°°

Senator Phil Gran370 Russell Senate OfficeWashington, O .C . 20510Attention: Hed Jems

TDear Senator Grama; *

TThank you for your recent correspondence concerning the Koppers TexarkanaSuperfund site. In response, we offer tite following for your consideration.This correspondence appears to have been Initiated by a letter (datedApril 29, 1989) which you recel-ed from Donald E. Preston, a resident ofTaxarkana. In that letter, Hr, Preston refers to a previous letter to theU.S . Environmental Protection Agency from Friends United for a Safe Environ--ment, Inc. (FUSE, a Texarkana community group) which outlined their objectionsto the Remedial Investigation (RI ) and the chosen site remedy, We respondedto these concerns in a letter to FUSE dated February 21, 1989. A copy of thisresponse, which addresses the request that residents be permanently relocatedand compensated for their hones, is enclosed. Permanent relocation and coapen-sation was not chosen for the Koppers Texarkana site, for the reasons explainedtherein. //~sHr. Preston's letter nakes reference to "newly discovered contamination* and"hot spot" that was discovered on January 20, 1989, The Agency's interimRemedial Investigation (R t ) which prompted a 1985 Emergency Response removalof highly contaminated topsoil, and the subsequent Rl and Feasibi l ity Study(FS) which prompted the reoedy selection of soil washing/ground vwter filtering,nas addressed this area as being contamination in one of the residentialyards targeted for further cleanup. Mr. Preston's concerns that the datafailed to reflect the true degree of contamination, and that buried tanks,debris, and concentrations of chemicals all threaten the ecology indefinitelyh«tve been addressed through the RI/FS, and will be further addressed duringthe site's remedial activit ies.Hr. Preston's letter to you also refers to the analytical detection limitsreported irt the RI as being unacceptably high. The tone of the letter suggestsmisunderstanding of the reasons that high detection limits jay occur, and themanner by which such data may be used in tne decision pro .ess at the Kopperssite. The following trill hopefully clarify these issues.6H-ET:Q£ESE:Vl:DISK 2/1 ; .-28-89

*#• ** • ̂-ftij-'^fsi^'.itrS- "-1 "•• . %*rfas col*—jr Ttewgh the Of mctffts «r-*——riir rfrtrtaiiiilii - *- t_ t-.—.t«.. _ . ^^ . _*

aa:.M« 4o aot taUtw Uut high dtttctfon Halts•it. aMTjrm «MtftaU a for 9 «*th1n these generalthe remedial activities. This samollna 1

f *Mr 4 Rofla^d BurnettPresidentFriends United for a Safe CO13 13 Hazel StreetTexarkanai Texas*Arkanm 75501^e: Koppers Texafkane Sucerfund Site^ear tfr. Burnett;Thank you for the letter of January 23» 1989, expressing your organizationsconcerns for the Impact the Koppers s1t@ has on the citizens and the environ-ment in the Texarkana area* We appreciate all of ytwr considerations andrecommendations^ however» we differ with yoor findings of the EPA' sInvestigation Report.The Kopper's Remedial Investigation and Feasibility Study (RI/FS) was p1n accordance with the requirements of the Comprehensive Environmental Respond.Compensation and liability Act of 1980, as amended by the Super-fund Amendmwtsand Reauthor1zat1on Act of 1986 (CEECLA); and the National (HI and Hai:anThe Agency adhered to its responsibility to protect human health and the environ^nent by basing the rdmedy selection on the need to practically and effactt«Bl.yreduce the toxic levels of carcinoganic polynuc)e

*egardino your concern about the Immediate health risks posed by contaminatedsoil, ground waters sediments, and surface water to local residents, we haveIdentified site contaminants that are potential carcinogen* (1ea arsenic,t>enzene and benzo (a) pyrene), or are toxic to humans (xylenes, toluene* andoentachlorophenol (PCP) . We assessed the potential pathways and contaminantconcentrations with relation to risks to human health if no "emedlal actionwas taken. Both carcinogenic and non-carcinogenic risks were considered* Therisks are reported in the FS report and also in Appendix C of the KopparsDeclaration for the Record of Decision. Summarized below is the aggregaterisk to each receptor group from all site contaminants and pathways. Theserisks are the worst case scenarios of potential effects on human health andassume no remediation of site contaminants*

peceptgr Qrpup

Non carcinogenicHazard Index(Target * i)Average MaximumExcess LifetimeRisk of CancerAverage Maximum

