four on-site shallow wells in order to confirm previous testing (19).

    These three RFI sampling rounds were evaluated and are presented in this Public Health Assessment. All groundwater samples were collected by Keystone Environmental representatives and analyzed by Keystone's Analytical Division. Table 2 summarizes the range of chemical concentrations detected in these sampling rounds.

    TABLE 2: ON-SITE GROUNDWATER CONTAMINANTS OF CONCERN
    MAXIMUM CONCENTRATIONS, MONITORING AND RECOVERY WELLS
    AUGUST AND DECEMBER 1989 (19)

    Contaminant Groundwater Zone (ppb) Recovery
    Wells
    (ppb)
    Comparison
    Value
    (ppb)
    A and B C and D
    Benzene 715 ND 670 1 CREG
    Ethylbenzene 3,290 ND 555 700 LTHA
    Pentachlorophenol 40,000 2.87 110,000 0.3 CREG
    2,3,5,6-Tetrachlorophenol 4,200 ND 33,400 No Value
    2,4,6-Trichlorophenol 723 4.66 6,220 3 CREG
    2,4-Dichlorophenol 1,560 10.3 17,000 20 LTHA
    2,4-Dimethylphenol 308 ND 2,460 No Value
    2,4-Dinitrophenol 47,000 ND 243,000 No Value
    2-Chlorophenol 817 ND 3,230 40 LTHA
    2-Methyl-4,6-dinitrophenol 5,820 2.16 69,000 No Value
    4-Chloro-3-methylphenol 1,970 2.03 1,730 No Value
    4-Nitrophenol 16,300 4.99 128,00 60 LTHA
    2-Nitrophenol 158 ND ND 60 LTHA
    Phenol 28,800 3.97 20,000 6,000 RMEG
    Polycyclic Aromatic Hydrocarbons 455,000 626 5,670,000 No Value
    Arsenic 684 ND 78.8 0.000006 CREG
    Dissolved Arsenic 128 ND 21.6 0.000006 CREG
    Chromium 2080 11.7 119 100 MCL
    Dissolved Chromium 10 ND ND 100 MCL
    Hexavalent Chromium 41.4 0.012 20 50 EMEG
    Copper 45.4 ND
    -
    1,300 MCL
    Dissolved Copper 25.5 ND
    -
    1,300 MCL
    Mercury 25.6 0.38 4.28 2 MCL
    Dissolved Mercury 3.1 ND 3.61 2 MCL
    Dioxins and Furans ** 0.00166
    -
    -
    -
    ND - Not Detected
    ** - Dioxin and Furan results are from a sample of six on-site monitoring wells.


    Soil

    Soil boring samples were collected from twelve Solid Waste Management Units (SWMUs) in August and September 1989. These samples were collected at two feet intervals from areas that were most likely to be contaminated (the closed creosote lagoon, the abandoned landfill, the drip track area, the former spray-field, the existing spray-field, and the former pentachlorophenol pond) (19). The samples were not representative of surface soil samples. ATSDR defines surface soil as soil from 0" to 3" in depth. Surface soil samples are needed for the evaluation of public health impact associated with exposures to contaminants in this media. In the absence of this data, chemical data for deeper soils may suggest the possibility of human exposure and the development of toxicity. This method, however, only provides a tentative evaluation. A "background" soil sample was collected from near the plant office and was designated to be a background sample; however, this sample may not be representative of a true background sample.

    Visual contamination guided the selection of soil samples. The Keystone Environmental Division laboratory performed the analyses including pH, total recoverable phenols, acid extractable phenolics, oil and grease, PAHs, arsenic, copper, chromium, and mercury. Selected samples were also analyzed for hexavalent chromium, and dioxins and furans (19).

    The highest levels of carcinogenic PAHs were found in the old creosote lagoon. Table 3 presents the contaminants of concern identified for this media.

    TABLE 3: SUBSURFACE SOIL SAMPLES - 0 TO 8 FOOT DEPTH
    1989 KII-F RCRA FACILITY INVESTIGATION (19)

    Contaminant Concentration Range-ppm Comparison Value-ppm
    Pentachlorophenol ND - 2,230 No Value
    2,3,5,6-Tetrachlorophenol ND - 332 No Value
    2,4,6-Trichlorophenol ND - 101 No Value
    2,4-Dichlorophenol ND - 68.8 No Value
    2,4-Dimethylphenol ND - 27.6 No Value
    2-Chlorophenol ND - 38.2 No Value
    2-Methyl-4,6-Dinitrophenol ND - 308 No Value
    2,4-Dinitrophenol ND - 309 No Value
    4-Chloro-3-Methylphenol ND - 185 No Value
    4-Nitrophenol ND - 341 No Value
    2-Nitrophenol ND - 74.3 No Value
    Phenol ND - 18.6 No Value
    Polycyclic Aromatic Hydrocarbons
    (noncarcinogenic)
    ND - 13,600 No Value
    Arsenic ND - 152 2 EMEG
    Chromium ND - 326 10 EMEG
    Copper ND - 38.1 No Value
    Mercury ND - 29.9 No Value
    Dioxins and Furans ** 0.00000146 - 0.004155 0.000002 EMEG
    ND - Not Detected
    ** - Dioxins and Furans are assessed in terms of Toxicity Equivalents (TEQs). The TEQs listed here are from the RFI report.


    Air Monitoring

    On-site air monitoring was conducted on September 12, 13, and 14, 1989 as part of the investigations for the RFI. One upwind and two downwind sampling locations varied based on the wind direction. Sampling times were chosen to minimize the influence of emissions from regulated units on the KII-F property. On all three days, one of the sampling locations was located near the southwestern corner of the site. Depending on the wind direction, this location was either an upwind or downwind sampling station. Samples from this location showed either the highest or near the highest concentrations of PAHs and pentachlorophenol detected on-site. Table 4 presents the contaminants of concern identified for this media.

