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PUBLIC HEALTH ASSESSMENT

AGRICULTURE STREET LANDFILL
NEW ORLEANS, ORLEANS PARISH, LOUISIANA


APPENDICES

APPENDIX I.

Site Description and Historical Operations

ASL is a 95 acre site in New Orleans, Orleans Parish, Louisiana. The ASL is predominantlyresidential with some commercial, retail and service businesses. ASL is 3 miles south of LakePontchartrain and 2.5-3.0 north-northeast of the city's central business district. ASL is bounded onthe north by Higgins Boulevard and south and west by Southern Railroads right-of-ways. Theeastern boundary of the landfill extends from the cul-de-sac at the southern end of Clouet Street,near the railroad tracks to Higgins Boulevard between Press and Montegut Streets.

Forty acres of the site were developed between 1970's-1980's for residences, Moton School, PressPark Community Center, and an electrical substation. Forty eight acres of the site is undevelopedand vegetated. The undeveloped area lies on the western and extreme southern portions of the ASLsite. EPA Region VI has installed an eight foot high fence around this area.

Single family housing units includes Gordon Plaza Subdivision. Multiple family housing unitsinclude Housing Authority of New Orleans (HANO) and Gordon Plaza Apartments. Moton Schoolis located on the eastern part of the ASL. Press Park Community Center is located on the southeastcorner of Benefit and Press Streets. A recreational center is located on the southeastern portion ofthe site, northwest of the intersection of Feliciana and Industry Streets. The recreational center isused for indoor basketball. The playground is located north of the recreational center.

Table A-1 describes the historical operations conducted at the ASL and the activities that resulted in the closure of ASL.

Table A-1.

Historical Operations of ASL
Date Site Operation
1909 Area authorized to be used as a landfill; household, city services, and commercial waste accepted.
1921 City of New Orleans approved ASL as receiving point of city's garbage. Incinerator waste also deposited here from city incinerator.
1934 Primary waste accepted was commercial waste.
1946 Primary waste disposed of was city garbage. Community begins development around ASL.
1948 Residents in the area complain of odors and smoke from dump fumes. A portion of the landfill area made into sanitary landfill.
1940-1950's Routine spraying of ASL with DDT.
1952 ASL reported closed because of public concern.
1962 300,000 cubic yards of excess fill removed from ASL because of subsurface fires.
1965-1966 ASL operated under emergency basis to accept debris and spoiled foodstuff from Hurricane Betsy.
1966 ASL officially closed. Some operations still reported in 1967.

Site Demographics

ASL lies within the 1990 U.S. Census Bureau tract 17.03. Of the 4,506 citizens that reside in thiscensus tract, 1,137 people reside on the ASL site. Approximately, 351 children under the age of fivereside in this census tract. Primarily, the population is African American (see Table A-2). Themedian age for this population is 28.5 years. The median income for this population is $ 11,279.There are single and multi-unit family dwellings, a school, and some light commercial industry in the area.

Table A-2.

1990 Census Data for Agricultural Street Landfill: Tract 001703
All American Caucasian American African American Native American Asian American Other American
4,506 309 4,136 6 19 9


APPENDIX II

Table 1.

CDC Guidelines for Interpretation of Blood Lead Results and Follow Up Activities
Class Blood Lead Level
(ug/dL)
Interpretation of Blood Lead Results and Recommended Follow-up Activities
I < or = 9 A child in Class I is not considered to be lead-poisoned.
IIA 10-14 Many children (or a large proportion of children) with blood lead levels in this range should trigger community wide childhood lead poisoning prevention activities. Children in this range need to be rescreened more frequently.'
IIB 15-19 A child in Class IIB should receive nutritional and educational interventions and more frequent screens. If the blood lead level persists in this range, environmental interventions should be done.
III 20-44 A child in class III should receive environmental evaluation and remediation and a medical evaluation. Such a child may need pharmacologic treatment of lead poisoning.
IV 45-69 A child in Class IV will need both medical and environmental interventions, including chelation therapy.
V < or = 70 A child with class V lead poisoning is a medical emergency. Medical and environmental management must begin immediately.


APPENDIX III

Public Comments on Agriculture Street Landfill Public Health Assessment

The following questions and comments were gathered from oral and written statements on the earlierrelease of the Public Health Assessment (PHA), from health concerns raised in other publicmeetings, and from health questions that were submitted to EPA. Similar questions and commentshave been combined together and others have been summarized.