Carver Terrace Residents 0*01 0.08 2x10*Utility Workers —

phenolic compounds than did the downwind samples supports the conclusionthat the presence of these compounds Is related to background air qualityand not onsite air quality.,We recognize that the Implementation of the remedial action could result

reviews, after repudiation, to assess the s ite 's progress and determine Ifany further corrective action is necessary**e intend to negotiate an agreement with the Koppers Company whereby they* 111 assume all financial responsibility for implementing the remedialaction plan* If it appears that a plausible agreement cannot be reachedin a reasonable timefrane, w& will consider all options available to us,Including taking legal action against Koppers, ordering them to remediatethe site.If you need further Information, please contact me,Sincerely yoHi Robert tRobert £. Layton Jr. , P .E *Regional Administrator

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TO;DATE;

CONGRESSIONAL INQUIRY

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RETURN TO CHAStflTTE HEROD BY CLOSE OF BUSINESS: - ff

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Bfivircwnerital Protection Agency410 H Street S.W.Congmssiceial LiaisonWashington, D.C. 20460Dear Slrei

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Yours respectfully,_ j>

Senator Phil Grantn370 Hussell Senate Office BuildingWashington, D.C. 20510Attentions Ked Jaires

(224-2934)

PHIL C&AMMUnited States SenatorPGieajencloeure

• -•^

April 29, 1989

Honorable Phil GrammOnited states senate313

»ear Senator GrammsO

the« at Carve,Subsequen tcontamination our letter to the EPA, addit ional_ . . _- *^ * i has been uncovered and substantiates ourcontention that the EPA was making decisions on incompletedata that fai led to ref lect the true degreecontamination. The threat of health problemsonly for those citizens who are living on thepresent tim«j but the buried tanks, debris,of chemicals that were poured into holes un tne siall t h r ea t en the ecology indefin ite ly. It is myunderstanding fehat your office has received a report of anadditional *hot spot" that was discovered on January 20,of this yesriAdditionally! different experts with degrees in chemistryhave decl*ua

Two other chemists have remarked about the high detectionlevels. One local chemist (Masters degree) used the term"outrageously high*1 to describe the detection levels*Neither of these experts has

