PUBLIC HEALTH ASSESSMENT
MUNISPORT LANDFILL
NORTH MIAMI, DADE COUNTY, FLORIDA
APPENDIX A: SITE MAPS AND SAMPLING LOCATIONS
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APPENDIX B: CONTAMINANTS LACKING SUFFICIENT TOXICOLOGICAL DATA
- thio bis methane
dimethyl acetate octadienol
trimethyl bicycloheptene
dimethyl disulfide
benzene acetic acid
methyl butanoic acid
dibenzofuran
dibenzothiophene
dodecanoic acid
tridecanoic acid
tetradecanoic acid
pentadecanoic acid
hexadecanoic acid
heptadecanoic acid
tetrahydofuran
trimethyl bicycloheptanone
benzothiazalone
benzene propanoic acid
propoxy phenol
phosphoric acid
ethoxy phenol
chloromethyl benzeneamine
ethylmethylbenzene sulfonamide
endrin aldehyde
delta BHC
trimethyl benzene sulfonamide
diethyl methyl benzamide
dimethyl ethyl phenol
APPENDIX C: CONTAMINANT CONCENTRATIONS AND EXPOSURE PATHWAYTABLES
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled | Comparison Value | |
|---|---|---|---|---|
| (mg/L) | Source | |||
| ammonia | NA | --- | --- | --- |
| benzene | ND | 0/1 | --- | --- |
| di(2-ethyl hexyl) phthalate | NA | --- | --- | --- |
| cadmium | ND | 0/1 | --- | --- |
| carbon disulfide | NA | --- | --- | --- |
| chloromethane | NA | --- | --- | --- |
| coliform bacteria | NA | --- | --- | --- |
| dieldrin | NA | --- | --- | --- |
| lead | 0.130 | 1/1 | 0.015 | FL MCL |
| methylene chloride | ND | 0/1 | --- | --- |
| pentachlorophenol | NA | --- | --- | --- |
| PCBs | NA | --- | --- | --- |
| styrene | NA | --- | --- | --- |
| vanadium | ND | 0/1 | --- | --- |
| zinc | 0.275 | 1/1 | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
FL MCL - Florida Maximum Contaminant Level
LTHA - EPA Lifetime Health Advisory
Source: 1982 Florida DER and Dade County DERM Summaries of Analytical Results, as quotedin 1984 EPA Remedial Action Master Plan (9).
| Contaminants of Concern | Maximum Concentration (mg/kg) | number positive* / total # sampled | Background Concentration (mg/kg) | Comparison Value | |
|---|---|---|---|---|---|
| (mg/kg) | Source | ||||
| ammonia | 13 | 3/25 | ND | none | --- |
| benzene | ND | 0/25 | ND | --- | --- |
| di(2-ethyl hexyl) phthalate | 3.2 | 1/25 | ND | 0.03 | CREG |
| cadmium | ND | 0/25 | ND | --- | --- |
| carbon disulfide | ND | 0/25 | ND | --- | --- |
| chloromethane | ND | 0/25 | ND | --- | --- |
| coliform bacteria | NA | --- | NA | --- | --- |
| dieldrin | 0.064 | 1/25 | ND | 0.040 | CREG |
| lead | 87 | 18/25 | 180 | none | none |
| methylene chloride | ND | 0/25 | ND | --- | --- |
| pentachlorophenol | 21 | 2/25 | 21 | 5.8 | CREG |
| PCBs | 0.270 | 3/25 | ND | 0.090 | CREG |
| styrene | ND | 0/25 | ND | --- | --- |
| vanadium | ND | 0/25 | ND | --- | --- |
| zinc | 97 | 18/25 | 51 | none | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/kg - milligrams per kilogram
CREG - ATSDR Cancer Risk Evaluation Guide
Sources: 1984 EPA Site Investigation (6) and 1988 EPA Remedial Investigation (7)
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled | Background Concentration (mg/L) | Comparison Value | |
|---|---|---|---|---|---|
| (mg/L) | Source | ||||
| ammonia | 63 | 36/38 | none | 30 | LTHA |
| benzene | ND | 0/33 | none | --- | --- |
| di(2-ethyl hexyl) phthalate | ND | 0/21 | none | --- | --- |
| cadmium | 0.015 | 6/69 | none | 0.005 | EMEG |
| carbon disulfide | 0.096 | 14/21 | none | 1 | RfD |
| chloromethane | 0.011 | 4/33 | none | 0.003 | LTHA |