Comment # 1:
By limiting non-carcinogenic health effects to the effects of lead, EPA failed to consider reproductive risks and developmental risks.

LOPH/SEET Response:
The health assessment did not limit non-carcinogenic health effects to just lead. Both the carcinogenic and non-carcinogenic health effects of each contaminant of concern was evaluated.

Comment # 2:
I am concerned that the 1994 blood lead screening in the area wasn't done right. There was low turnout so it's not representative. This HA was very unfair to the citizen's of this community, due to the fact that almost none of the lead tests that the children of this community received test at the location cited in your report. Please assist us by providing on-site testing or we can provide you with copies from our private physicians.

LOPH/SEET Response:
The blood lead screening in 1994 conducted by the City of New Orleans was a voluntary screening program that was advertised in the community. Everyone that wanted to was able to get the free blood lead test. It was not a randomized, controlled study, so it was not intended to perfectly represent the area. As a screening, it can give an indication whether there is a public health problem.

In order to compare the Agriculture Street Landfill area with other communities in the city, weonly reported the results of those children (up to 6 years of age) with reported residentialaddresses on the site. We did not include others that also had their blood tested in this screening. In addition, because of the small numbers, we also looked at 2 years of data from the HelenLevy Clinic and, again, only included children living on the site.

Blood lead testing is available for small children as part of city health unit programs, includingones at the Helen Levy Clinic on Louisa St. Any elevated levels of lead are reported to the stateand follow-up activities are conducted according to CDC guidelines (see Appendix II). Inaddition, ATSDR, with help from LOPH/SEET, is planning to provide Environmental HealthServices to the ASL community. Please contact Dalton Savwoir at LOPH/SEET for currentinformation on this project, 568-5072.

Comment # 3:
Even if yards are cleaned up, lead could pose a continuing problem. Finding 18% >10mg/dL is significant because of other exposures. Children will have increased exposure to lead as yard soils are excavated. No safe level of lead in children.

LOPH/SEET Response:
If the yards with elevated levels of lead are cleaned up as recommended, exposure to lead in the soil will be reduced. However, we are all potentially exposed to lead from a number of sources besides this site, such in food, water, paint chips, dust, etc. In addition, a number of areas in New Orleans have very high lead levels in the soil. Therefore, exposure to lead should be an area of concern for all of us.

We agree that there is no safe level of lead in children. Any child with blood lead levels greaterthan 10 ug/dL should be followed up according to CDC guidelines. This is a significant resultfor that child. The purpose of the comparison in the public health assessment is to show that asa group, the children living over the site do not have higher blood lead levels as compared to thechildren tested in other New Orleans health clinics.

The concern about increased exposures due to soil removal activities has been addressed byEPA in their dust suppression plans and air monitoring program. Dust will minimized bykeeping the surface soil wet and particulates will be collected and analyzed during removalactivities. LOPH/SEET is also committed to reviewing these results to ensure no significantexposures.

Comment # 4:
Some blood lead levels are above levels requiring attention. Children with blood lead levels over 10 ug/dL should be evaluated for potential sources of lead. Then the sources removed from contact with the children.

LOPH/SEET Response:
Any child with blood lead levels greater than 10 ug/dL should be followed up according to CDC guidelines (see Appendix II). This follow-up is directed by the family physician or by the health clinic where the test was conducted.

Because lead is very common in our environment, the children at the ASL site are likely beingexposed to several different sources of lead. However, as stated in the PHA, soil tests haveindicated that some areas on the ASL site have elevated lead levels and we have made recommendations to eliminate this as a potential pathway of exposure.

Comment # 5:
In a Site Update date September 16, 1993, it was stated that the high blood lead levels found during the 1986 blood tests could be partly attributable to the proximity of the ASL site to a major highway system at a time when leaded gasoline was in use. It was further stated that since the use of leaded gasoline has now been banned that blood lead levels could be expected to be "significantly lower". Has any blood lead tests been conducted on residents since the 1986 to determine if this has occurred?

LOPH/SEET Response:
Please see the Health Investigation Activities Section in this Public Health Assessment for additional review of blood lead test results in 1993 and 1994. The blood lead levels are lower in the more recent years, however this is based on a screening of a small number of volunteers; a rigorous study was not conducted to evaluate this.

