PUBLIC HEALTH ASSESSMENT

HIPPS ROAD LANDFILL
JACKSONVILLE, DUVAL COUNTY, FLORIDA

mg/l - milligrams per liter
ND - not detected

D. Public Comments

Summary of Public Comments and Florida HRS Responses
Draft Public Health Assessment

From October 19-21, 1994, we sent 24 copies of the draft Hipps Road Landfill Public HealthAssessment to community leaders, government officials, the PRP, the document repository, and alocal grocery store for document access and public review. On November 17, 1994, we held apublic meeting to present the findings of the draft public health assessment and to gather thepublic's comments on the draft document. To announce this meeting, we included a meetingannouncement/health assessment fact sheet in the front of each document copy we distributed,and community leaders delivered 900 fact sheets to nearby residences. In addition, FHRS' publicinformation staff contacted media representatives in Jacksonville and, on November 17, theFlorida Times-Union (Jacksonville) published a story about the draft health assessment andannounced the meeting. Approximately 80 adults attended the public meeting, 24 of whom gavecomments on both health-related and nonhealth-related issues. We also solicited public commentsby mail through December 16. As of December 23, we had received nine written responses,mostly from area residents. The following is a summary of the public's comments (in bold) and our responses:

1. One resident commented that landfill operation began in 1967, not 1965. This had beenestablished in one of the court cases involving the landfill. Another resident commentedthat not all of the houses on site were demolished - some were moved to other locations. Another individual recommended a few other minor, factual changes to the text.

   Thank you for the comments; we have made appropriate corrections in the text. Because thefirst comment involves a date change, it also lessens the exposure period and our estimates forincreased cancer risk. Therefore, we have changed the information in Tables 16-18 to reduce thenumber of years of potential exposure.

2. One resident commented that children used to swim in the cypress pond, but no longer do so.

   Thank you for this correction. We have changed the text in Conclusion #6 and reduced therecommended sampling frequency in Recommendation #6 to reflect this fact.

3. Several residents reported health problems from present-day exposure to their privatewell water. These problems include: nausea, diarrhea, headaches, burning eyes whileshowering, cataracts, ear problems, sinus problems, thyroid disease, blood poisoning, badnerves, liver problems, skin rashes, itching skin, allergies, back problems, difficulty healingafter surgery, heart attacks, strokes, cancer, and other health problems. Many residentsare worried that their children's drinking and bathing in this water will harm their health.

   We have added burning eyes while showering, itching skin, blood poisoning, and difficulty healingafter surgery to the health problems listed in the text. The other health problems were already reported.

   We have not been able to identify any potential health problems in children or adults frompresent-day exposure to the groundwater. The Duval County Public Health Unit (CPHU)periodically monitors private wells in the community to ensure the water meets primary drinking water standards.

4. One resident questioned the safety of the air stripper. When living next to the airstripper, this individual had headaches, sinus problems, and eye irritation whenever the airstripper operated. After this person moved to a home farther away from the air stripper,these symptoms persisted but to a lesser degree. This person had not experienced theseproblems prior to air stripper installation, and has not experienced them since it has beendown for repairs. This individual wanted HRS staff to be aware of these effects, eventhough the HRS analysis found the air stripper was unlikely to harm a person's health.

   Although we did not find the emissions from the air stripper were likely to harm health, we'verecommended that water going into the air stripper continue to be monitored to allow us toidentify potential public health problems, should they develop in the future. We have asked EPAto share with us the sample data they've gathered since the trial run. We will re-evaluate thesedata if any contaminant concentrations measured exceed those measured during the trial run ofthe air stripper.

   We have added eye irritation to the health problems listed in the text. The other health problemswere already reported.

5. A few residents questioned the cancer risk evaluation in the health assessment, believingthe risk estimates to be much too low.