    TABLE 4
    AIR MONITORING DATA
    SEPTEMBER 12, 13, AND 14, 1991 (19)

    Contaminant Concentration Range
    (micrograms / standard cubic meter)
    Comparison
    Value
    Arsenic 0.002 - 0.017 10 EMEG
    Copper 0.014 - 0.14 No Value
    Chromium 0.006 - 0.31 No Value
    Pentachlorophenol ND - 0.24 No Value
    Polycyclic Aromatic Hydrocarbons ND - 980 No Value
    ND - Not Detected


    B. Off-site Contamination

    Groundwater - Monitoring Wells

    According to a January 6, 1989 memorandum from Gary Stowe, SCDHEC Pee Dee District, district personnel made a composite sample of four Florence wells on February 15, 1988. The SCDHEC laboratory analyzed this sample for 59 compounds including various chlorinated aliphatic (non-aromatic) compounds, benzene, dichlorobenzenes, chlorotoluenes, naphthalene, and xylenes. The analysis did not show the presence of any of these compounds.

    On June 11, 1991, Representatives of Keystone Environmental Resources sampled eight residential wells in the Hyman street Neighborhood. Sampling analysis did not reveal the presence of either or phenolic compounds. Table 5 summarizes the results of off-site monitoring well sampling for the RFI.

    Groundwater - Private Wells

    In February 1992, representatives of SCDHEC and EPA Region IV performed a door-to-door well survey of the areas to the southeast, south, and southwest of the KII-F site. This survey 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. No contaminants of concern were detected in these wells.

    Soil

    No off-site soil data are available for review. This pathway will be evaluated as data becomes available.

    Surface Water and Sediment

    Surface water was sampled from the tributaries located east and south of the site in August and November 1986 and in May 1987. ATSDR and the EPA currently do not have comparison values that are appropriate for accessing contaminants detected in surface water, sediments, and fish tissue. Table 6 presents the concentration range of the contaminants detected in these media; these contaminants will be evaluated further in this public health assessment.

    The RFI conducted two additional rounds of surface water and sediment sampling in August and December of 1989. Table 7 presents the contaminants of concern identified in these media.

    TABLE 5: OFF-SITE GROUNDWATER CONTAMINANTS
    AUGUST AND DECEMBER 1989 (19)

    Contaminant Groundwater Zone (ppb) Comparison
    Value
    (ppb)
    A and B C and D
    Benzene 33.6 ND 1 CREG
    Ethylbenzene 70.4 0.335 700 LTHA
    Pentachlorophenol 6,370 11.9 0.3 CREG
    2,3,5,6-Tetrachlorophenol 1,610 ND No Value
    2,4,6-Trichlorophenol 104 9.18 3 CREG
    2,4-Dichlorophenol 485 23.4 20 LTHA
    2,4-Dimethylphenol 150 ND No Value
    2,4-Dinitrophenol 80 3.68 No Value
    2-Chlorophenol 413 0.669 40 LTHA
    2-Methyl-4,6-dinitrophenol 1,960 1.66 No Value
    4-Chloro-3-methylphenol 3.07 0.519 No Value
    4-Nitrophenol 10,900 3.39 60 LTHA
    2-Nitrophenol 0.922 ND 60 LTHA
    Phenol 141 1.07 6,000 RMEG
    Polycyclic Aromatic Hydrocarbons 55,100 11.2 No Value
    Arsenic 13.1 ND 0.000006 CREG
    Dissolved Arsenic 20 ND 0.000006 CREG
    Chromium 290 32.4 100 MCL
    Copper 308
    -
    1,300 MCL
    Mercury 3.22 3.2 2 MCL
    Dissolved Mercury 2.28 1.58 2 MCL
    ND - Not Detected


    TABLE 6
    SURFACE WATER, SEDIMENT, AND FISH TISSUE SAMPLES
    Koppers Industries INCORPORATED, FLORENCE, SC (19)

    Contaminant Surface Water **
    ppb
    Sediments ***
    ppm
    Fish Tissue ****
    ppm
    Arsenic ND - 58 ND - 8.59 0.28 - 17
    Chromium ND - 206 ND - 45.4 ND - 1.52
    Copper ND - 65 ND - 33.8 ND - 9.52
    Oil and Grease ND - 21,400 ND - 1,000
    -
    Pentachlorophenol ND - 840 ND - 14.6 0.38 - 32.2
    Phenolic Compounds ND - 48 ND - 1.2 1.38 (1 sample)
    Naphthalene ND - 5 ND - 21.1 ND - 0.33
    Polycyclic Aromatic Hydrocarbons ND - 129 ND - 318.8 ND - 0.71
    ND - Not Detected
    ** - Surface water samples were drawn in August 1986, November 1986, February 1987, and May 1987.
    *** - Sediment samples were taken in August 1986 and February 1987.
    **** - Fish samples were taken November 1986, May 1987.


    TABLE 7
    OFF-SITE SURFACE WATER AND SEDIMENTS
    CONTAMINANTS OF CONCERN
    AUGUST AND DECEMBER, 1989 (19)

    Contaminant Surface Water (ppb) Sediments (ppm)
    Pentachlorophenol ND - 248 ND - 3.32
    2,3,5,6-Tetrachlorophenol ND - 12.9 ND - 1.74
    2,4,6-Trichlorophenol ND - 1.56 ND - 4.36
    2,4-Dichlorophenol ND - 6.04 ND - 2.27
    2,4-Dimethylphenol ND ND - 0.157
    2,4-Dinitrophenol ND - 3.62 ND - 3.74
    2-Methyl-4,6-dinitrophenol ND - 5.94 ND - 3.13
    4-Chloro-3-methylphenol ND ND - 0.125
    4-Nitrophenol ND ND - 1/17
    2-Nitrophenol ND - 1.92 ND - 0.274
    Polycyclic Aromatic Hydrocarbons ND - 67.664 ND - 58.6
    Dioxins and Furans 0.0000102 - 0.003729 0.0000129 - 0.002643
    Arsenic ND - 93.8 ND - 18.6
    Dissolved Arsenic ND - 13.1
    -
    Chromium ND - 160 ND - 46.5
    Copper ND - 118 ND - 26.9
    Mercury ND ND - 5.23
    ND - Not detected


    Food Chain

    In August and December 1989, the RFI sampled the biologic diversity of fish and benthic organisms at the same locations as those sampled for surface water and sediments. This survey indicated environmental/toxic stress in the biota of tributaries east and south of the site. The amount of stress decreases as the distance from the site increases. The creek to the east of the site has been impacted to a greater degree than the creek to the south of the site. Environmental/toxic stress is not a direct measure of human health; however, it may be related to several factors that are or are not associated to the site. It also suggests the possibility that fish and other foods from these creeks may be contaminated (19).