Comment # 6:
Why weren't kids older than 6 years old tested for lead?

LOPH/SEET Response:
In general, blood lead tests are recommended for small children because their greater exposure potential and their greater sensitivity to the effects of lead. Young children tend to exhibit hand-to-mouth behaviors that increase their exposure to lead from their environment. If children consume lead-contaminated materials, such as soil, house dust, or paint chips; they absorb more of the lead from their stomachs and intestines than adults do. Lead is particularly harmful to the developing brain and nervous system of young children.

Older children and adults may be tested for lead in special circumstances (such as in certainoccupational settings), but are not routinely tested. The 1994 Special Blood Lead Screeningdone by the City of New Orleans did test a few older children and adults. These results were notreported in the health assessment since we were trying to compare the same age group as testedin the city health clinics.

Comment # 7:
When will the cleanup of contaminants be completed? How can you safely clean it up and when will it begin?

LOPH/SEET Response:
The Environmental Protection Agency, EPA, is the agency responsible for the clean-up or remediation of this site. As of January 1999, EPA was conducting soil removal activities in the undeveloped area of ASL. EPA has responded to citizen concerns of additional exposure by developing work plans to reduce dust, prevent surface water run-off, and monitor the air quality.

Comment # 8:
The grass and weeds are not cut on a timely basis. We were told that this area would be maintained. Everything is dumped along this fence.

LOPH/SEET Response:
Since EPA removal activities have begun, the grass and weeds have been trimmed. If there are future problems with weeds or trash, these concerns would best be addressed by EPA or the City of New Orleans.

Comment # 9:
Would cutting down the trees in the undeveloped area expose airborne contaminants?

LOPH/SEET Response:
Possibly. The contaminants in the ASL site are generally bound to soil particles. Therefore, if trees are cut down, it would be important to suppress the exposed soil from blowing around in the wind. This is often done by keeping the soil wet.

Comment # 10:
Information in the Health Assessment for this site should be re-evaluated to determine whether the proposed clean-up remedy will be safe for the community.

LOPH/SEET Response:
The conclusions and recommendations in the Health Assessment still apply to the current situation. In the developed, residential area of ASL, scattered pockets of elevated lead, arsenic, and PAHs need to be addressed. As of this writing, the extent of cleanup in the residential area is still being determined.

The undeveloped area of the site has been classified as a public health hazard if developedresidentially. Right now, EPA is providing a barrier to these contaminants in the undevelopedarea. Future land use of this area has not been determined.

Comment # 11:
What about the problem when not all yards are cleaned?

LOPH/SEET Response:
EPA has decided to conduct a voluntary soil removal program. Each property owner needs to evaluate their situation and decide whether to allow the soil replacement. If areas of elevated contaminants are not cleaned up, there is the possibility of exposure at levels of health concern.

Comment # 12:
Cutting grass in undeveloped area might cause rodents to infest neighborhood.

LOPH/SEET Response:
This concern has been addressed by EPA in their rodent control program. So far, there have been no reports about rodents moving into the residential areas.

Comment # 13:
The executive summary should be mailed directly to each resident in the area bounded by Florida Avenue, Almonaster, I-10, and Alvar Street.

LOPH/SEET Response:
Comment duly noted. We will check our mailing list and see if we can expand it.

Comment # 14:
Some residents didn't receive notice of public meeting about the PHA (public comment release).

LOPH/SEET Response:
We sent a notice to everyone on our mailing list. We will try to update this list for the final release.

Comment # 15:
Have ATSDR HARP recommendations been followed? Was the community informed of the findings of the PHA by LOPH/SEET and ATSDR? Is public health education occurring now? Did ATSDR Division of Health Studies review the findings and make recommendations for any follow-up actions?

LOPH/SEET Response:
Yes, the ATSDR HARP recommendations are being followed. There was a public meeting to release the public comment version of the PHA; notices were sent to over 500 households. Physician and community health education has been conducted in the past and will continue in the Environmental Health Services project being developed by ATSDR. The ATSDR Division of Health Studies (DHS) did review the findings of the PHA and Health Consultation on Health Outcome Data. DHS worked with LOPH/SEET in developing recommendations for the Health Consultation.

