PRELIMINARY PUBLIC HEALTH ASSESSMENT
ALCOA (POINT COMFORT)/LAVACA BAY
POINT COMFORT, CALHOUN COUNTY, TEXAS
- Fish and crabs from the closure area of Lavaca Bay should not be eaten. Evidence indicates that people have been exposed to mercury in the past and that exposure to mercury is occurring at present. The exposed population includes people who ate contaminated fish, crabs and oysters in the past as well as people who currently eat contaminated fish and crabs from the closure area. Since eating fish and crabs contaminated with mercury at the concentrations observed at this site may affect the unborn fetus and the currently exposed population may include pregnant females, we have classified this site as an urgent public health hazard.
- Persons who have been exposed in the past may also include on-site workers exposed to mercury vapor. Urine samples collected from workers between 1966 to 1983 showed elevated levels of mercury. Additionally, anecdotal reports of mercury in washing machine traps suggest that former chlor-alkali workers may have brought mercury home on their clothes. Although the likelihood that mercury brought to these homes continues to represent a significant health threat is low, data to eliminate this as a continued source of exposure are not available.
- There is no evidence that indicates recreational activities along Port Lavaca beaches should be limited due to mercury contamination. Concentration of mercury in sediment decreases as distance from the dredge spoil island increases.
- Migration of mercury-contaminated groundwater may be contributing to further contamination of the Bay. In addition, if sediment in on-site lagoons is contaminated with mercury, this sediment could serve as a continuing source of contamination to groundwater and to Lavaca Bay via groundwater migration.
- Limited data suggest that fish, oysters, and sediment in Lavaca Bay also may be contaminated with polycyclic aromatic hydrocarbons (PAHs) and polychlorinated biphenyls (PCBs). We are unable to evaluate the public health implications of these contaminants due to insufficient data.
- Over the past fourteen years, levels of mercury contamination in fish have remained relatively constant, implying that mercury in the Bay has remained bioavailable. A continued source of mercury or resuspension of mercury from activities that disturb the sediment, such as dredging and shrimp trawling, could explain these constant levels.
- A limited number of fish samples from Keller Bay (which is outside the closure area) indicatethat fish in this area may be contaminated with mercury. However, since all of the fish sampleswere over the Texas Parks and Wildlife Department maximum size limit, we were unable todetermine the public health significance of these contaminated fish.
Cease/Reduce Exposure Recommendations
- We recommend that no fish or crabs from the Lavaca Bay closure area be eaten. Increase public awareness of adverse fetal health effects that could occur as a result of pregnant women consuming more than five ounces of mercury-contaminated fish per month or 11 ounces of crabs per month taken from the closure area. Notify the public and local physicians (particularly obstetricians) of the health hazards associated with consumption of mercury-contaminated fish and crabs. Designate a contact person to respond to physicians' questions and to record information about patients experiencing adverse health effects potentially associated with exposure to mercury.
- Publicize the areas of the Bay which contain fish and blue crabs with concentrations of mercury at levels that could cause adverse health effects to increase public awareness of the hazard of eating fish and crabs taken from contaminated areas of the Bay. Continue current ban on fish and crabs.
- Better delineate the area closed to the taking of fish and crabs. Improve marking of the closure area. Signs describing the closure area of the Bay should be in any appropriate language to reach the exposed population (English and Spanish) and signs should be added at the Point Comfort boat ramp (and the ramp in the Olivia area if it is constructed).
- Complete a fish consumption survey of the area.
Site Characterization Activities
- Continue to sample fish inside the closure area for mercury; analyze fish samples for PAHs and PCBs. Sample fish of legal catch size at Keller Bay near Rattlesnake Cove; analyze the samples for total mercury (and methylmercury) and provide results to the Texas Department of Health/ATSDR for evaluation.
- If mercury levels in fish (of legal catch size) from Keller Bay near Rattlesnake Cove are elevated, sample crabs and sediment from this area.
- Collect additional crab samples from the closure area and analyze for mercury. Based on sampling results, re-evaluate ban on the taking of crabs from the closure area to determine appropriate public health action.
- Collect oyster samples inside closure area near the Witco dock and analyze for PAHs and PCBs.
- Test the sediment in the lagoons for mercury and other contaminants.
- Determine if groundwater contamination on site is contributing to contamination of Lavaca Bay.
- Continue to conduct demolition or soil moving activity in the vicinity of the R-300 (chlor-alkali) building in accordance with applicable health and safety regulation (29CFR 1910.120).
- Determine if mercury brought into homes by former chlor-alkali workers continues to be asource of exposure.
