PUBLIC HEALTH ASSESSMENT
PETRO-PROCESSORS OF LOUISIANA INCORPORATE
BATON ROUGE, EAST BATON ROUGE PARISH, LOUISIANA
Figure 1 Site Location Map.
Figure 2 Topographic Features of Brooklawn Area.
Figure 3 Location of Monitoring Wells and Boring at Brooklawn Area.
Figure 4 Topographic Features of Scenic Highway Area.
Figure 5 Wells Location at Scenic Highway Area.
Figure 6 Area Location Map to include Devil's Swamp and Mississippi River
Figure 7 Area Location Map to include Demographic Block Groups
APPENDIX B: Health Survey for Alsen Community Residents.
APPENDIX C: Health Outcome Data.
Comparison Values
APPENDIX D: Open House/Information Hearing on Petro-Processors of Louisiana Inc,.
APPENDIX F: Response to Public Comment
Figure 1. Site Location Map.
Figure 2. Topographic Features
of Brooklawn Area.
Figure 3. Location of Monitoring
Wells and Boring at Brooklawn Area.
Figure 4. Topographic Features
of Scenic Highway Area.
Figure 5. Wells Location at
Scenic Highway Area.
Figure 6. Area Location Map
to include Devil's Swamp and
Mississippi River.
Figure 7. Area Location Map
to include Demographic Block Groups.
The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services
Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
HEALTH OUTCOME DATA SOURCE
LOUISIANA TUMOR REGISTRY:
The Louisiana Tumor Registry (LTR) is a population-based registry which covers all hospitals, radiation centers and pathology laboratories in the state. The LTR was first established in 1974 by Charity Hospital at New Orleans as a cancer registry for the New Orleans area and as a participant of the National Cancer Institute, (NCI). In 1979, it was transferred to the state's Office of Public Health as a pilot for a statewide registry. The LTR is now provided by the Louisiana State University Medical Center, P.O. Box 60630, New Orleans LA, 70160 (504-568-2616). Since 1983, LTR has gradually expanded by region, to cover the entire state by 1988.
The LTR is composed of 5 regional registries; each responsible for the complete recording of all cancer cases diagnosed and/or treated within its region. A monograph was produced in 1990 which includes all cases of cancer diagnosed during the period from January 1, 1983 through December 31, 1990. The monograph lists frequency of tumor occurrence (incident) cases by age, adjusted incidence rates by race, sex and region, cumulative rates (age 0 - > 74) and average annual age-adjusted rates. Incidence rates are computed using population estimates by age, sex, and race for each geographic region. The population estimates are obtained from the U.S. Bureau of the Census and Louisiana Tech University. In addition to the monograph, the number of cases grouped by cancer type, zip code and/or block group, age, and sex are maintained on a computerized database. This information is available for all of Louisiana from 1983 to 1990.
OFFICE OF VITAL STATISTICS:
The Office of Vital Statistics has been officially collecting vital statistics in Louisiana since 1877. At that time, the Louisiana Legislature transferred the Orleans Parish Vital Records Registry to the Louisiana Board of Health. The office is a participator in the national birth and death registration system and provides stillbirth and marriage data to the National Center for Health Statistics and Induced Abortion data to Centers for Disease Control. Certificates of vital events and reports of communicable diseases are listed by address, from 1960 to the present, and are available upon request. In addition, a monograph displaying trends in disease by Parish is produced annually.