Comment # 16:
The terminology used in the PHA has only made me more skeptical of what is not being told from the testing. There are too many instances where one sentence tells you there are contaminants, metals and pesticides were detected, lead was found, levels were higher than normal. Then another sentence tells us these things do exist, but the majority of, generally, most of, not significantly contributing, should be, not expected to. These statements do nothing to squelch the anxiety and concern about and for my health and the health of my family and neigbors.

LOPH/SEET Response:
The reason for the seemingly contradictory language of this PHA is that this document has several objectives. One objective is to inform the public about all contamination present at the site while another objective is to distinguish between what contaminants are present and what is present at levels of concern. The presence of a contaminant in a medium (air, water or soil) does not automatically mean it is harmful. The contaminant must be present at high enough levels to cause harm to an individual before it can be called a health threat. Therefore, once a contaminant is identified, it's concentration must be considered. Unfortunately, it is not possible to say with complete confidence that a contaminant is safe all the time and under all circumstances, since so many variables exist. This is the reason for such qualifying statements as "not significantly contributing" and "not expected to".

Comment # 17:
Some members expressed concern that our source of data is EPA.

LOPH/SEET Response:
In general, the health agencies rely upon the environmental agencies, like EPA and the state LDEQ, for sampling data. We are not funded to do our own testing. If other quality data are available, we will review them and include them in our assessment.

For this site, EPA's Remedial Investigation (RRII) provided the most current and complete dataon soil and air for us to review. If the health agencies have any concerns about the type orextent of the sampling effort, these would be listed in the health assessment and brought to theattention of EPA.

Comment # 18:
Dioxin is not mentioned in the front portions of the report. It is only mentioned in the analytical data. I would like dioxin listed as a contaminant on the summary page of the PHA.

LOPH/SEET Response:
On the summary page, we try to focus our readers' attention to areas of possible concern, rather than listing all the contaminants found on-site. As dioxin was found at very low levels and does not pose a health threat, it was not included in the summary page.

Comment # 19:
We want a buy-out/relocation as soon as possible. (25 times)

LOPH/SEET Response:
EPA or the responsible parties for the site would have to offer a "buy-out". The health agencies do not have that authority. However, if the health agencies felt that an urgent health hazard existed, we would make the appropriate recommendations to protect the public health.

Comment # 20:
I feel if there were more than 100 chemicals at the beginning when the EPA first did the test, no one will make me believe that there is only four chemical and tell me that they are not hazardous. Are the primary contaminants found in the soil listed in the report the only contaminants found in the soil? Why have you only listed these? What about the others that poses a much greater threat to the community?

LOPH/SEET Response:
Across the country, every site, and even every backyard, tested will have many chemicals present. With the highly sophisticated laboratory analysis these days, very small quantities of chemicals can be detected. As little as 1 part of a chemical in 1,000,000,000 parts of soil are often reported. Sometimes, they are naturally present, such as arsenic which is found in background soils throughout Louisiana. Sometimes, the chemicals are from man-made sources, such as automobile exhaust, factory emissions, household pesticide use, or waste sites.

At every site we work on, a long list of chemicals are detected. The chemicals which are far, farbelow levels known to cause health effects are not included, so the health assessment can focuson those which may possibly be of health concern. In the ASL public health assessment, over 40compounds and their concentrations were listed as they were detected in at least 25% of thesamples or they were present at levels of concern. Of these, only lead, arsenic, and PAHs werefound at high enough levels to warrant health concerns. In summary pages and in fact sheets,only these 3 are mentioned in order to focus attention on possible risks. A more in-depthdiscussion is included in this document. To list over 100 chemicals every time we talk about thesite would only confuse the real issues of public health.

Comment # 21:
How can our soil be safe and the soil on the only undeveloped site not be safe? We do not understand or believe that the contamination levels of the undeveloped area and the developed area are different.

LOPH/SEET Response:
Because people have the greatest exposure to the soil in the top few inches (surface soil), most of the health issues hinged on the levels of contaminants in the surface soil. The extensive data collected by EPA showed that the contaminant levels in the undeveloped area were higher than those in the developed area and that is why the areas have different hazard categories.

The public health assessment also reviewed the levels of contaminants in the subsurface soil. Because the exposure to those contaminants would be infrequent and of short duration, noadverse health effects would be expected.