   We, too, are concerned about the numbers of illnesses, especially cancers, in the community. When we did this assessment, we erred on the side of protecting public health when we made ourestimates. We did this by evaluating only the highest contaminant concentrations for evaluationand using the maximum exposure period that was reasonable. In other words, we always erred onthe side of public health and estimated the worst case exposure. The greatest increased cancerrisk we estimated for any one contaminant is 1 in 1,000. Nevertheless, we do not know all thereis to know about cancer-causing chemicals, nor how all of the chemicals the community wasexposed to interact. This is one reason we have recommended ATSDR perform some kind ofhealth follow-up study. Other reasons are: our analysis indicates health problems, includingcancer, could occur in the community; and, there is a large number of reported illnesses.

6. One individual strongly disagreed with the methodology of the public health assessment,stating "the overall philosophical approach and methodology presented in the Draft PHAare fundamentally flawed." In particular, this individual believed the health assessmentwas too conservative in using worst-case assumptions, particularly by using maximumconcentrations for each chemical; contradicted EPA guidelines in its use of worst-caseassumptions, which is likely to result in a substantial overestimate of a potential problem; and contradicted ATSDR guidelines in its use of screening values (EMEGs) to predicthealth effects.

   As explained in the text (Public Health Implications Section, Uncertainty in Health Assessments),we did not have sufficient sampling data to know if the maximum values reported were themaximum values the residents were actually exposed to, nor did we have adequate geologic andsample data to predict peak values. We decided to err on the side of protecting public health byusing maximum measured values in our analysis. We cannot know if the resulting risk estimatestruly are upper-bound estimates. Nevertheless, we believe the risk of illness is unlikely to belarger than the risk we have estimated, and may be smaller. Our decisions and conclusions showthat a public health assessment requires the use of scientific and professional judgement; weunderstand readers may not agree with all of our judgements.

   The confusion between EPA risk assessments and public health assessments is understandable. An EPA risk assessment is used to support the selection of cleanup activities at a Superfund site. A public health assessment is a mechanism to assess any current or future public health impactsfrom the release of hazardous substances into the environment, provide the community withinformation on the public health implications of a specific site, identify those populations forwhom further health actions or studies are needed, and make recommendations for actions neededto protect public health. In the public health assessment, we acknowledge the uncertainties of ourassumptions and estimates (Public Health Implications Section, Uncertainty in HealthAssessments) which may lead to an under- or over-estimate of the risk of illness, largely becauseof gaps in the data. We cannot know the magnitude or direction of our presumed errors withoutevaluating the very data that are missing.

   The statement about our using EMEGs (or other comparable values) as predictors of healtheffects is incorrect. In accordance with ATSDR guidelines and as described in the text(Environmental Contamination and Other Hazards Section), we used ATSDR's standardcomparison values to select contaminants of concern for further evaluation. The individualmaking the comment may be confused because when we selected one contaminant of concern inone medium, we reported that contaminant in all other media. This is why some contaminants ofconcern are below their comparison values for a particular medium in Tables 4-12. Carefulexamination of these tables will show each contaminant of concern to be above its standardcomparison value in at least one of these tables, or to have no standard comparison values forinitial screening. In addition, all readers should note that the draft public health assessmentunderwent ATSDR technical review before being released as a public draft document.

7. One resident asked about the physician education program conducted at St. Vincent'shospital in September 1994 and wanted to know how residents could find out the names ofdoctors who were interested in treating people who had been exposed to chemicals.

   Information about the physician education program can be obtained from HRS by contacting:
   
   

   Ms. Julia Winter
   HRS/HSET
   1317 Winewood Boulevard
   Tallahassee, FL 32399-0700
   (904) 488-3385

8. Many residents had questions and comments about the proposed follow-up health study. Suggestions about the type of study residents would like to see include: a study of theincidence of learning disabilities, cancer, and other health problems reported in thecommunity in comparison with the incidence of these problems in a nonexposedcommunity, a biomedical study of the health of past and present community residents, anda tracking of the health problems identified within the community in the present and in the future.

   If ATSDR accepts the recommendation for a follow-up health study, HRS and ATSDR plan tomeet with residents early in 1995 to discuss the options available and the community's needs for ahealth study.