    Crayfish tails were analyzed for arsenic, chromium, copper, mercury, PAHs, acid extractable phenolic compounds, and total recoverable phenolic compounds. Not enough crayfish were collected for analysis with the exception of one station located beyond the Old Mars Bluff Neighborhood (FS-13). Fifty-three crayfish tails were combined into one sample (19). Table 6 presents the contaminants of concern identified for this media.

    C. Quality Assurance and Quality Control (QA/QC)

    The data in this section are from the 1990 RCRA RFI. Thus, this report contains the latest information for this site. Quality Assurance and Quality Control (QA/QC) conclusions drawn for this public health assessment are determined by the validity of the analysis and conclusions made and the availability and reliability of the referenced information. SCDHEC assumes that adequate quality assurance and quality control measures were followed with regard to chain-of-custody, laboratory procedures, and data reporting.

    The data analyses of groundwater were performed by Keystone Environmental Resources, Inc. Keystone Environmental Resources, Inc. is certified by the State of South Carolina to conduct such analyses. Full Quality Assurance and Quality Control data were not supplied within the RFI. The RFI states that organic compound identification was on the basis of retention data only. The use of retention data could result in misidentification of compounds.

    According to information supplied by Keystone Environmental Resources, Inc., approximately half of the volume of creosote is composed of 25 to 30 compounds. Of these, only a dozen are listed as priority pollutants by the EPA. Creosote is a mixture of many chemicals. Analyses performed would include less than half of the material present in creosote and only a small number of the possible compounds. This reflects the scientific uncertainty associated with this mixture.

    Groundwater data sheets often report an unrealistically high number of significant figures, e.g.- total PAHs of 4366.705 µg/L. In some samples, concentrations of dissolved metals were higher than the concentrations of total metals, and concentrations of hexavalent chromium were higher than total chromium.

    The RFI did not collect surface soil samples. ATSDR defines surface soil as soil from 0" - 3" in depth. Surface soil samples are needed to evaluate the public health impact that contaminants found in this media could pose. In the absence of this data, chemical data for deeper soils may suggest the possibility of human exposure and the development of toxicity. This method, however, only provides a tentative evaluation.

    A "background" soil sample was collected from a location between the plant office and the wood treatment area. The concentrations of arsenic, chromium, and copper detected in this sample were comparable to other samples in the eastern United States. The concentration of mercury in the "background" soil sample is approximately ten times the mean concentration of mercury in the eastern United States but within the observed range (ATSDR Public Health Assessment Guidance, February 1991). The presence of chlorinated phenols in this sample indicate that plant activities may have led to contamination of this location.

    Available air data was collected at the same time on three consecutive days. The wind conditions on the collection dates was an approximate 6 miles per hour. Higher winds would be more likely to entrain soil particles that could lead to exposures. While these data may suggest the composition and concentration of contaminants, the lack of variation in sampling time, the brief period of time, and the lack of variation in weather conditions prevent any firm conclusions relative to air contamination.

    The analysis of crayfish tails was derived exclusively from station FS-13. This station is located south of the site. Additional monitoring of fish and crayfish is necessary to accurately evaluate the site's potential impact on food-chain entities. Because of the unavailability of specimens, fish tissue analyses represent only a few of the specified sampling locations.

    D. Physical and Other Hazards

    KII-F is an active wood-treatment plant. Physical hazards include industrial machinery, stacked lumber, and a railroad yard.


    PATHWAYS ANALYSES

    To determine whether nearby residents may be affected by contaminants at the site, ATSDR and SCDHEC evaluate the environmental and human components that lead to human exposure. This pathways analysis consists of five elements: a source of contaminations; transport through an environmental media; a point of exposure; a route of human exposure; and an exposed population.

    ATSDR and SCDHEC identify exposure pathways as completed, potential, or eliminated. Completed pathways have all five elements and indicate that exposure to a contaminant has occurred in the past, is currently occurring, or will occur in the future. Potential pathways, however, have at least one of the five elements missing, but could exist. Potential pathways indicate that exposure to a contaminant could have occurred in the past, could be occurring now, or could occur in the future. Eliminated pathways have at least one of the five elements missing and will never be present. Completed and potential pathways may be eliminated when they are unlikely to be significant. The discussion which follows identifies the completed, potential, and eliminated pathways at this site.

    Regional Geology and Hydrogeology

    There are three major aquifers beneath the KII-F site: the Shallow Aquifer system, the Black Creek Aquifer, and the Middendorf Aquifer. Groundwater from these aquifers supplies water for the city of Florence. Two of the ten water supply wells for the City of Florence are located less than one mile downgradient and to the southwest of the sit e; both of these wells draw water from the Middendorf aquifer. The water table at the site is usually approximately ten feet below the ground surface. Shallow groundwater is generally slightly acid; most pH values measured from monitoring wells range between 4.5 and 6.0

    Monitoring wells are screened into A(10-foot), B(50-foot), C(100-foot) and D(deeper than 100-foot) monitoring zones. The A and B zones appear to be connected and be in the upper portion of the Shallow Aquifer. The C zone is the lower portion of the Shallow Aquifer and the D zone is within the Black Creek Aquifer. Groundwater in the A and B zones flows to the southwest in the western portion of the site and to the southeast in the eastern portion of the site. The C and D zones flow toward the west.