| coliform bacteria | 5,400/ 100 mL | 10/10 | none | 1 per 100 mL | FL MCL |
| dieldrin | ND | 0/21 | none | --- | --- |
| lead | 0.063 | 3/69 | none | 0.015 | FL MCL |
| methylene chloride | ND | 0/33 | none | --- | --- |
| pentachlorophenol | ND | 0/33 | none | --- | --- |
| PCBs | ND | 0/33 | none | --- | --- |
| styrene | ND | 0/33 | none | --- | --- |
| vanadium | 0.020 | 2/33 | none | 0.020 | LTHA |
| zinc | 0.210 | 19/77 | none | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed, ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
LTHA - EPA Lifetime Health Advisory
EMEG - ATSDR Environmental Media Evaluation Guide
RfD - EPA Reference Dose
FL MCL - Florida Maximum Contaminant Level
Sources: 1982 Florida DER and Dade County DERM Summaries of Analytical Results, asquoted in 1984 EPA Remedial Action Master Plan (9), 1984 Remedial Action Master Plan (5),and 1988 EPA Remedial Investigation (7).
| Contaminants of Concern | Maximum Concentration (mg/kg) | number positive* / total # sampled | Background Concentration (mg/kg) | Comparison Value | |
|---|---|---|---|---|---|
| (mg/kg) | Source | ||||
| ammonia | 370 | 5/6 | none | none | --- |
| benzene | ND | 0/18 | none | --- | --- |
| di(2-ethyl hexyl) phthalate | ND | 0/18 | none | --- | --- |
| cadmium | ND | 0/18 | none | --- | --- |
| carbon disulfide | ND | 0/18 | none | --- | --- |
| chloromethane | ND | 0/18 | none | --- | --- |
| coliform bacteria | NA | --- | none | --- | --- |
| dieldrin | ND | 0/18 | none | --- | --- |
| lead | 80 | 5/18 | none | none | --- |
| methylene chloride | ND | 0/18 | none | --- | --- |
| pentachlorophenol | ND | 0/18 | none | --- | --- |
| PCBs (1242) | 0.90 | 2/18 | none | 0.090 | CREG |
| styrene | ND | 0/18 | none | --- | --- |
| vanadium | 26 | 13/18 | none | none | --- |
| zinc | 430 | 13/18 | none | none | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/kg - milligrams per kilogram
CREG - ATSDR Cancer Risk Evaluation Guide
Sources: 1984 EPA Remedial Action Master Plan (5), 1988 EPA Remedial Investigation (7), and1989 EPA Water Quality and Toxic Assessment Study of Mangrove Preserve (12).
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled | Background Concentration (mg/L) | Comparison Value | |
|---|---|---|---|---|---|
| (mg/L) | Source | ||||
| ammonia | 561 | 35/36 | 0.27 | 30 | LTHA |
| benzene | 0.002 | 3/20 | ND | 0.001 | CREG |
| di(2-ethyl hexyl) phthalate | ND | 0/20 | ND | --- | --- |
| cadmium | 0.011 | 1/73 | ND | 0.005 | EMEG |
| carbon disulfide | ND | 0/20 | ND | 1 | RfD |
| chloromethane | 0.001 | 1/20 | 0.007 | 0.003 | LTHA |
| coliform bacteria | 2,400/ 100 mL | 31/106 | 7 per 100 mL | 1 per 100 mL | FL MCL |
| dieldrin | 0.00008 | 1/20 | ND | 0.000002 | CREG |
| lead | 0.90 | 57/127 | 0.17 | 0.015 | FL MCL |
| methylene chloride | ND | 0/20 | ND | --- | --- |
| pentachlorophenol | 0.006 | 2/20 | ND | 0.0003 | CREG |
| PCBs | ND | 0/20 | ND | --- | --- |
| styrene | ND | 0/20 | ND | --- | --- |
| vanadium | 0.054 | 9/20 | 0.032 | 0.020 | LTHA |
| zinc | 12 | 76/114 | 9.1 | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
LTHA - EPA Lifetime Health Advisory
CREG - ATSDR Cancer Risk Evaluation Guide
EMEG - ATSDR Environmental Media Evaluation Guide
Rfd - EPA Reference Dose
FL MCL - Florida Maximum Contaminant Level
Sources: 1984 EPA Remedial Action Master Plan (5), 1987 Ross Report (10), and 1988 EPA Remedial Investigation (7).