TABLE 11: Standard Incidence Ratio of Cancer of the Trachea, Bronchus, & Lung (1983-1990)
| Age | Cases Observedb |
Population | Rate per 100,000 c |
Cases Observedb | Population | Rate per 100,000c | Expected Casesd |
| <5 | 0 | 182 | 25011 | 0.00 | |||
| 5-9 | 0 | 231 | 24388 | 0.00 | |||
| 10-14 | 0 | 264 | 22955 | 0.01 | |||
| 15-19 | 0 | 607 | 28264 | 0.00 | |||
| 20-24 | 0 | 172 | 33798 | 0.00 | |||
| 25-34 | 0 | 419 | 56797 | 0.00 | |||
| 35-44 | 0 | 356 | 42513 | 0.08 | |||
| 45-54 | 1 | 202 | 27020 | 0.45 | |||
| 55-64 | 0 | 176 | 22750 | 1.53 | |||
| 65-74 | 4 | 135 | 16274 | 4.61 | |||
| 75> | 4 | 68 | 9747 | 6.45 | |||
| TOTAL | 9 | 2812 | 309517 | 13.13 | |||
(a) Block groups 0041-1, 0042032, and 0042034 in Alsen
(b) Cases observed from 1983 to 1990
(c) Annual rate per 100,000 persons
(d) Expected cases for the population within the 3 block groups observed
Standard Cancer Incidence Ratio 0.69
CHI-SQUARE 1.26
P-Value >0.05
TABLE 12: Standard Incidence Ratio of Cancer of the Bladder & Urinary Systeme (1983-1990)
| Age | Cases Observedb |
Population | Rate per 100,000c |
Cases observedb |
Population | Rate per 100,000c |
Expected Casesd |
| <5 | 0 | 182 | 25011 | 0.00 | |||
| 5-9 | 0 | 231 | 24388 | 0.00 | |||
| 10-14 | 0 | 264 | 22955 | 0.07 | |||
| 15-19 | 0 | 607 | 28264 | 0.02 | |||
| 20-24 | 0 | 172 | 33798 | 0.00 | |||
| 25-34 | 0 | 419 | 56797 | 0.03 | |||
| 35-44 | 0 | 356 | 42513 | 0.11 | |||
| 45-54 | 0 | 202 | 27020 | 0.32 | |||
| 55-64 | 0 | 176 | 22750 | 0.52 | |||
| 65-74 | 1 | 135 | 16274 | 1.24 | |||
| 75> | 0 | 68 | 9747 | 2.40 | |||
| TOTAL | 1 | 2812 | 309517 | 4.71 | |||
(a) Block groups 0041-1, 0042032, and 0042034 in Alsen
(b) Cases observed from 1983 to 1990
(c) Annual rate per 100,000 persons
(d) Expected cases for the population within the 3 block groups observed
(e) Cases include bladder, kidney, renal pelvis and ureters.
Standard Cancer Incidence Ratio 0.21
CHI-SQUARE 2.94
P-VALUE >0.05
TABLE 13: Standard Incidence Ratio of Other Cancer Sites (1983-1990)
| Age | Cases Observedb | Population | Rate per 100,000c |
Cases Observedb | Population | Rate per 100,000c | Expected Casesd |
| <5 | 0 | 182 | 25011 | 0.02 | |||
| 5-9 | 1 | 231 | 24388 | 0.01 | |||
| 10-14 | 1 | 264 | 22955 | 0.89 | |||
| 15-19 | 0 | 607 | 28264 | 0.69 | |||
| 20-24 | 0 | 172 | 33798 | 0.23 | |||
| 25-34 | 0 | 419 | 56797 | 0.87 | |||
| 35-44 | 2 | 356 | 42513 | 8.09 | |||
| 45-54 | 4 | 202 | 27020 | 7.28 | |||
| 55-64 | 8 | 176 | 22750 | 8.57 | |||
| 65-74 | 5 | 135 | 16274 | 17.06 | |||
| 75> | 9 | 68 | 9747 | 32.03 | |||
| TOTAL | 30 | 2812 | 309517 | 75.74 | |||
(a) Block groups 0041-1, 0042032, and 0042034 in Alsen
(b) Cases observed from 1983 to 1990
(c) Annual rate per 100,000 persons
(d) Expected cases for the population within the 3 block groups observed
Standard Cancer Incidence Ratio 0.40
CHI-SQUARE 27.27
P-VALUE >0.05
TABLE 14: Standard Incidence Ratio of Cancer for All Sites (1983-1990)
| Age | Cases Observedb | Population | Rate per 100,000c |
Cases Observedb | Population | Rate per 100,000c | Expected Casesd |
| <5 | 0 | 182 | 25011 | 0.02 | |||
| 5-9 | 1 | 231 | 24388 | 0.01 | |||
| 10-14 | 1 | 264 | 22955 | 0.61 | |||
| 15-19 | 0 | 607 | 28264 | 0.71 | |||
| 20-24 | 0 | 172 | 33798 | 0.23 | |||
| 25-34 | 0 | 419 | 56797 | 2.76 | |||
| 35-44 | 4 | 356 | 42513 | 8.28 | |||
| 45-54 | 3 | 202 | 27020 | 8.05 | |||
| 55-64 | 8 | 176 | 22750 | 10.67 | |||
| 65-74 | 10 | 135 | 16274 | 22.92 | |||
| 75> | 13 | 68 | 9747 | 38.49 | |||
| TOTAL | 40 | 2812 | 309517 | 92.75 | |||
(a) Block groups 0041-1, 0042032, and 0042034 in Alsen
(b) Cases observed from 1983 to 1990
(c) Annual rate per 100,000 persons
(d) Expected cases for the population within the 3 block groups observed
Standard Cancer Incidence Ratio 0.43
CHI-SQUARE 30.13
P-VALUE >0.05
COMPARISON VALUES
Comparison values for ATSDR public health assessments are contaminant concentrations in
specific media that are used to select contaminants for further evaluation as to potential public
health effects. The values provide guidelines used to estimate a dose at which health effects
might be observed. Below is a list and description of the comparison values used in the section
Environmental Contamination and Other Hazards and in the Public Health Implications sections
of this public health assessment. Also enclosed are other acronyms used in this PHA.