    A confining unit appears to separate units A and B from the deeper units (C and D). However, the site consists of a downward gradient that may serve to spread contaminants to the deeper aquifers. Low levels of contaminants have been detected in wells screened in the C and D zones.

    A. Completed Exposure Pathways

    Table 8: Completed Exposure Pathways

    Exposure Pathway Elements Time
    Source Environmental
    Medium
    Point of
    Exposure
    Route of
    Exposure
    Exposed
    Population
    KII-F Groundwater Off-site Ingestion
    Dermal Absorption
    Inhalation
    Adults
    Children
    Past

    A past completed exposure pathway has been identified for the KII-F site. Residents of the Day Street neighborhood complained of creosote odors emanating from their private drinking water wells. SCDHEC tested these wells and found phenolic compounds in the water. KII-F paid for municipal water lines to be installed and for the water bills for these residences for one year. However, not all residents agreed to use this water supply. Records do not indicate if the water supply wells were removed from use. Because of economics, many residents who were utilizing municipal water may have reverted to the use of wells. Project staff have noted well houses in this neighborhood.

    The 1988 Preliminary Health Assessment noted deficiencies in the groundwater data from the private wells in the vicinity of KII-F. In February and March 1992, EPA sampled private wells identified in areas southeast, south, and southwest of the site. These wells did not show the presence of site-related contaminants. Therefore, this pathway is not considered to be of concern at this time.

    KII-F has operated a series of 14 extraction wells downgradient of the site for the last four years. If effective, these wells should prevent the migration of contaminated on-site groundwater to these neighborhoods.

    B. Potential Exposure Pathways

    Table 9: Potential Exposure Pathways

    Exposure Pathway Elements Time
    Source Environmental
    Medium
    Point of
    Exposure
    Route of
    Exposure
    Exposed
    Population
    KII-F Groundwater Off-site Ingestion
    Dermal Absorption
    Inhalation
    Adults
    Children
    Future
    KII-F Soil On-site
    Off-site
    Ingestion
    Dermal
    Absorption
    Adults
    Children
    Future
    KII-F Surface Water
    and
    Sediment
    Off-site Ingestion
    Dermal
    Absorption
    Adults
    Children
    Future
    KII-F Surface Water
    (Fish)
    Off-site Ingestion Adults
    Children
    Future
    KII-F Air On-site Inhalation Adults
    Children
    Future

    Groundwater Pathway

    Future potential exposure pathways have been identified for the Old Mars Bluff, the Mustang Drive, and the Day Street neighborhoods. A SCDHEC survey of the Old Mars Bluff neighborhood revealed the presence of well houses in most yards. Wells from this neighborhood have not been sampled. Therefore, this pathway cannot be evaluated at this time.

    Hydrogeologic data indicates the possible migration of contaminated groundwater toward the Mustang Drive neighborhood. Sampling data show only small concentrations of contaminants in this direction. In March 1992, EPA sampled a private well in this neighborhood; no site-related contaminants were detected.

    A past completed exposure pathway was identified for the Day Street neighborhood. Samples collected and analyzed in February and March 1992 did not detect site-related contaminants; therefore, no exposures are known to be occurring at this time. A series of 14 extraction wells are operable in this area and if effective, are believed to prevent the migration of on-site groundwater contamination from spreading to these neighborhoods. However, if the extraction well system is not fully effective, it is possible that contaminated groundwater could migrate towards the identified private wells.

    In February and March 1992, EPA sampled private wells identified in areas southeast, south, and southwest of the site. These wells did not show the presence of site-related contaminants. However, because of the low concentrations of contaminants in multiple wells between KII-F and these neighborhoods, there could be a potential exposure pathway if people decide to utilize contaminated groundwater as their drinking water source.

    Soil Pathway

    Because of the sandy nature of the soil on the site and the proximity of SWMUs to populated areas, it appears reasonable to assume that contaminated soils could be spread to the nearby neighborhoods. However, because of the lack of surface soil data, this is considered a potential pathway. Exposures could also occur if trespassers accidentally ingest or come into dermal contact with contaminated soil.

    Soil contamination on the site is due to landfilling and to the release of contaminants. Contaminated soil could be stirred by wind and nearby residents, on-site workers, or trespassers could accidentally ingest the soil. The average adult ingests small amounts of soil; children tend to ingest larger amounts of soil because of their patterns of hand to mouth contact.

    Surface soil samples are needed to better characterize the extent of soil contamination. Analysis of these samples are needed to provide information for the evaluation of adverse human health effects associated with exposures to specific contaminant levels.

    Surface Water and Sediment Pathway

    A potential exposure pathway has been identified for surface water and sediments. Surface water runoff from the site has led to documented contamination to the streams located to the south and east of the site. Exposures could occur to people who ingest or come into dermal contact with contaminated surface water or sediments. However, the streams are very small and it is unlikely they would be used as primary drinking water sources. Therefore, this pathway is not considered to be of concern at this time.

    These two streams lead to nearby rivers. These streams consist of ditches and narrow (two-foot wide) creeks with little observable flow except in periods of heavy rain on the site. The beginning of Two Mile Creek leads northeastwardly toward Polk Swamp. Polk Swamp leads toward the south. An unnamed tributary stems from the western portion of the site toward Jeffries Creek. This tributary crosses the Day Street neighborhood and the Old Mars Bluff neighborhood.