Health Activities Recommendation Panel (HARP) Recommendations
In accordance with the Comprehensive Environmental Response, Compensation, and Liability Act(CERCLA) of 1980, as amended,the data and information developed in the ALCOA (PointComfort)/Lavaca Bay Public Health Assessment have been evaluated by the Agency for ToxicSubstances and Disease Registry's Health Activities Recommendations Panel (HARP) and TDHfor appropriate follow-up activities. Based on evidence that people have been exposed tomercury in the past and that exposures are continuing to occur at present, HARP recommendedtaking the following actions to identify exposed populations: 1) conduct a fish consumptionsurvey in the vicinity of the site; and 2) determine indoor mercury vapor levels in houses wherepeople who worked in the chlor-alkali unit lived during the time they worked in this unit. HARPrecommended that if exposed populations are identified, TDH should conduct a biologicalindicators of exposure investigation. HARP concurred with TDH that improved warning signs inSpanish and English should be posted and that TDH should provide educational materials to thepublic and physicians (particularly obstetricians) regarding health effects associated withconsuming mercury-contaminated fish and crabs.
Public Health Action Plan
- TDH has maintained a ban on taking fish and crabs from certain areas of Lavaca Bay since1988.
- TDH will notify the public and local physicians of the health hazards associated with consumption of mercury-contaminated fish and crabs. TDH will designate a contact person to respond to physicians' questions and to record information about individuals experiencing adverse health effects potentially associated with exposure to mercury.
- TDH will publicize the areas of the Bay which contain fish and blue crabs with concentrations of mercury at levels that could cause adverse health effects (closure area).
- TDH will work with ALCOA and EPA to improve the clarity of information and maps posted on the warning signs describing the closure areas of the Bay and will investigate the possibility of improving the markers of the closure area.
- ALCOA has contracted with Radian Corporation to complete a fish consumption survey of the area.
- TDH will periodically collect additional crab samples from the closure area and analyze them for mercury. TDH will use these data to re-evaluate the current ban on crabs within the closure area and determine appropriate public health actions as necessary.
- TDH will recommend that EPA have ALCOA sample additional fish of legal catch size outside closure area (Keller Bay near Rattlesnake Cove), analyze the samples for total mercury, and provide results to the Texas Department of Health/ATSDR for evaluation.
- ALCOA will conduct biological monitoring studies on former chlor-alkali plant workers to assess their current exposure to elemental mercury. The results of these tests can be used to indicate whether exposure above normal background is occurring in homes.
- TDH will recommend that fish from all parts of Lavaca Bay periodically be analyzed for mercury.
- TDH will request to EPA that sediment samples be collected inside the closure area near the Witco dock and analyzed for PAHs and PCBs. Sampling of oysters and fish may be recommended if sediment samples contain elevated concentrations of PAHs and PCBs.
- TDH will recommend that EPA test the sediment in the on-site lagoons for mercury and other contaminants.
- TDH will recommend that EPA determine the extent to which on-site groundwater contamination is contributing to further contamination of Lavaca Bay.
- TDH recommends that demolition and soil moving work in the vicinity of the R-300 (chlor-alkali) building continue to be conducted in accordance with applicable health and safety regulation (29CFR 1910.120).
- EPA has requested that the Army Corp of Engineers obtain sediment samples immediatelyprior to and after dredging of the ship channel to determine if mercury is being resuspended.
Susan L. Prosperie, M.S., R.S.
Environmental Quality Specialist
Health Risk Assessment & Toxicology Program
John F. Villanacci, Ph.D.
Health Risk Assessment and Toxicology Program
Kathryn A. Evans, M.P.H.
Health Risk Assessment and Toxicology Program
Nancy B. Ingram
Public Health Technician
Health Risk Assessment and Toxicology Program
Laurie B. Wagner
Health Risk Assessment and Toxicology Program
ATSDR Regional Representative
George Pettigrew, P.E.
Senior Regional Representative
ATSDR - Region 6
ATSDR Technical Project Officer
The ALCOA (Point Comfort)/Lavaca Bay Preliminary Public Health Assessment was prepared bythe Texas Department of Health under the a cooperative agreement with the Agency for ToxicSubstances and Disease Registry (ATSDR). It is in accordance with approved methodology andprocedures existing at the time the Assessment was initiated.
William Greim, M.S., M.P.H.
Technical Project Officer
Division of Health Assessment and Consultation
The Division of Health Assessment and Consultation, ATSDR, has reviewed this PreliminaryPublic Health Assessment and concurs with its findings.
Robert C. Williams, P.E., DEE
Director, DHAC, ATSDR
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