4tFeb. 25, 1969

The National Toxics Campaign is suggesting that we "kick incinerators inhe ash". If you read TN# 15 , and obtained the material you wi l l understandwhy we should kick them in the ash, $nd grab them by the scrubber.The Wrenching Debate held in Texnrkana, Arkansas & Texas was a wrenchingsuccess! Meetings were held in the Mount Zion Baptist Church in CarverTerrace, a sub-divis ion that was developed on top of an old creosote woodtreatment plant orce operated by Koppers, Co. The Group held two days ofhearings. They heard testimony from many victims of toxic poisoning andenvironmental activists from all over the country. The Wrench .ended Sundaywith a march through Carver Terrace in the rain. People came out of theirdoors &nd joined the walk. We sang, " . . .b lack and white together, deep inmy heart, I do believe, we shall have clean air .some day". As we marchedthough Carver Terrace the rain water pooled in the yards and surface waterwashed the top f«w inches of soi l . Phenolie pyr*m& odors were present, anaoi ly f * lms w«r» vis ible in pools and 1n the run-off in the strast, CarvsH^Terrace 1« & toxic »ase! The citizens of Carver Tsrraca ar« l iving on top*~of some of the moat toxic chemlcalo known to man. Ths demand made by the ^j-group was that the residents of Carver Terrace be ralocated, (NOW! ) andcompensated for their losses. Residents Carver Terrace are truly victimsof poisoning. All they have received from EPA is a letter dated 2/7/89 °which somewhat understates the poisoning going on in Carver Terrace:"Contaminants at the Koppers sit® ar© classified as polynucleararomatic hydrocarbons (PAHs) . The PAHs found 1n elevated concentrationswere: Acenapthene, Anthracene,.Senzo (a)-pyrene, Benzofluoranthanes,Chyrsene, Fluoranthene, Naphthalene, Pheftanthrene, Pyrene, and 2-Methyl-napthalene. Benzo(a)~pyrene has been identified as a local systemicanimal carcinogen through oral, skin and intratracheal exposure routes."petrta ajs w^JJ. as isomors o_f dtoxins ajad fjurans are on £he; silg, but EPAbungled their tests which resulted in discounting the danger related tothese poisons. (See TN #7 ,8 *9 ) The chemistry of PAHs is .d iscussed in "BasicChemistry of Dioxins and Furans", offered in TN#7. Their toxicity isrelated to the to benzene, see TN»1. PAHs generally attack the centralnervous system causing a variety of neurotoxic symptoms s imi lar to thosedescribed in previous Toxic News, Th*»y are also Irnmunosuppressive agents.Environmental activists that missed this meeting missed an Importantturning point in the environmental movement. Don't miss the next WrenchingOobntei we are in the beginning of a change for the better, and workingtogether w® wi l l turn this toxic course around. Meeting face to face,talking over Issues, putting a face with a name, getting the factsstraight, clarifying our position, and taking action ar« importantdevelopments for the environmental movement. We shall overcome!Meanwhi le , at Koppers, inc., the mapagors of their spec1alti.es group boughta chemical "unit" from Beazer, Xnc. , Koppars .Industries; Inc., former tarand wood products group recently bought a tar processing, wood preservationand furnace, and foundry cok© operations from Koppers Co* . Koppors Co.also sold their science and technology center to PPG Industries, Inc. Are! vultures picking the carcass of Koppers Co., or is this business as usual?Toxic NewsP.O. Box 3133tf . c . , KS. estca

TOs F.U.S.Ec/o Ben Preston •2922 MarionTexarfcsna, Texas 75501

Published by : George

Toxic News•* 1.7The Toxin of tho tta«k 1e Cr*o*Qt«*. ,Cr,*oaofc*. 1» a brown to black oilyliquid with a charact@r1iBt1c.«h8rp^emo|ceyv?o:r.'.tarny odor,. Its chemicalfamily is coal tar distillates* Synonyms-for creosote are brick oi l , coaltar creosote, creosote oil, craosotum, er«styl1c creosote, dead oil, heavyoil, liquid pitch oil, napthalene oil,'tar .oil, and wash oil. Creosote isa coiaplex i, ixture of poly nuclear aromatic hydrocarbons, tar acids (phenoliccompounds), tar bases, aromatifs' am1nes>and,.heterocyclie compounds.Benzo(a)pyrene may be present.1n levels^above 0 , 18 . -Creosote may be mixedwith coal tar, tar bottoms and/or heavy oi:lsr. -(Creosote should not beconfused with wood tar creosote, which ,1s distil lee from wood tar an£ ismainly used in medicine.) The major uses of creosote 1s as a woodpreservative for railroad ties9 marine pilings, telephone polesdisinfectant for fruit trees, and. ae a component in road-tar manufacture.Vapors or creosote-contaminated dust ;c«n .ba Irritating to the nosa,throat and eyes. Severity of daw®GQ is related to the phenolic content ofthe creosote, Contact to the akin will cause pain and second degree burh/Safter skin contact for a few minutes. Skin or mucous membrane contact w

FRIENDS UNITED FOR A SAFE ENVIRONMENT, INC.1313 Hazel Street

TEXARKANA, TEXAS-ARKANSAS 75501

January 23. 1989

Mr, Robert E* Layton, Jr.Regional Administrator EPAAl lied Bank Tower1 4 4 5 Soss Avenue, 12 t h FloorDal las , Texas 75202UK: Koppt't s Toxat k&n& Super fund Site

i:

oDear Sir:Members of this organization as citizens directlyimpacted by the contamination and the proposed remedialaction contemplated for the Koppers Superfund Site ,Texarkana, Texas, and as citizens of the area who areindirectly impacted by the site, we submit the following forthe consideration of all of those persons responsible forremedial action, original despoilers, home and propertyowners in the immediate area of the. site, and property andhoma owners sharing the impacted aquifer, and all thoseliving south of the impacted area including but not limitedto the citizens of the Pleasant Hil.! Community, citizens inthe Sulphur River Basin and citizens of the city of BossierCity, &A and others who are dependent on water from the Redand that river's sources.Th i n organ i za t i on ob jec t s to the proposed Koppers SiteSupt-rfund Site remedial action in several particulars. Weare compelled to object to the findings of the FinalRemedial Investigation Report as being cavalier tinadvertently prejudiced, and based on incomplete data andon data that fails to ref lect the true degree ofcontamination of the Koppers Superfund Texarkana Site*For a time period of eight (8) years, the residents ofCarver Terrace have lived on this site without ^nacomprehensive health survey b$ing completed, even thoughample evidence is available from casual conversation thatthesa residents are suffering severe and catastrophic healthproblems that are most likely traceable to the fc'-aperfundsite. The human tragedy of so many of the homaownera ofthis area just walking away from their property after havingremitted years of mortgage payments cannot be easilydismissed. Most of th« homaowners who still remain in thearea are trapped by financial circumstances whereby theirlife's work hast bean invested in those homes.

During the eight (8) years of testing, only one series ofair quality tests deemed acceptable to the investigators isrecorded. These air tests, which were made at time mostfavorable to reveal no contamination of the air, none-the-less showed dangerous contaminat ion which exceededestablished EPA acceptable limits in two of the three daysof testing. These tests were conducted on November J.9, 21,and 22 of 1 9 8 5 . At other t imes, o.\ factory arid ocularexaminat ion of the area is suffic ient indication thatcontamination is present in the air, especially prevalentduring periods fol lowing ra infa l l . Eye irr i tat ion can behar s h , even ai 1^5 from the- sit* i t t e l t f * The report for the

ot! ht- dt*t * »ot «*d |.f;«'nc- 1 & t hatby s t a t im ) t h A t only twot h e i r zospec t ive l i m i t s * . . of t

cl«?«r ly?7 compounds Bt*A 1" . . .exceeded

In addition, no mention was made of the ramificationsof the mixing of traces of PAH ' s « id other phenoliccompounds with air contaminar^s which in themselves aloneconstitute a known health hazard. It is the contention ofFOSE that the possibility of air contamination could remainfor an indefinite period ever after the proposed remedialaction based on observation of the mc">i l ity of the compoundswhich have saturated the area and their proclivity to leachfrom under buildings and roadways. Tne presence of thesecompounds would be most likely in the most dangerous placesfor human health, in that they would be leaching into theground immediately adjacent to and from under the homes ofthe residents of the Carver Terrace Addition.FUSE contends that leaving these compounds under the housesconstitutes an unnecessary and unacceptable risk for theres idents . FUSE a lso contends that to assume that thefounda t i on s of the homes in the Carver Terrace Add i t ionOffer an adequate barrier to rising fumes is an unproved anddangerous assumpt ion that could keep the health of theresidents of that area in jeopardy. Again, no effort hasbeen made to monitor the quality of air in the homes of thecitizens of Carver Terrace and FUSE would contend thatrefuge in the homes at Carver Terrace does notnecessarily offer protection from the hazards of the aircontamination of the site. The presence of PAH's in the soilportends a certainty that they will continue to escape intothe air indefinitely.The Department of tha Interior * s comments on thecontamination of Cowhorn and Waggoner (also designated asWagnsr) Creeks,, seems to substantiate common senaa in thatthe contamination in the water of these streams is notAva&ly disbursed nor diluted to a point where it offers noconcern but rather indicates that there is a highprobability that there are heiavy concentrations of poisonsin various forme at various places.