    Biota Pathway

    Data indicate contamination of fish and crayfish in the streams near the site. However, because of the difficulties in obtaining an adequate sample, this contamination has not been fully characterized. Project staff have observed people fishing in these creeks; therefore this is considered a potential exposure pathway. Because of the size of these streams, sustenance fishing appears unlikely. However, it is possible that a person may occasionally ingest fish from this stream. Additional data are needed to better characterize and evaluate the potential for adverse health effects associated with the ingestion of contaminated fish and crayfish. The South Carolina Wildlife and Marine Resources Department reports that Jeffries Creek is a major fishery for the Florence area. (The stream southwest of the site flows into Jeffries Creek.) However, neither site-specific creel surveys nor angler effort statistics are available.

    Air Pathway

    Air monitoring showed very low levels of contaminants. These contaminants could be due to the continued operation of the plant or they could represent either the volatilization of contaminants from soil and the entrainment of contaminated soils by wind. The contaminated air could be inhaled.

    Although the monitoring was not sufficient for drawing a firm conclusion, the monitored levels of contaminants were very low. The expected doses would be much less than the doses anticipated from other routes of exposure.


    PUBLIC HEALTH IMPLICATIONS

    A. Toxicological Evaluation

    Introduction

    In this section we will discuss the health effects which may impact on people exposed to site-related contaminants. To evaluate health effects which may result from an exposure, ATSDR has developed Minimal Risk Levels (MRLs). MRLs estimate an exposure which is not likely to cause deleterious health effects; exposure to even lower amounts would be even less likely to cause adverse health effects. MRLs are specific to the route of exposure and the length of exposure. Routes of exposure may include ingestion (eating and drinking), inhalation (breathing), and dermal absorption (absorption through the skin). The duration of exposure is commonly classified as acute (less than 14 days), intermediate (15 to 364 days), and chronic (greater than 365 days) exposures.

    ATSDR developed MRLs to assess the possible toxicity of compounds to body organs. MRLs do not include information on the potential of compounds to cause cancer. In general, we assume that a person exposed to small amounts of a carcinogenic compound will incur a small increase in the statistical probability of developing cancer. A person exposed to larger doses of the compound will incur a larger increase in the statistical probability of developing cancer.

    This Public Health Assessment expresses the additional probability of developing cancer as a result of an exposure to a chemical in terms of no increased risk, no apparent increased risk, a low increased risk, a moderate increased risk, and a high increased risk. EPA has developed a mathematical methodology for estimating the extreme maximum probability that a person will develop cancer as a result of exposure to a chemical. The EPA Risk expresses estimates in the corresponding terms of less than one-in-a-million risk, one-in-one-hundred-thousand risk, one-in-ten-thousand risk, one-in-one-thousand risk, and one-in-one-hundred risk.

    ATSDR also develops Toxicological Profiles on chemical contaminants commonly found at hazardous waste sites. These documents provide information on health effects, environmental transport, human exposure, and regulations affecting these substances.

    The human exposure pathways section of this Public Health Assessment lists the routes by which site-related contaminants may enter the human body. As stated above, an evaluation of these hazards relies on an accurate estimation of the amount of these chemicals to which a person may be exposed. This estimate will use several standardized assumptions.

    We will assume that an adult weighs 70 kilograms (154 pounds) and a child weighs 10 kilograms (27 pounds). An adult ingests 2 liters of water per day (2 L/day, the same as a 2-liter soda bottle). A child drinks half that amount (1 l/day). During the course of the day, adults typically ingest 50 to 100 milligrams of soil per day (mg/day); this occurs by both inhaling small soil particles carried in the air and by placing soiled hands and other objects in the mouth. Because small children typically place objects in their mouths, it is assumed that they ingest a greater amount of soil, typically 200 mg/day.

    The following discussions of chemicals rely on the preceding assumptions combined with the information in the Exposure Pathways section.

    Polycyclic Aromatic Hydrocarbons (PAHs)

    The ATSDR Toxicological Profile for PAHs states that PAHs are a group of chemicals that are formed by the incomplete burning of coal, oil, gas, garbage, tobacco, or almost any other organic substance. Natural sources of PAHs include forest fires and volcanoes. Consequently, PAHs occur throughout the environment in the air, water, and soil. According to the toxicological profile, the only significant health effect demonstrated in humans following low-level exposure to some PAHs is cancer. Although animal studies have suggested that other effects may occur, these have not been adequately documented. Because only a few PAHs have been shown to cause cancer in laboratory animals, this public health assessment divides PAHs into carcinogenic (cPAHs) and non-carcinogenic PAHs (15).

    The most likely route of exposure to cPAHs could be from ingestion of off-site groundwater. This dose is several orders of magnitude greater than the doses that could be received from the inhalation of on-site air, the ingestion of on-site soil, and the ingestion of off-site fish.

    EPA is currently reassessing the toxicologic data for PAHs. However, an idea of their potency may be derived from the information within the July 25, 1990 Federal Register. Using this data, the ingestion of maximally contaminated off-site groundwater for a lifetime could lead to a very high increased risk of developing cancer. Additionally, on-site groundwater concentrations are greater than off-site concentrations. If the amount of off-site contamination should increase, a higher carcinogenic risk would result.

    Off-site soil has not been tested, and there are no surface soil samples for evaluation. Because of these data limitations, on-site subsurface soil may serve as a representation of an extreme worst case. It appears unlikely that any person could chronically contact on-site subsurface soil. In this case, the ingestion of on-site soil could add a high increased risk of developing cancer. This estimate will be revised as further information becomes available.

    Because of the small number of fish found in the associated creeks and the resulting improbability of a regular, lifetime exposure, the cancer risk from eating fish tissue will not be further considered under PAHs.

    ATSDR has developed an acute MRL for PAHs (15). The ingestion of maximally contaminated off-site groundwater would result in a dose which is thirty times the ATSDR acute MRL. However, the MRL is 100 times below the No Observed Adverse Effect Level (NOAEL) in animals. The NOAEL was the dose in a particular animal study at which no adverse health effects were observed. This study looked at the development of adverse reproductive effects, which is a very sensitive predictor of a chemical's toxicity. In developing the MRL, ATSDR used safety factors because the information was not based upon a study involving humans, and for variability between humans. Based upon this animal study, health effects in humans would not be anticipated from acute exposures to the levels found in the groundwater. However, some humans are more susceptible to the effects of PAHs due to sensitivity to PAHs, having other sources of exposure to PAHs, or a compromised immune system. These individuals may be at risk of developing adverse health effects from exposure to maximally contaminated off-site groundwater.