Comment # 22:
The threat of run-off and migration of chemicals from the contaminated undeveloped area to the developed area has not been adequately addressed.

LOPH/SEET Response:
The type of contaminants at this site adhere to soil particles and are not very soluble in water. Therefore, the contaminants will not flow easily with water from rain or floods. In addition, current soil removal activities by EPA on the undeveloped area will create a barrier over the contaminants and will slope the undeveloped area away from the residential area.

Comment # 23:
This is no new information. This is the same information given by EPA. This is not a Health Study done for the immediate community.

LOPH/SEET Response:
A Public Health Assessment (PHA) is an evaluation of relevant environmental data, health outcome data, and community concerns. It is not intended to be a health study, but rather a PHA may lead to a health study if warranted. Although there is some overlap with EPA, a Public Health Assessment has different purposes and goals as compared with EPA's risk assessment process. That both agencies came to similar conclusions should be reassuring to the community.

As an example of where the PHA process can lead, look at the Environmental Health Servicesbeing developed for the ASL site. Comments on the PHA led to LOPH reviewing cancerincidence data and other health outcome data. From this review, it became clear that there weremany health concerns in the area that were not easily addressed. Therefore, ATSDR proposedan Environmental Health Services project to address individual's health concerns as they relateto the ASL site.

Comment # 24:
Is it possible that many of us will eventually get sick from living here? A number of individual felt their health problems and their family's problems are due to site...

LOPH/SEET Response:
From the environmental data reviewed in this health assessment, the contaminants are not at levels that would cause you to get sick from present exposure (the undeveloped area is a public health hazard if developed for future residential use). However, to be safe, we do recommend that a few scattered pockets of contamination that be addressed to limit exposure to lead, arsenic, and PAHs.

We also reviewed health outcome data (blood lead levels, cancer incidence, and birth outcomes)to see if there were unusual rates of illness in the community. All of the above health data for thearea around the ASL site was similar to comparison areas, except for breast cancer rates. Thecause for the increased breast cancer rates in the area could not be determined from that review. See the October 1997 Health Consultation for the ASL site for an in-depth discussion on thecancer rates.

As a follow-up to the Public Health Assessment and the Health Consultation, ATSDR is developing a Environmental Health Services project. This project will address an individual's healthconcerns as they relate to the ASL site.

Comment # 25:
Have any exposure investigations, neurological test batteries or enzyme tests been done in the community to find out whether they already bear a body burden or effects from the contamination? This should be considered before final decisions are made.

LOPH/SEET Response:
In order to propose specific health studies such as you suggest, there should be evidence of exposure to contaminants at levels of that would likely cause these effects. We have not seen data that would suggest this.

Comment # 26:
Overall, the assessment lacked consideration to exposure levels as it relates to factors inherent to the individual, such as the age, sex, body weight, immunological status, genetics, health, and emotional state.

LOPH/SEET Response:
Individual factors, such as you stated above, do affect exposures to chemicals and their related health effects. However, for the purposes of a health assessment, we attempt to draw conclusions and make recommendations that will protect public health as a whole. This approach will be more conservative (i.e. protective) than looking at just one individual's situation. That is also why an individual needs to see their personal physician for specific health concerns, so that their physician can take all these factors into account when making a diagnosis and a treatment regimen.

Comment # 27:
Are there any findings regarding the past health experiences of the residents of ASL, including incidences of cancer and mortality rates? Have doctors for the community been interviewed regarding problems? There should be a review of any cancer registries, of hospital data on cancer, and of birth defects.

LOPH/SEET Response:
Yes, there has been a review of cancer incidence rates and other health outcome data in the October 1997 Health Consultation for the Agriculture Street Landfill. Please call LOPH Section of Environmental Epidemiology and Toxicology at 504-568-8537 for a copy of the Health Consultation. Although birth outcomes, such as stillbirths and low birth weights, were reviewed in the Health Consultation, there is no registry in Louisiana of birth defects.

Comment # 28:
A list of people who have died at the Agriculture Street Landfill site should be made.

LOPH/SEET Response:
A list of ASL residents who have died would not enable us to make a determination about the potential health threat of the site since we would need to know the cause of death as well as other information. Many factors play a role in the one's illness and death. The best health outcome data available to us (cancer incidence, blood lead levels, and birth outcomes) have been reviewed in the Health Consultation and this Public Health Assessment. Call 504-568-8537 for more information.