| Contaminants of Concern | Maximum Concentration (ppm) | number positive* / total # sampled | Background Concentration (ppm) | Comparison Value | |
|---|---|---|---|---|---|
| (ppm) | Source | ||||
| ammonia | NA | --- | NA | --- | --- |
| benzene | 0.562 | 8/8 | NA | 0.00003 | CREG |
| di(2-ethyl hexyl) phthalate | NA | --- | NA | --- | --- |
| cadmium | NA | --- | NA | --- | --- |
| carbon disulfide | NA | --- | NA | --- | --- |
| chloromethane | 0.0006 | 1/8 | NA | 0.4 | EMEG |
| coliform bacteria | NA | --- | NA | --- | --- |
| dieldrin | NA | --- | NA | --- | --- |
| lead | NA | --- | NA | --- | --- |
| methylene chloride | 0.002 | 1/8 | NA | 0.00006 | CREG |
| pentachloro-phenol | NA | --- | NA | --- | --- |
| PCBs | NA | --- | NA | --- | --- |
| styrene | 0.261 | 4/8 | NA | 0.10* | EMEG* |
| vanadium | NA | --- | NA | --- | --- |
| zinc | NA | --- | NA | --- | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
ppm - parts per million
CREG - ATSDR Cancer Risk Evaluation Guide
EMEG - ATSDR Environmental Media Evaluation Guidelines
* - EMEG for styrene: No Observable Adverse Effect Level for humans following long-terminhalation exposure (1ppm) X safety factor of 10.
Source: 1991 EPA Environmental Response Team Report on Air Sampling Performed at theMunisport Landfill (11).
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled | Background Concentration (mg/L) | Comparison Value | |
|---|---|---|---|---|---|
| (mg/L) | Source | ||||
| ammonia | 11 | 27/45 | 0.070 | 30 | LTHA |
| benzene | ND | 0/15 | ND | --- | --- |
| di(2-ethyl hexyl) phthalate | ND | 0/15 | ND | --- | --- |
| cadmium | ND | 0/21 | ND | --- | --- |
| carbon disulfide | 1.9 | 10/21 | 0.023 | 1 | RfD |
| chloromethane | ND | 0/15 | ND | --- | --- |
| coliform bacteria | 190/100 mL | 5/5 | NA | 1 per 100 mL | FL MCL |
| dieldrin | ND | 0/15 | ND | --- | --- |
| lead | ND | 0/22 | ND | --- | --- |
| methylene chloride | ND | 0/15 | ND | --- | --- |
| pentachlorophenol | ND | 0/15 | ND | --- | --- |
| PCBs | ND | 0/15 | ND | --- | --- |
| styrene | ND | 0/15 | ND | --- | --- |
| vanadium | 0.092 | 13/15 | 0.110 | 0.020 | LTHA |
| zinc | 0.150 | 9/24 | ND | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
LTHA - EPA Lifetime Health Advisory
RfD - EPA Reference Dose
FL MCL - Florida Maximum Contaminant Level
Sources: 1982 Florida DER and Dade County DERM Summaries of Analytical Data, quoted in1984 EPA Remedial Action Master Plan (9), 1984 EPA Remedial Action Master Plan (5), and1988 EPA Remedial Investigation (7).