    ATSDR has not developed chronic or intermediate oral MRLs for PAHs. Other than cancer, the intermediate health effects listed in the ATSDR Toxicological Profile occur at doses similar to the acute effects. The ATSDR Toxicological Profile does not list adequate studies for the determination of chronic health effects following oral exposure. The EPA Integrated Risk Information System Database (IRIS) does not list an oral Reference Dose (RfD) for PAHs.

    Pentachlorophenol (PCP)

    The ATSDR Toxicological Profile for Pentachlorophenol states that this chemical was one of the most extensively used pesticides in the United States. It is still used extensively as a wood preservative (13).

    According to the toxicological profile, the ingestion and dermal contact of PCP may be followed by toxicity to the liver, kidney, blood, nervous system, and gastrointestinal tract according to the toxicological profile. Animal studies have shown that PCP is also toxic to the immune system and to the fetus (13).

    The ingestion of water from PCP-contaminated groundwater in the Day Street neighborhood could be of concern at this site. However, PCP was not present in 1992 private well samples. Therefore, ingestion of PCP contaminated water is not occurring at the present time and no adverse health effects are expected. If contaminated groundwater is not remediated, it is possible that the future migration of groundwater could lead to human exposures. Off-site monitoring wells in the direction of the Day Street neighborhood display PCP concentrations up to 6,370 µg/L. Children ingesting this water would receive a PCP dose slightly greater than equivalent doses causing toxicity to the immune system in rats. Additionally, this dose is one-fortieth the lethal acute dose in rats. Therefore, the ingestion of this contaminated water by humans may cause the health effects listed in the preceding paragraphs. The EPA has proposed a limit (Maximum Contaminant Level) of 1 µg/L of PCP in drinking water.

    Numerous studies show that PCP is absorbed through the skin and that it evaporates easily. Using this water for household uses would increase the dose of PCP and the probability of developing health effects similar to those of ingesting the water.

    According to the toxicological profile, laboratory animals exposed to high levels of PCP have developed an increased rate of cancer. Although there is no conclusive evidence that PCP causes cancer in humans, the EPA treats PCP as if it may cause cancer in humans (13). The extremely high concentration of PCP in monitoring wells would lead to a very highly significant risk of developing cancer as a result of drinking this water over a lifetime.

    A person ingesting on-site soil would receive a dose of PCP just slightly above the ATSDR MRL (13) for an intermediate duration of exposure. The dose received from inhaling on-site air is negligible. As a trespasser would only be exposed to on-site soil for brief periods of time and neither on-site nor off-site surface soil data are available, an estimate of carcinogenic potency will not be made at this time. However, the health effects resulting from exposure to PCP are due to the total exposure. That is, one must add the doses received from ingestion, inhalation, and dermal exposure.

    Polychlorinated Dioxins and Furans

    Polychlorinated dioxins and polychlorinated furans have similar chemical and toxicologic properties. This report will refer to these compounds as dioxins.

    Dioxins are inadvertently produced in very small amounts as an impurity during the manufacture of other chemicals, including certain wood preservatives. Further information on the chemical properties, physical properties, and general toxicology of dioxins may be found in the ATSDR Toxicological Profile for 2,3,7,8-Tetrachloro-Dibenzo-p-Dioxin (9).

    In humans, doses of dioxins greater than those anticipated from the ingestion of site-related groundwater or soil may cause chloracne. (Chloracne is an eruption on the skin similar to acne that results from exposure to chlorine and its compounds). Other studies described in the toxicological profile suggest that dioxins may cause damage to the liver, a loss of appetite, weight loss, and digestive disorders in humans. These effects are not anticipated from the doses of dioxins at this site. Recent evidence suggests that dioxins may be less toxic and less carcinogenic in humans than previously thought. Consequently, the EPA is currently reevaluating its position on dioxins (9).

    Laboratory animals exposed to dioxin doses greater than those anticipated at this site have suffered liver damage, a loss of weight, a susceptibility to infections, and reproductive effects. In laboratory animals, exposure to dioxins has been associated with the subsequent development of various forms of cancer (9). On the basis of the ATSDR Toxicological Profile for 2,3,7,8-Tetrachlorodibenzo-p-Dioxin, the ingestion of contaminated groundwater from this site over a lifetime would result in a high increased risk of contracting cancer as a result of this ingestion.

    Adults and children ingesting maximally contaminated groundwater and/or ingesting soil from this site would receive a dioxin dose from 10 to 100 times greater than the ATSDR MRL for this chemical. However, because the MRLs use safety factors, the doses received at the site are 10 to 100 times less than doses that have caused effects in animals (9). Additionally, humans appear to be less sensitive to dioxins when compared to some animal species.

    Trespassers would only spend a small portion of time on the site. Therefore, exposure to dioxin in on-site soils is not likely to result in any observable adverse health effects.

    Arsenic

    Arsenic is a naturally occurring element. While pure arsenic is a gray-colored metal, arsenic compounds show a wide range of properties. Arsenic containing compounds are used in a wide variety of applications including pesticides, herbicides, and wood preservatives. According to the Toxicological Profile for Arsenic, small amounts of arsenic are essential to human health (2).

    At KII-F, potential and completed exposure pathways for arsenic include four sources: inhalation of air, ingestion of soil, ingestion of fish, and ingestion of groundwater. The concentration of arsenic in air is insignificantly low and will not be further considered.