9. One resident asked about testing for radiation in water and soil.

   EPA has not sampled the groundwater or soil for radioactivity. HRS has recommendedradionuclides be measured in future water samples. The Duval CPHU recently began measuringradionuclides in the private well samples they collect from the Hipps Road area. So far, thosesample results have come back negative. If radionuclides are found in the groundwater in thefuture, HRS will evaluate the need for testing surface water and soil for radioactivity.

10. A few residents had questions about the adequacy of past sampling around the landfill. Specifically, why was most of the sampling confined to the areas northeast of the site?

    Because groundwater near the site generally flows to the northeast, EPA has focused theirsampling and cleanup efforts northeast of the site. However, we don't believe contaminantmovement in directions west, east, or south of the site has been fully described. We also don'tbelieve enough surface soil, surface water, or sediment samples have been collected around thesite. Therefore, in the health assessment, we have recommended EPA conduct additionalsampling to further investigate potential environmental contamination around the site.

11. One resident was concerned that contaminant plume boundaries had not changed since they were first delineated years ago.

    In 1989, site contractors collected information needed to delineate the boundaries of thecontaminant plume, northeast of the site, in order to design the cleanup system (Golder 1990). We do not have the hydrogeological expertise to evaluate whether or not the contaminant plumeboundaries have moved significantly since these data were evaluated; this issue is best addressed by EPA.

12. One resident questioned the purpose and effectiveness of the clay cap. Another residentwas concerned the site contractor had damaged the cap by driving heavy vehicles on it.

    The clay cap has three purposes. First, because the cap covers the fill material, it prevents thesematerials from being blown or washed off site. Second, the cap prevents the mounding ofcontaminated groundwater over the fill material, which subsequently can cause contaminants toflow away from the landfill in all directions. Third, because the cap keeps rainfall out of the fillmaterial, it prevents downward movement of contaminants into the groundwater. However, thecap will not prevent contaminants, already dissolved in the groundwater, from flowinghorizontally away from the site. We do not know if the landfill cap has been damaged; it is EPA'sresponsibility to ensure the cap is periodically checked and remains intact.

13. A couple of people commented on the landfill's contents. One individual requestedHRS to recommend a more complete source determination be made of the landfill'scontents, so that proper sampling and cleanup can ensue.

    From a public health standpoint, contaminants found on site become important only if there is apoint of human exposure to them. We believe that as long as the cap remains intact, thegroundwater monitoring around the site continues, and EPA collects the additional environmentalsamples we have recommended, we will have adequate information to assess the potential publichealth threat from the site. Therefore, our findings do not support an additional need for furthercharacterization of the landfill contents at this time. In the health assessment, we haverecommended future uses of the site be restricted to those compatible with the remainingcontamination. If site uses were to become incompatible, in terms of potential human exposure,we would consider recommending further site characterization work be performed. For example,if a developer wanted to build homes on the site in the near future, we would likely recommend acomplete source determination be conducted for the site. We do not have the expertise toevaluate whether or not further site characterization is needed to adequately clean up the site; thisissue is best addressed by EPA.

14. One individual reported difficulty in obtaining recent site documents from EPA, andrequested HRS's help in obtaining recent sampling data.

    We have requested recent sampling information from EPA and will share whatever data we obtainwith the public, upon request.

15. Several residents had questions about testing of their private well water.

    The Duval CPHU is responsible for testing private wells in the Hipps Road area. Nearbyresidents should call the Duval CPHU, at 630-3272, if they want to have their well water tested. Presently, there is no charge for the sampling or analyses. It takes several weeks to get the watersample results back from the laboratory in Jacksonville.

16. Many residents had questions about when hookup to city water on their streets wouldoccur. Others had comments about the high cost of hookup.

    The community leaders have information about the schedule for bringing city water to the HippsRoad neighborhood and the availability of financial assistance for residents unable to pay for hookup.

17. One resident asked about current activities at the site.

    The air stripper has been shut down since September because of filtration problems in one of theholding ponds. The construction equipment and materials are on site to fix the filtration problem.

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