| Contaminants of Concern | Maximum Concentration (mg/kg) | number positive* / total # sampled | Backround Concentration (mg/kg) | Comparison Value | |
|---|---|---|---|---|---|
| (mg/kg) | Source | ||||
| ammonia | 620 | 9/9 | 9 | none | --- |
| benzene | 0.002 | 1/16 | ND | 24 | CREG |
| di(2-ethyl hexyl) phthalate | ND | 0/16 | ND | --- | --- |
| cadmium | 4.1 | 1/16 | ND | 25 | EMEG |
| carbon disulfide | 0.003 | 1/16 | ND | 5,000 | RfD |
| chloromethane | ND | 0/16 | ND | --- | --- |
| coliform bacteria | NA | --- | --- | --- | --- |
| dieldrin | ND | 0/16 | ND | 0.040 | CREG |
| lead | 110 | 6/16 | 27 | none | --- |
| methylene chloride | ND | 0/16 | ND | --- | --- |
| pentachlorophenol | 0.4 | 1/16 | ND | 5.8 | CREG |
| PCBs (1260) | 0.077 | 1/16 | ND | 0.090 | CREG |
| styrene | ND | 0/16 | ND | --- | --- |
| vanadium | 23 | 11/16 | 36 | none | --- |
| zinc | 1,600 | 9/16 | 33 | none | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/kg - milligrams per kilogram
CREG - ATSDR Cancer Risk Evaluation Guide
EMEG - ATSDR Environmental Media Evaluation Guide
RfD - EPA Reference Dose
Sources: 1984 EPA Remedial Action Master Plan (5), 1988 EPA Remedial Investigation (7), and1989 EPA Water Quality and Toxic Assessment Study (12).
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled | Background Concentration (mg/L) | Comparison Value | |
|---|---|---|---|---|---|
| (mg/L) | Source | ||||
| ammonia | 78 | 39/39 | 0.27 | 30 | LTHA |
| benzene | ND | 0/13 | ND | --- | --- |
| di(2-ethyl hexyl) phthalate | ND | 0/13 | ND | --- | --- |
| cadmium | ND | 0/52 | ND | --- | --- |
| carbon disulfide | ND | 0/13 | ND | --- | --- |
| chloromethane | 0.008 | 1/13 | 0.007 | 0.003 | LTHA |
| coliform bacteria | 1,420/ 100 mL | 1/47 | 7 per 100 mL | 1 per 100 mL | FL MCL |
| dieldrin | ND | 0/13 | ND | --- | --- |
| lead | 0.037 | 24/61 | 0.17 | 0.015 | FL MCL |
| methylene chloride | ND | 0/13 | ND | --- | --- |
| pentachlorophenol | ND | 0/13 | ND | --- | --- |
| PCBs | ND | 0/13 | ND | --- | --- |
| styrene | ND | 0/13 | ND | --- | --- |
| vanadium | 0.029 | 2/13 | 0.032 | 0.020 | LTHA |
| zinc | 0.12 | 19/31 | 9.1 | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
LTHA - EPA Lifetime Health Advisory
FL MCL - Florida Maximum Contaminant Level
Sources: 1982 Florida DER and Dade County DERM Summaries of Analytical Results quoted inthe 1984 EPA Remedial Action Master Plan (9), 1984 EPA Remedial Action Master Plan (5),and 1988 EPA Remedial Investigation (7).
| Contaminants of Concern | Maximum Concentration (mg/kg) | number positive* / total # sampled | Background Concentration (mg/kg) | Comparison Value | |
|---|---|---|---|---|---|
| (mg/kg) | Source | ||||
| ammonia | NA | --- | --- | --- | --- |
| benzene | NA | --- | --- | --- | --- |
| di(2-ethyl hexyl) phthalate | NA | --- | --- | --- | --- |
| cadmium | ND | 0/8 | ND | --- | --- |
| carbon disulfide | NA | --- | NA | --- | --- |
| chloromethane | NA | --- | NA | --- | --- |
| coliform bacteria | NA | --- | NA | --- | --- |
| dieldrin | 0.024 | 1/8 | ND | none | --- |
| lead | ND | 0/8 | ND | --- | --- |
| methylene chloride | NA | --- | NA | --- | --- |
| pentachlorophenol | NA | --- | NA | --- | --- |
| PCBs (1254) | 0.44 | 5/8 | 0.091 | none | --- |
| styrene | NA | --- | NA | --- | --- |
| vanadium | 0.21 | 1/8 | ND | none | --- |
| zinc | 1,400 | 8/8 | 3,100 | none | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/kg - milligrams per kilogram
Source: 1988 EPA Remedial Investigation (7).