    On-site subsurface soil analyses show significant amounts of arsenic. In assessing the ingestion of soil, a person is only likely to come into contact with soil from the upper three inches of soil, unless the soil is disturbed. Considering the environmental behavior of arsenic, the arsenic concentrations are likely to be higher in surface soil. However, the RFI did not sample surface soil. Even though site visits have indicated that people trespass on the property, a trespasser is unlikely to remain on the property for greater than a few hours. Therefore, subsurface soil concentrations of arsenic will not be further considered. However, the hypothetical ingestion of on-site subsurface soil could produce doses approximately three times greater than the doses produced by groundwater. This would increase the probability of adverse health effects.

    The ATSDR Toxicological Profile for Arsenic lists the health effects that may occur: "...a number of studies indicate that, in more sensitive individuals, doses as low as 20 to µg/kg/day may produce one or more of the characteristic signs of arsenic toxicity, including gastrointestinal irritation, anemia, neuropathy, skin lesions, vascular lesions, and hepatic or renal injury. The severity of symptoms in affected individuals generally tends to increase as a function of exposure duration, although in some individuals, effects may occur after relatively brief exposure periods" (2). Thus, the same effects at KII-F may be expected following acute and chronic exposure.

    Ingesting a 1/2-pound fish meal could produce an oral arsenic dose similar to doses which have caused acute effects in humans. In the unlikely event that a person should subsist on fish from the nearby stream, this person would receive a chronic dose approximately ten times the ATSDR MRL (2).

    The ingestion of off-site groundwater containing the highest concentrations of arsenic by a child would lead to an arsenic dose similar to the doses which have caused effects in human studies. This dose is over ten times the ATSDR acute, intermediate and chronic MRL. (Chronic, intermediate, and acute effects tend to occur at similar dosages.) Additionally, studies have associated the ingestion of arsenic with the development of cancer in humans. The EPA has estimated that oral arsenic doses similar to the ingestion of off-site groundwater at KII-F may result in a moderate increased risk of developing cancer as a result of this exposure.

    2-Nitrophenol and 4-Nitrophenol

    Nitrophenols are closely related chemicals with similar chemical and physical properties. They are used mainly to produce dyes, paint colorings, drugs, rubber chemicals, and substances that kill fungi (12).

    Other than acutely lethal doses in animals, the ATSDR Toxicological Profile for Nitrophenols: 2-Nitrophenol, 4-Nitrophenol does not list oral studies for these chemicals. (The lethal doses are several orders of magnitude greater than those found at the site and therefore not considered of concern at this site. Respiratory effects were noted in one 13 week study at exposures similar to a 13 week lethal study.) ATSDR has not derived an oral MRL for these chemicals (12).

    EPA has released a draft Drinking Water and Health Advisory for 4-nitrophenol. The Health Advisories are 800 µg/L for one-day, and 60 µg/L for a lifetime. However, EPA's Integrated Risk Information System (IRIS) states that, "a risk assessment for this substance/agent is under review by an EPA workgroup. Therefore, in the interim, we can only note that the off-site groundwater concentrations of 4-nitrophenol is 14 times the one-day EPA Health Advisory" (21). (The EPA Health Advisories serve as guidance for levels of contaminants in drinking water which should not cause health effects for the specified time period.)

    Data for systemic effects following intermediate inhalation exposures are confined to a single study; the rats in this study displayed an increase in the levels of methemoglobin in the blood, minor signs of minimal liver toxicity, and changes in the eye. In the lack of further ingestion data, the similarity of effects that have been observed in animal studies, and the large concentrations of these compounds in off-site groundwater, it appears reasonable to tentatively assume that the ingestion of these compounds may produce similar effects to their inhalation. However, there is no evidence that people are using groundwater containing nitrophenols. Therefore, no adverse health effects are anticipated at this time.

    Benzene

    Benzene is a naturally occurring substance produced by volcanoes and forest fires and is present in many plants and animals. The ATSDR Toxicological Profile for Benzene states that it is a major industrial chemical made from coal and oil. It is found in gasoline, glues, adhesives, household cleaning products, and art supplies (3).

    Although large amounts of benzene may produce various health effects, only its carcinogenesis is of concern for the benzene detected in off-site groundwater. Exposure to benzene has been associated with various types of cancer in humans. The ingestion of maximally contaminated off-site groundwater over a lifetime would produce a very small but inapparent increase in the likelihood of cancer within a population (3).

    2,4,6-Trichlorophenol

    Trichlorophenol has not been made in the United States since 1986. In the past, the major uses of 2,4,6-trichlorophenol were as an antiseptic and pesticide. Its uses also included preserving wood, leather and glue, and preventing the build-up of mildew on fabric according to the ATSDR Toxicological Profile for 2,4,6-Trichlorophenol (16).

    Other than cancer, the levels of trichlorophenol found in off-site groundwater are not likely to produce adverse health effects. However, because several similar chemicals are present, trichlorophenol may interact with the other chemicals present.

    According to the toxicological profile, laboratory animals have developed various cancers after prolonged oral exposure to high levels of trichlorophenol. Whether or not trichlorophenol causes cancer in humans has not been adequately studied (16). However, since it causes cancer in animals, it is possible that it could cause cancer in humans. With this assumption, the lifetime ingestion of off-site groundwater could result in an increased rate of cancer. This increase, however, would not be apparent by standard statistical studies.

    2,4-Dichlorophenol

    The amounts of dichlorophenol found in off-site groundwater, by themselves, are not of public health concern. However, the ATSDR Toxicological Profile for 2,4-Dichlorophenol states, "concurrent exposure to other substances that exert their toxic effects by uncoupling oxidative phosphorylation (e.g., tri-, tetra-, and pentachlorophenol) could be expected to lead to increased adverse responses" (8). Since various other chlorophenols are present, this suggests that the toxicity of this mixture of chemicals may be greater that anticipated by analyzing each compound individually.