| CREG | = | Cancer Risk Evaluation Guide |
| EMEG | = | Environmental Media Evaluation Guide |
| aEMEG | = | Environmental Media Evaluation Guide based on acute Minimal Risk Level |
| EPA SA | = | Environmental Protection Agency Site Assessment |
| MCL | = | Maximum Contaminant Level (µg/L) |
| MCLG | = | Maximum Contamination Level Goal (µg/L) |
| PMCLG | = | Proposed Maximum Contaminant Level Goal |
| MRL | = | Minimal Risk Level (mg/kg/day) |
| IMRL | = | Intermediate Risk Level |
| CMRL | = | Chronic Risk Level |
| LTHA | = | Lifetime Health Advisory |
| PEL | = | Permissible Exposure Limit (mg/m3) |
| REL | = | Recommended Exposure Limit (mg/m3) |
| RfD | = | Reference Dose (mg/kg/day) |
| RfC | = | Reference Concentration (mg/m3) |
| RMEG | = | Environmental Media Evaluation Guide based on EPA's RfD or RfC |
| ppm | = | parts per million =milligrams per liter (mg/L water) |
| = | milligrams per kilogram (mg/kg soil) | |
| ppb | = | parts per billion |
| = | microgram per liter (µg/L water) | |
| = | microgram per kilogram (µg/L soil) | |
| kg | = | kilogram |
| mg | = | milligram |
| µg | = | microgram |
| pg | = | picogram |
| L | = | liter |
| m3 | = | cubic meters |
| ATSDR | = | Agency for Toxic Substances and Disease Registry |
| NAAQS | = | National Ambient Air Quality Standards |
| LDEQ | = | Louisiana Department of Environmental Quality |
| DHH | = | Louisiana Department of Health and Hospitals |
| EPA | = | Environmental Protection Agency |
| LOPH | = | Louisiana Office of Public Health |
| SIR | = | Standard Cancer Incidence Ratio |
Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations that would be expected to cause no more than one excess cancer in a million (10E-6) persons exposed over a lifetime. CREGs are calculated from EPA's cancer slope factors.
EPA has not established a final cancer slope factor for benzo(a)pyrene. Therefore, the comparison value used for carcinogenic PAHs is based on an interim cancer slope factor.
The drinking water equivalent level (DWEL) is a lifetime exposure level specific for drinking water (assuming that all exposure is from that medium) at which adverse, noncarcinogenic health effects are not expected to occur.
Environmental Media Evaluation Guides (EMEG) are based on ATSDR minimal risk levels (MRL) and factor in body weight and ingestion rates.
Maximum Contaminant Levels (MCL) represent chemical concentrations 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 liters of water per day (for an adult).
Maximum Contaminant Level Goals (MCLG) are drinking water health goals set at levels at which no known or anticipated adverse effects on the health of persons occurs and which allows an adequate margin of safety. Such levels consider the possible impact of synergistic effects, long-term and multi-stage exposures, and the existence of more susceptible groups in the population. When there is no safe threshold for a contaminant, the MCLG should be set at zero.
A Minimal Risk Level (MRL) is an estimate of daily human exposure to a chemical (mg/kg/day) that is not likely to cause an appreciable risk of deleterious effects (noncarcinogenic) over a specified duration of exposure. MRLs are based on human and animal studies and are reported for acute ( 14 days), intermediate (15-364 days), and chronic (365 days) exposures. MRLs are published in ATSDR Toxicological profiles for specific chemicals.
The Occupational Safety and Health Administration's Permissible Exposure Limit (PEL) in air is an 8-hour, time-weighted average developed for the workplace. The level may be exceeded, but the sum of the exposure levels averaged over 8 hours must not exceed the limit.
EPA's Reference Dose (RfD) is an estimate of the daily exposure to a contaminant that is
unlikely to cause adverse health effects. However, RfDs do not consider carcinogenic effects.