-o

Because of past gravel min ing act iv i t i e s a long thewaterways, including Day ' s Creek, contaminat ion of theaquifer has occurred from several sources. It would seemthat the spillage since the year 19 10 at the site itse lf hassaturated the soil from the surface down into the aquiferand is leaking directly into the aquifer at the ait * . Apartial cleaning of the site, ( i . e . ) reaoving & fo^t of topsoil will not stop the continued destruction of th* aquifer.Tho qravc lDays C i e * f«r. r i > * - l ift

in the• * ! * «

th*by fro »which the

AndI > *

. f *• r 1 t

* lorvg tid« of11 »» 1 f * va«Mvd ana*t do** < d i * - i -

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Since the p i ts are dug into the aquifer itself, groundwaterand surface water has become almost as one and what is saidabout one is almost always true about the other. The creeksof the area flow into the gravel pits and feed the aquiferat several points. The light chemical concentrations flowinto the aquifer during low water and the heavier sedimentsare washed into the aquifer during flooding. The chemicalsare collected in deadly pools throughout the aquifer andoffer a continuing threat to the health of hundreds offamilies who rely on the aquifer for their water supply.The Koppers site is not the only source of contamination ofthe aquifer. Years of inadequate sewer treatment and thesubsequent dumping of untreated waste water, the run-off ofthe National Creosote Superfund Site, and the continuedchemical leakage from Kerr-McGee into Howard and WaggonerCre e k s have al l contr ibuted to the contaminat ion of thea q u i f e r . Wh i l e an e f f o r t has been made to improve thewa s t e -wa t e t be ing re l eased by the waste-water plant ande f for t s are being made at Kerr-MeGee, visual and olfactoryexaminations indicate that the problems at these places arenot solved.The Nat iona l Creosote Superfund s ite is still underinvestigation by the Texas Water Commission and it's impactand the extent of the damaging effect on the aquifer has notbeen a s s e s s ed . Because of these other sources ofcontamination FUSE urges that upmost care and effort beutili2ed to clean up the Kopper sits to the most pristineconditionFailure to remove all contaminated soil from the CarverTerrace area would endanger workmen making home repairs.Additionally, any break in water aupply pipes would exposeresidents to possible unacceptable health risks by bothingestion and absorption.

FUSE must also address itself to the remedial report whereincompiler of the report has rational izedthe port as rational ized duringdiscussion of Public Health and Environmental Assessment ,In our opinion no good urchildren who comenot place a hand in their mouthwill taste eo bad

our opinion no good purpose is served by saying thatin contact with the various poisons wil l

. _ - . , a second time because it_ _ _— the first time, or that no d i s c e rn i ngper«on would enter the water in the grave l p i t s or thestreams in the area.Such unsc ient if ic speculation detracts fro* what should be «ffiopt f i o r i o yB d i s c u s s i o n of hea l t h ha s * i r t s «nd at if!» not *ubft *«ncf * to the i t ddc i * . The wi i t * t *J * o r*f>«r£* thatW*9^on*r Cr«ek »»«te dr ink i ttq wator ftt«ndft$

FUSE also recommends that after as much contaminatedmaterial is removed as possible, the site be landscapedwithout returning the cleaned soil, and the area be left assmall ponds for the propagation of aquatic and wildlife.The use of the area as a wetland would be beneficial as partof the Central Flyway and give the land an opportunity toheal itself. Because the taxing authority of Texarkana,Texas has reduced the value of this property, itcause A d i f f i c u l t cash-f low problem with theBMC to b < > removed from the tax r o l l s .

shouldc i ty for notthe

-PPioved by the, membership of PUSH

Donald E. Prestoncompiler Honald BurnettPresident

5

STATEMENT OF PATSY OLIVER(To a National Meeting of Greenpeace Members in Washington DCon April 3, 1989 as a representative of POSE)

My name ie Patsy Oliver I am a member of FUSS,. .Friends UnitedFor a Safe Envirnment... headquartered in Texarkana, Texas* . .andI am so pleased to be among friends and to be able to talk aboutmy home . . * my dream home in the Koppera Texarkana Superfundsite.. . because usually when I talk about Carver Terrace it iswith official type people/ like the EPA. . . and those guys are nofriends.