    Chromium

    Chromium is a naturally occurring element found in three different states: chromium 0, chromium III (trivalent chromium), and chromium VI (hexavalent chromium). In nature, most chromium is trivalent. According the ATSDR Toxicological Profile for Chromium, it is used to make steel and other alloys, bricks for metallurgical furnaces, chrome plating, the manufacture of pigments, leather tanning, wood treatment and water treatment (4).

    Chromium III is an essential nutrient that helps to maintain normal metabolism of glucose (sugar), cholesterol, and fat in humans. The National Academy of Sciences Drinking Water and Health (Volume 3, page 367) states, "Compounds of chromium in the trivalent state have no established toxicity. When taken by mouth they do not give rise to local or systemic effects and are poorly absorbed. No specific effects are known to result from inhalation. In contact with the skin they combine with proteins in the superficial layers, but do not cause ulceration" (4).

    The toxicological profile states that chromium VI is irritating to the skin and nasal passages. In the body it attacks the liver, kidney, and central nervous system. Inhalation of high levels of hexavalent chromium has ben associated with an increased risk of lung cancer in humans.

    At KII-F, off-site groundwater sampling has not detected the presence of hexavalent chromium. The RFI did not sample off-site surface water, sediments, or biota for hexavalent chromium. On-site soil sampling did not differentiate between the different states of chromium. The RFI did not sample off-site soil. On-site groundwater demonstrates significant amounts of hexavalent chromium.

    To date, no established routes of human exposure to hexavalent chromium exist. Consequently, no adverse health effects are anticipated. However, if future sampling shows the presence of hexavalent chromium in off-site groundwater or on- or off-site surface soil, the potential adverse effects of chromium will need to be reevaluated.

    Copper

    Copper is a reddish metal that occurs naturally in rock, soil, water, sediment, and air. The United states penny displays the reddish appearance of copper. According to the ATSDR Toxicological Profile for Copper, it is an essential element for all known living organisms including humans and animals (5).

    Vomiting and diarrhea are two of the most sensitive indicators of oral copper toxicity. At KII-F, a child ingesting maximally contaminated off-site groundwater would receive a 1/2 dose of copper that has resulted in vomiting and diarrhea in humans (5).

    An adult ingesting 30 grams of crayfish would receive an oral dose of copper roughly equivalent to an acute dose of copper sulfate that resulted in vomiting in humans. However, because any ingested copper would be within the crayfish tissue, the adverse effects of copper may not appear in this case.

    The levels of copper in the air are not of public health concern. Other than in the case of certain rare genetic diseases, such as Wilson's Disease and Menke's Disease, systemic copper toxicity is not known in humans (5). Therefore, other than the vomiting and diarrhea listed above, copper is not anticipated to be a public health threat.

    Mercury

    Mercury is a chemical element that occurs naturally in several forms. The most familiar is the silvery liquid metal used in some thermometers and other common products. Mercury also occurs in combination with other elements. One form of mercury, methylmercury, can build up in certain fish (11).

    The concentration of mercury detected in off-site groundwater and off-site crayfish is inadequate to produce adverse health effects. Therefore, no adverse health effects are anticipated at the present time. However, if future off-site groundwater samples indicate high levels of mercury, the effects of mercury will be reevaluated.

    Creosol

    Creosol (methylphenol) is a component of creosote (7). Sampling did not adequately determine the concentrations of creosol present in the various media. Therefore, no further statement can be made at this time.

    2-Chlorophenol

    ATSDR has not developed an MRL for this compound. The ingestion of maximally contaminated off-site groundwater by an adult would result in a dose of 2-chlorophenol approximately twice EPA's reference dose. Because of the conservative assumptions used by EPA, the ingestion of this compound in off-site groundwater should not produce adverse health effects. However, if the future off-site concentration of this compound increases, this compound will be reevaluated.

    Ethylbenzene

    Ethylbenzene is a colorless liquid that smells like gasoline (10). Currently, the maximum concentration of ethylbenzene in off-site groundwater is approximately equal to the EPA Maximum Contaminant Level Goal and the EPA Lifetime Health Advisory. Therefore, no health effects are anticipated at this time.

    Phenol

    Phenol is used in many manufacturing processes and products. Consumer products include ointments, ear and nose drops, cold sore lotions mouthwashes, gargles, throat lozenges, and antiseptic lotions (14). Currently, the concentrations of phenol present in off-site groundwater are not of concern. They are less than the ATSDR acute MRL. (ATSDR has not derived a chronic MRL for phenol.) Concentrations are less than the EPA lifetime health advisory for phenol. However, phenol concentrations on-site are several orders of magnitude greater than off-site concentrations. Should off-site concentrations of phenol increase in the future, this chemical will need to be reevaluated.

    Other Compounds

    Adequate toxicologic information was not available for the evaluation of 2,3,5,6-tetrachlorophenol, 2,4-dimethylphenol, 2,4-dinitrophenol, 2-methyl-4,6-dinitrophenol and 4-chloro-3-methylphenol.

    B. Health Outcome Data Evaluation

    The State of South Carolina does not currently have an implemented database or registry dealing with health effects in the vicinity of KII-F. Therefore, no evaluation may be made of health outcome data.

    C. Community Health Concerns Evaluation

    SCDHEC has voiced concerns over the use of private wells in the Day Street and Mustang Drive communities. In February and March of 1992, SCDHEC and EPA surveyed homes in areas southeast, south, and southwest of the site. Water from identified wells was analyzed for a wide range of contaminants. No site-related contaminants were identified. Therefore, the current consumption of water from these wells will not result in adverse health effects. Available data indicate that these wells could have been contaminated in the past. However, the data are not adequate to evaluate past exposures. There is a potential that these wells could become contaminated in the future. Therefore, this public health assessment recommends continued monitoring of these wells.

    As listed in the section titled "Community Health Concerns," all attempts to contact community leaders and identify any community health concerns have been unsuccessful. This Public Health Assessment therefore recommends further work to establish a system of information exchange.

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