| PATHWAY NAME | EXPOSURE PATHWAY ELEMENTS | TIME | ||||
|---|---|---|---|---|---|---|
| SOURCE | ENVIRONMENTAL MEDIA | POINT OF EXPOSURE | ROUTE OF EXPOSURE | EXPOSED POPULATION | ||
| Surface Soil | Munisport Landfill | Surface Soil | On the Landfill | Ingestion and Skin Contact | Children trespassing on site | Past Present Future |
| Surface Water | Munisport Landfill | Surface Water | Landfill lakes | Ingestion and Skin Contact | Children swimming in on-site lakes | Past Present Future |
| Fish and Oyster * | Munisport Landfill | Fish and Oysters | Residence | Ingestion | Biscayne Bay Fish and Oyster Eaters | Past Present Future |
| Ambient Air | Munisport Landfill | Air | Nearby Residences | Inhalation | Highland Village Residents | Past and Future |
* It is unlikely that this site is the source of PCB contamination of Biscayne Bay.
| PATHWAY NAME | EXPOSURE PATHWAY ELEMENTS | TIME | ||||
|---|---|---|---|---|---|---|
| SOURCE | ENVIRONMENTAL MEDIA | POINT OF EXPOSURE | ROUTE OF EXPOSURE | EXPOSED POPULATION | ||
| Stormwater Run-off | Munisport Landfill | Stormwater | Highland Village | Skin Contact | Highland Village Residents | Past and Future |
| Landfill Leachate | Munisport Landfill | Leachate | On the Landfill | Skin Contact | Children Trespassing on the Site | Past |
| Surface Soil | Munisport Landfill | Surface Soil | On the Landfill | Ingestion and Skin Contact | On-site Workers | Future |
| Soil Gases | Munisport Landfill | Air | Highland Village | Inhalation | Highland Village Residents | Future |
APPENDIX D: SUMMARY OF PUBLIC COMMENT ON THE DRAFT PUBLICHEALTH ASSESSMENT AND FLORIDA HRS RESPONSE
In August 1992, Florida HRS mailed a one page "fact sheet" to 150 people on the EPAMunisport Landfill Superfund mailing list. This fact sheet summarized the findings of the draftpublic health assessment, announced its availability, and solicited public comments. The EPAmailing list included all residents who had previously attended public meetings, all involvedgovernmental agencies, local television stations, radio stations, and newspapers. We also maileda copy of the draft health assessment directly to six community leaders. A story regarding thedraft assessment appeared in the August 23, 1992 Neighbors edition of the Miami Herald. TheMunisport Dump Coalition also summarized the draft assessment in their November newsletter. The deadline for comments on the draft was September 25, 1992. In September, we mailed asecond "fact sheet" to everyone on the mailing list. This fact sheet again summarized the draftpublic health assessment and announced that due to the extensive hurricane damage in DadeCounty, we were extending the deadline for public comment to October 30, 1992.
We received six sets of comments on the draft public health assessment. Following is asummary of these comments and our responses:
Comment #1
One person pointed out that the March 20, 1992 Consent Decree defined the Superfund site as 30acres, not 291 acres.
Response:
Florida HRS and ATSDR are not bound by the site definition contained in the Consent Decree. Our definition of the site (Figure 2) includes all potential sources of contamination that mayaffect public health.
Comment #2
One person felt the draft failed to give adequate attention and credence to the 1987 H.J. RossAssociates Site Investigation Report that showed the landfill consisted of construction debris,yard trash, and household garbage. This person contends this report and the 1988 RemedialInvestigation Report demonstrate that Munisport is a typical landfill and not a hazardous wastesite.
Response:
H.J. Ross Associates observed material in 38 soil borings and 71 exploratory trenches in thelandfill. They failed, however, to collect any samples for chemical analysis. Many of thecontaminants of concern at this site are only detectable by chemical analysis. The 1988 EPARemedial Investigation also failed to collect any samples from the fill material. Therefore, weare unaware of any sampling of the fill material to determine if it contains hazardous chemicals.
In the 1988 Remedial Investigation, EPA did collect and analyze 10 surface soil samples fromthe landfill cover. These samples, however, were of the cover material, not the fill material. Tencover soil samples from the 170 acre landfill (1 sample/17 acres) are inadequate to fullcharacterize the extent of contamination in the cover material. These two studies failed todemonstrate this site does not contain hazardous chemicals.
Comment #3
Two people felt the draft public health assessment went beyond available information inasserting that residents' health complaints are unlikely to be site related. They pointed out thatassociation of specific symptoms with exposure to toxic chemical is an inexact art.