OPEN HOUSE/INFORMATION HEARING ON PETRO-PROCESSORS OF LOUISIANA INC.
PERTINENT QUESTIONS:
The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services
Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
Comments on Petro-Processors Inc, Public Health Assessment
LOPH received numerous comments from the public during the comment period on the release
of the Petro-Processors Inc. public health assessment. All comments were noted and many
comments were addressed by making changes or additions to the text and/or tables. Other
comments are addressed by LOPH separately in this appendix. If the same comment was made
by several sources, the comment and response was listed only once.
| Comment 1: | Not enough community involvement in preparing the health assessment. |
LOPH/SEE and ATSDR encourages comments from the community during the entire process,
prior to writing of the Public Health Assessment, at public meetings, through the CAP.
| Comment 2: | The Public Health Assessment did not address the "total" environmental hazards to this community. |
The Public Health Assessment provides an analysis and statement of public health implications,
resulting from a community'S exposure to hazardous substances released from a particular site.
While the Toxic Release Inventory (TRI) lists many industries near the site that contribute to the
release of chemicals in the environment, it does not predict health effects. However, new
methods are being developed to better address the potential health effects of chemicals released
from several industries (Comparative Risk Analysis of the TRI Data as an Environmental
Indicator-A Louisiana Case Study, 1995, W. R. Lea, K. McManis and R. Alexander, Dept.
Environmental Engineering, Univ. of New Orleans, New Orleans, LA).
| Comment 3: | Door to door health surveys to gather new data or proactive health intervention were not performed. |
LOPH/SEE and ATSDR will continue to provide information regarding the exposure of
contaminants and health effects. A health survey of Alsen Community was conducted in Nov.
1980 with results provided in Appendix B. In addition, the Health Activities Recommendation
Panel (HARP) at ATSDR, suggests a health professional education program to be conducted to
advise local community members and health professionals of possible health effects.
| Comment 4: | The selected study population for health outcome data did not represent the exposed population. |
The health outcome data has been revised to better represent the exposed community. To
address this, current information was obtained by the Louisiana Tumor Registry and Vital
Statistics for block groups which are smaller than the traditional method of using zip code areas.
The block groups, 0041-1, 0042032 and 0042034 which include the community surrounding the
site were used to evaluate the health outcome data. The information is addressed on page 7,
Appendix A (map indicating the area included), and Appendix C, containing health outcome
data.
| Comment 5: | Off-site migration and contamination of groundwater and air was not addressed adequately. |
Recommendations provided in this health assessment and suggested by the HARP for follow-up
health activities included the assessment and impact of off-site contamination from groundwater
and air monitoring. A follow-up report on the residential well survey will be provided by LOPH.
| Comment 6: | Air monitoring at fence line was not adequate. |
Air monitoring data at the PPI site including the incineration data and data at the fence line is
currently being reviewed by ATSDR. Results and recommendations will be provided in a health
update in the future.
| Comment 7: | The choice of health outcome data was inadequate , miscarriages, incidence of low birth weight, birth defects, overall live birth incidence was not addressed. |
An analysis of the health outcome data including cancer incidence, low birth weight, and other
vital statistics did not demonstrate an increased number of health effects over the comparison
population.
| Comment 8: | The window of time chosen to study cancer was too limited and an extensive survey of all known health effects is needed. |
Health outcome data has been revised to better represent the community exposed and has been
expanded to cover data from 1983 to 1990. The results included cancer information available
and are presented in Appendix C, with a discussion of results on page 42.
| Comment 9: | The toxicological evaluation is unrealistic and should address total exposure, repeatedly for a long period of time. |
The toxicological evaluation for the contaminants of exposure at the PPI site, covered only
exposure scenarios specific for the site. This is a limitation of the field of study in environmental
health where very little information is known about combined exposures and synergistic effects
to populations located in urban environments and/or industrial corridors.
| Comment 10: | Recommendations in the health assessment are good, but not extensive enough (do not address the total environmental problems within the community. |
The recommendations in the Public Health Assessment are part of an ongoing active process of
health evaluations for the community. Assessments of health impacts to the community is
continuous and updates or site reviews are conducted periodically.
| Comment 11: | Hunting and fishing activities in Devil's Swamp should be addressed to include educational approaches as well as policing the area to keep people out. |
A health advisory exists for the Devil's Swamp area (Appendix E) recommending the limiting of fish consumption of all species of finfish to two meals per month. LOPH place a public service announcement in the Baton Rouge Advocate in 1993. In addition, several articles have been written regarding the fishing and hunting in Devil's Swamp. A fact sheet is currently being prepared.