! wonder what it is that they are thinking about, when I telltheft that nearly every person who has lived on this site for anylength of time hag a serious health problem. Their usualresponse is to display a vocabulary that advertises a knowledgeof how to pronounce dozens of jaw-braking names of poisons, andtwenty different ways to says see and smell. But no reason whythere has never been a comprehensive health survey made on thissite, where 78 families l ive.* , well, we say live. But it is nota normal l ife* . . We dare not bring our grandchildren into ourhouses. . . We no longer feel safe working in our yards . . . No freshcut roses from our gardens sitting on a tab le . * . certainly wewouldn't keep a vegetables garden. . . How could one eat a radishfrom a garden grown in soil that EPA experts won't even step onwithout a Moonsuit and gas mask! Not one turnip or watermelonpatch in the whole 64 acres!For eight long years the EPA has been studying the site. Thehazards of the site first became common knowledge when aDemocratic Congress in the late ?0 f s ordered the 50 largestchemical companies to report all abandoned dump sites. My homeis built right on top of one of those abandoned dumpsites. A sitethat was used by Koppers and other chemical companies from 1910until 1960 .

The site changed hands several times and in 1964 some white guygot th« idea of building a nice community for the "niggers.*After all, in 1964 , there was no choice about where blacks wouldlive in Texarkana. We lived where we were told. Filthy ghettoswith unpaved roads, inadequate police protection ... wel l/absolutely everything was second c lass . . . schools, water supply/sewer service, drainage.. . just everything! Let me tell you...the prospect of being able to own our homes in a community withwater and sewer service, paved roads, a neighborhood playgroundfor our chi ldren-., hearts just beat faster... this was the realAmerican dream. . . a dream that we could just begin to dream.Today, that dream is a nightmare!Some of my neighbor's homes would be worth $70 ,000 or $80 ,000 inofeh^r parts of Toxieana. . . but not in Carver Terrace. Someformer members of the community... tired of slowly dying, just&ov$d out * . . never mind those years of mortgage oayments,p«-raonal health was more important. These houses have beenbought by speculators for &s little && $7 ,000, But the money is

CMCCVI

not the most important thing. What would our government sayabout the Russians if those guys had left their citizens withinthe fall-out range of Chernobyll Or if the Indian government hadnot intervened in behalf of the Bhopal victims* We in CarverTerrace know that we are victims..- and that we are being hurt bythe contamination in the Superfund site that we are living on . * *and «MS know that we are getting the shaft when the EPA spokesmansays Carcinogenic Polynuc lear Aromatic HydrocarbonsSuperealifragilistlcexpealadoches IWhen the EPA is told at a public meeting that there is ane x t r eme l y high number of cancer cases , l iver problems,P iaca t r i age s , And ear ly deaths : they ft«y, one in thrae g«t*cancer, ethnic *adie»] proble*, find everybody has to dift!RfMl iy when one dcale with these guys, one is tetnpted to doubtthe sanity of the wor ld . How bout this l You know that it takesthe EPA four pages of single spaced type to says that sweat iswet. . . The book report on the contamination. . . written by theemployees of the Koppers Company who understand their own vestedinterest in thig report* . , say that these PAH's can kill you.. .or cause il lne§8. * *But, if a child gets some on his hands andthen put! the hand in his mouth... it will taste so bad, he won'tdo it ar/ain. And the writer of the book says that the water inthe nearby str«ams has a sheen of chemicals on top and a browntrail of poison* on the bed.. . but, not to worry. No one withgood sense would get in that water. And then, just a few pageslater the writer says that those streams meet all of Texasprimary and secondary drinking water standards- But I1 11 tellyou a secret my friends. Those same EPA people refused take adrink of water from my hydrant.In the whole sight years that all of this examination has beengoing on/ thera has only bsen one series of three days of airtests. On two of those thrae days/ contaminates exceeded EPA' sown standards of safe levels . . . despite that test being made atthe most favorable time to show no contamination.Each environmental organization in this country can do more forhis cause , just by support ing the cause of otherenvironmentaliitfi. Let me combine a few words of two beautifulpoems.* . ! What Happens To A Draam Deferred, ... Does it Dry OpLike a Raisin IJR The sun,,. Never to See the Light of Dav* Is aDream Deferred & Death That Will Take Me With It,. . .Or Will MyAmerican Dream Soar, And Corns to Beautiful Fruition While YouServe As the Wind Under My Wings- . . And Your Dreams Will Soar andBear Fruit Whil* | $%%?& ae j^* win