Response:
We will explain the difficulty in excluding environmental chemical exposure as a cause of healtheffects reported by nearby residents.
Comment #4
One person felt the public health assessment should specify which agency should carry out eachrecommendation.
Response:
Since public health assessments are advisory not regulatory, other agencies are not required tofollow our recommendations. Therefore, we have not specified which agency should carry outeach recommendation. We will, however, work with all local, state, and federal agencies toensure that our recommendations are carried out.
Comment #5
One person strongly agreed with our recommendation that the appropriate agency maintain a 15foot buffer free of vegetation between the site and the Highland Village mobile home park. Thisperson also strongly agreed that during any site remediation, construction, or development theappropriate agency control dust at the site and monitor air quality at the Highland Village mobilehome park.
Response:
We will work with the appropriate local, state, or federal agency to ensure that ourrecommendations are carried out.
Comment #6
One person pointed out that in 1985 the site manager and his family lived in an on-site trailer anddepended upon a nearby well for their drinking water. This person asserts during the time thelandfill was in operation some residents of the Highland Village mobile home park alsodepended on wells for their drinking water.
Response:
Although prior to 1974 Dade County moved municipal water supply wells further inland becauseof saltwater intrusion, some individual may have continued to use shallow wells for drinkingwater and irrigation. Since there were no analyses of water from these wells, we can not assessthe health risk.
Comment #7
One person pointed out that in 1987 the manager of a youth facility northeast of the sitecomplained that several boys developed serious skin infections after being cut or scratched.
Response:
Although we can not determine the source of these infections, it is possible they were the resultof swimming in the on-site lakes, especially if the levels of bacterial contamination had notchanged since 1982.
Comment #8
One person observed that distance of residence from a hazardous waste site is a poor measure ofexposure. This person also observed that the ZIP code used to survey cancer incidence aroundthis site includes a large number of people who do not live close to the site. This person alsopoints out that the failure to establish a link between the site and the health of nearby residentsmay be more indicative of the limitations of epidemiological methods than the lack of an effect. As a result this person does not feel that one can draw meaningful conclusion regarding theeffects of this site on the incidence of cancer.
Response:
We agree that distance of a residence from a hazardous waste site is a poor measure of exposure. Distance from the site, however, is the only readily available measure of exposure we have. Wealso agree that use of the ZIP code to survey cancer incidence includes a large number of peoplewho do not live close to the site. Unfortunately, ZIP code is the smallest geographical areasearchable in the Florida Cancer Data System. This person is also correct that failure to establisha link between a site and the health of nearby residents may be more indicative of the limitationsof epidemiological methods than the lack of an effect. We will highlight the limitations of theFlorida Cancer Data System and epidemiological investigations in general.
Comment #9
One person stated that the assumptions used to calculate fish and shellfish consumption were notcurrent and underestimate exposure 10 fold. This person also felt the draft relied too heavily on alimited set of fish-tissue samples and failed to consider bioconcentration.
Response:
Historically, a fish ingestion rate of 6.5 grams per day has been used as an average for both fishconsumers and non-consumers. We agree that there are more current and appropriate fishingestion rates. We will use 66 grams of fish and shellfish per day as the ingestion rate forrecreational fishers in Biscayne Bay. This rate is based on an estimate by Pao et al. (13) of 132grams per day (the 95th percentile daily intake averaged over three days for consumers of finfish) multiplied by 50% (an estimate of the percentage of a individual's total fish consumptionthat comes from Biscayne Bay).
We also agree that eight fish and oyster tissue samples is a limited number and call for furtherinvestigation of the extent of PCB contamination of fish and oysters in Biscayne Bay. Since werelied on direct measurement of PCB concentrations in fish and oysters as opposed to modelingfrom sediment or water concentrations, the relative contributions of bioaccumulation and/orbioconcentration are irrelevant.
Comment #10
One person suggested that landfill gases that currently migrate upward and dissipate may migratelatterly into Highland Village mobile home park if significant areas of the site are paved. Thisperson suggested that soil gas be monitored.
Response:
We agree that paving significant areas of the landfill could increase the lateral movement of soilgases. We will recommend soil gas monitoring if significant areas of the landfill near theHighland Village mobile home park are paved.



