Additionally, available data regarding crawfish and mammals obtained from Devil's Swamp, and
tested for contaminants has been analyses by Tulane School of Public Health in cooperation with
LOPH. The levels of contamination for HCB and HCBD were below levels that might pose an
adverse health effect. While there is no advisory for consumption of crawfish and mammals
obtained in this area, further sampling is recommended by LOPH/SEE and ATSDR.
| Comment 12: | Inorganics were removed from this edition of the Public Health Assessment. |
Within the public health assessment, chemicals released from operations that occurred on the site
are evaluated for dose and health effects, and are discussed in detail in the toxicology section.
| Comment 13: | Two separate plumes of groundwater contamination off-site from the Scenic Site (+ 40 ft MSL and + 20 ft MSL). Residents across the site are served by private water wells not accounted for in the assessment. |
A recommendation included in this document and suggested by the ATSDR Health Activities
Recommendation Panel is a follow-up report on the residential well use.
| Comment 14: | Surface water exposure in Bayou Baton Rouge between the railroad drainage ditch at PPI Scenic site and the upstream property boundary of Schuykill Metals was not addressed. |
The informational health advisory for Devil's Swamp and Bayou Baton Rouge is for the limited
consumption of finfish and exposure to surface water including swimming (Appendix E). The
advisory includes the area bound on the north by Hall Buck Marine Road, the east by the bluffs
and the Baton Rouge Barge Harbor, and on the south and west by the Mississippi River.
However, the area of concern should be considered beyond these boundaries due to frequent
flooding. Further sampling has been recommended.
| Comment 15: | The Health Department should consider expanding the advisory to include crawfish and other animals, as well as finfish. |
Examination of available crawfish data to date, by LOPH in cooperation with Tulane School of
Public Health, does not warrant at this time limited consumption of crawfish or other biota,
except finfish. Systemic toxicity to humans is determined by calculating the Margin of Exposure
(MOE). If the MOE for a specific chemical exceeds one (1.0), this indicates that a safe dose has
been exceeded. According to the analysis of samples at Devil's Swamp for HCB, HCBD,
Mercury, Lead and Arsenic, the level of concern was well below the safe dose. However, further
sampling and analysis is recommended by LOPH/SEE and ATSDR for crawfish consumption..
| Comment 16: | Subsistence fishing and hunting (people can not live on two meals a month) should be addressed. |
Please review the above comments 14 and 15, as well as the advisory in Appendix E. The
advisory is based on a wide margin of safety to reduce the risk of cancer or other diseases due to
exposure over a long period of time. Usually, chemicals are concentrated more in the fatty tissue.
The risk of exposure to theses chemicals can be reduced by following the methods of preparing
and cooking fish provided in the advisory. For crawfish, fatty tissue includes the head portion.
| Comment 17: | Calculate and assess the impact of the air emissions which occurred at the sites from 1965 to 1980. |
While exposure to air has been listed as a completed exposure pathway as defined by the ATSDR
Guidance Manual for Public Health Assessment. It is possible to predict exposure from on and
off-site exposures to volatile organic compounds during the release of volatile compounds in
1987, however it is not possible to accurately determine low chronic exposure during the
1965-1980 time period.
| Comment 18: | Risk associated with the incinerator operated on-site to treat the waste recovered from the recovery wells and sumps should be addressed. |
The air emission data for the incinerator, including the trial burn and routine fence-line
monitoring has been submitted to ATSDR for review. Results will be made available when the
analysis is completed.
| Comment 19: | House to house survey should be conducted by a doctor and/or nurse. |
One of the recommendations made by the ATSDR Health Activities Recommendation Panel is a
health professional education program designed to advise public health professionals. The focus
of this approach is to enable the medical community to better address the current needs of the
community.
| Comment 20: | Population data, and cancer incidence data of residents along Springfield road, including data from 1983-1987 were not addressed. |
As mentioned in response to comment 4 above, health outcome data has been revised to include
residents along Springfield Road.
| Comment 21: | Why does the assessment not concern itself with non-cancer problems. |
The health assessment does address non-cancer issues, covered in many sections; community health concerns, environmental contamination and other hazards, pathway and exposure analysis, toxicological evaluation, health outcome data and recommendations.