Comment # 29:
There are unusual amounts of cancer noticed in people living on the site. Can a door-to-door survey be done to find out information regarding cancer and respiratory problems?

LOPH/SEET Response:
Cancer incidence rates have been reviewed in the October 1997 Health Consultation done for this site (see the response to comment #27). The source of the cancer data was the Louisiana Tumor Registry, which provides more complete information than we could obtain in a door-to-door survey.

There is no state or local registry of respiratory problems that we could easily and reliably useto calculate rates. Respiratory illnesses are common and have many causes. Therefore, a door-to-door survey would not give us the information we need to find a cause or even say if thenumber of illnesses is high. However, some of these individual concerns may be addressed inATSDR's Environmental Health Services project which is now being developed. Please callDalton Savwoir, Jr. (with LOPH at 568-5072) for more information.

Comment # 30:
The short and long-term health effects should be identified and provided to the community during educational outreach activities.

LOPH/SEET Response:
We agree. The Public Health Assessment addresses the short and long-term health effects in the section entitled, "Extent of Contamination and Toxicological Implications of Exposure". A summary of this information is usually contained in fact sheets which are widely distributed. The need for additional health education in the ASL community will be continually reevaluated.

Comment # 31:
A medical (health) monitoring program for the community should be funded and implemented. A testing program for lead levels and the other top toxins found on this site should be provided.

LOPH/SEET Response:
Past testing of blood lead levels has not shown elevated rates as compared to the rest of the city (see the Health Investigation Activities section in this PHA). However, CDC guidelines do encourage all parents to have their children (0-6 years old) tested for lead in their blood. This testing can be done by a private physician or in the parish health units, such as Helen Levy clinic. Other health concerns may best be addressed by ATSDR's new Environmental Health Services being developed for this site. Please call Dalton Savwoir, Jr. (with LOPH at 568-8537) for more information.

Comment # 32:
The risks to children living over the site appears not to have been fully studied. Wouldn't this situation be a good one for the ATSDR Child Health Project to evaluate?

LOPH/SEET Response:
The risks to children are already considered in this health assessment, as we recognize their unique exposure routes and susceptibility to contaminants in the environment. The Child Health Initiative is ATSDR's special effort to address environmental threats to children's health. At present, this initiative does not have specific funding to carry out new site assessments, health investigations, or monitoring of population, nor does it alter ATSDR's established criteria for such actions. Instead, an effort is underway to emphasize child health issues in all existing programs.

Comment # 33:
My grandchildren have eaten from a garden that I had planted in my back yard. They are suffering with asthma. My grandchildren are having a rough time. Please help me.

LOPH/SEET Response:
Vegetables grown at the ASL site have been sampled two times, in 1984 and in 1994. Based on the levels of metals and pesticides measured, the vegetables should be safe to eat.

Individual cases of asthma are best evaluated by a personal physician who can look at andconsider all the factors that may contribute to the illness in that child. In addition, you may wantto contact ATSDR's new Environmental Health Services that is being developed for this site. Please call Dalton Savwoir, Jr. (with LOPH at 568-8537) for more information.

Comment # 34:
Data from Superfund sites suggest that proximity to hazardous waste sites is associated with increased risks of some types of birth defects. What do we know about birth defects, childhood cancers and reproductive disorders? Also children, have there been reports of early puberty, hormonal disturbances?

LOPH/SEET Response:
In the 1997 Health Consultation, we reviewed available health outcome data, which included cancer incidence, infant mortality, prematurity, term low birth weight, and stillbirths. No registries exist in Louisiana which record birth defects and reproductive disorders. We have informally heard of one case of early puberty in the ASL community. Since an apparent increase in early puberty has been reported all around the country, we have no reason to link this situation to this site. If you have specific information on these health problems in the community, please contact LOPH Section of Environmental Epidemiology & Toxicology at 568-8537.

Comment # 35:
The entire PHA ignored cumulative health effects due to many chemicals and many sources. The synergistic effects from the chemicals that are associated with this site is an issue that needs to be addressed before any solution or remedy is instituted at this site. Has any studies or tests been done to determine the possible human health risks posed by these different chemicals acting in combination with one another?