Once a concentration for a chemical of concern is determined and exposure assessments are
made (inhalation, ingestion, dermal contact, etc.), the dose is calculated. This involves
comparing chemical concentrations to a standard value, below which adverse health effects are
unlikely, The EMEG's and RMEG's are comparison values derived for health effects with
non-cancer end points, while the CREG comparison values are estimated contaminant
concentrations based on one excess cancer in a million persons exposed over a lifetime. These
values are very conservative and provide for a wide margin of human safety. If the concentration
exceeds this comparison value, then a dose is determined that takes into consideration levels of
contaminants (usually maximum levels), weight of the exposed individual, the rate at which the
contaminant could enter the body and the duration of exposure. If the chemical of concern is
non-carcinogenic, the dose is compared to a standard reference dose (RfD), or other standard
depending on the medium in which the chemical is contained (soil, water, air). A complete list
of these standards and explanation of how they are developed is presented in Appendix C. The
standards are based on research and determined to provide a wide margin of safety. If the dose
exceeds this value, recommendations are made to minimize exposure to these chemicals. Many
other factors that may have an effect include, genetic background, diet, and life style .
| Comment 22: | People in a one-mile radius and workers on-site should be interviewed. |
A health interview survey was conducted on November 17 & 18, 1980 by a team composed of a
physician, nurse and two public health investigators. In addition, health education activities for
the entire Baton Rouge Parish, were conducted in January 1995, including a physician education
packet that contained case studies to guide medical professionals through diagnosis, treatment,
and surveillance of persons exposed to hazardous substances. There was a 2.7% response by the
medical community. Also attempts were made to implement health education through the
schools regarding exposure and fish consumption in polluted areas.
| Comment 23: | Arsenic, lead and mercury are not part of Health Assessment. |
These compounds were detected in elevated levels off-site in Devil's Swamp. Exposure
scenarios for these hazardous substances are considered when implementing the informational
health survey for Devil's Swamp and Bayou Baton Rouge, limiting the consumption of finfish to
two meals per month and avoiding water contact. See Appendix E for the complete health
advisory.
| Comment 24: | Is the 400 ft aquifer closer to the surface in the Brooklawn area and poses more potential for contamination. |
The 400 ft aquifer appears to start at 110-120 MSL on-site at Brooklawn and appears from the
hydrology maps to be consistent at this level.
| Comment 25: | The definition and assumptions of MRL, RfD, EMEG and CPF's should be made understandable. |
Acronyms such as these describe standard values established by ATSDR and EPA to use as
comparison values below which adverse health effects are unlikely. However, this does not
mean that values above the comparison value will pose adverse health effects. A complete list of
the terms and standards used in preparing a Public Health Assessment is given in Appendix C.
| Comment 26: | Data on synergistic effects of substances in combination should be presented. |
At this time, research data is limited on combined effects of certain chemicals on human health.
As the information becomes available we will be better able to address this issue.
| Comment 27: | Exposure assumptions and parameters for measuring exposure were not similar to those developed by EPA. |
ATSDR uses more conservative exposure parameters for calculating exposure and dose such as; ATSDR's 10 kg for a child's body weight, compared to the 15 kg used by EPA, to calculate comparison values. Use of these lower parameters result in a wider margin of safety. However it must be remembered that other factors influence the health outcome such as genetic, diet and lifestyle.
As more information on exposure and health effects become available, these comparison values
are updated to better evaluate potential health effects.
| Comment 28: | LOPH/SEE appears to have based all their calculations for a given chemical on the highest detected concentration. |
Since it is impossible to determine the exact amount of exposure and chemical uptake into the
body, the highest concentration of the chemical determined from sampling, is used to calculate
the dose for each route of exposure and is totaled for all routes of exposure. This method is
conservative in approach to provide the maximum safe limit possible.
| Comment 29: | LOPH/SEE did not take into consideration an EPA approved Air Emission Risk Assessment performed in 1993. |
The 1993 Air Emissions data to include the trial burn for the incinerator located on-site as well as
current fence-line data, is being evaluated and assessed by the Agency for Toxic Substances and
Disease Registry (ATSDR). Information will be made available as soon as the evaluation is
completed. However, while data on past emissions is not available, inhalation exposure is
considered a completed pathway.
| Comment 30: | LOPH/SEE Public Health Assessment does not follow the guidelines established by ATSDR for writing Public Health Assessments. |
The Public Health Assessment Guidance Manual published by ATSDR is designed to provide a framework to evaluate public health exposures and their effects. It provides latitude to the health assessor to develop new approaches and allows for incorporation of professional judgement and discretion that better addresses the unique issues associated with a particular site.