LOPH/SEET Response:
The PHA is based on the most current science available. When chemicals are present above screening levels and may cause similar health effects, then additivity is assumed. Much research has been done on health effects of mixtures and combinations of chemicals. So far, the research seems to point to the additivity model. Applied public health practice generally is not based on only one research study, but on repeated experiments that eventually come to a consensus on that theory. Please see the response to comment #36 below for additional information on synergistic effects.

In addition to looking at the environmental data, we also reviewed available health outcomedata, which also may reflect combined effects of contaminants. Please see the Health Investigation Activities section in this PHA for this discussion.

Comment # 36:
Not enough information is provided on dioxin and pesticides, particularly in the house dust in the homes. Dr. McLachan of Tulane has done published a paper on the synergistic effects of pesticides. Has anyone consulted these scientists at Tulane?

LOPH/SEET Response:
The levels of dioxin and pesticides found in the soil at this site are summarized in this PHA. Dioxins never were detected above 1 ppb and are below levels of health concern. The level of pesticides in the soil also do not pose a health threat. EPA tested the dust in homes for lead because paint chips may contribute to lead exposure. No other contaminants were tested for in house dust. Assumptions are made in calculating exposure to soil contaminants that include inhaling dust particles.

Dr. McLachlan's paper, "Synergistic activation of estrogen receptor with combinations ofenvironmental chemicals", that was published in the June 1996 Science journal created quite astir regarding the synergistic effects of chemicals. However, since then, the paper was retractedby the authors (Science, July 1997) when no one could reproduce the results. The authors makeit clear that no conclusions should be drawn from this paper.

Comment # 37:
Dioxin hazards at this site are underestimated by ATSDR. Dioxin was detected everywhere on site. The PHA does not state whether it is measured as dioxin-TEQ or TCDD. Studies have said that highly exposed populations may be at special risk.. Also there is special risk from disturbing dioxin-contaminated soil.

LOPH/SEET Response:
First, the PHA is written for the community and as such, we attempt to avoid too many technical terms. That is why we discussed "dioxins" and did not clarify the congeners included in this general term. As discussed in EPA's RRII document on page 4.1-3, the dioxin results are presented as toxicity equivalents or TEQs. This includes dioxin-like compounds as well as 2,3,7,8-TCDD.

Dioxin is a common environmental contaminant in many urban areas. The levels found in theAgriculture Street Landfill soil are low (all less than 1 ppb) and below levels of health concern. Although it is not clear what studies you are referring to, this community would not be considered a "highly exposed population", because the levels in the soil are low. The concern aboutadditional exposure during soil removal activities has been addressed by EPA in their dustsuppression and air monitoring plans.

Comment # 38:
Groundwater should not be eliminated as a pathway of exposure because soil subsidence will cause water line breaks, cracks, and separation. The drinking water system may then become contaminated.

LOPH/SEET Response:
The municipal water supply is a pressurized system. If a crack were to develop due to subsidence, water would move from an area of high pressure to low pressure (ie: out of the pipe). It is not possible for soil to enter the water lines as long as it is pressurized. If water pressure was lost due to a large break, soil could enter the pipe but then no water would be flowing to the tap and the soil would sit in that location. The pipe would then have to be cleaned and repaired before the water flow could resume and again no contaminants would be able to enter the system.

Comment # 39:
There are an unusual number of broken pipes in area. Sewerage and Water Board has had to fix a lot of problems in area.

LOPH/SEET Response:
Because of this community concern, LOPH contacted the New Orleans Sewerage and Water Board (S&WB) and requested a comparison in the number of broken pipes at the ASL site as compared to other areas in the city. Although we were initially told that this comparison was possible, the S&WB later declined to give us specific results and simply summarized the situation as normal for the city.

In the few incidences of broken pipes that LOPH has looked into, the cause appears to be theresult of subsidence (soil level dropping). Subsidence is a common problem in New Orleans, butalso may result from degradation of organic materials in a landfill. We have seen no evidence ofpipes corroding.

Comment # 40:
All the homes are having plumbing problems. I called Sewerage and Water Board, and they sent a representative from their Environmental Department. The representative checked the sewerage system and the clean-out and found no obstructions. Yet my kitchen sink gives off a sewerage smell that is very sickening and unbearable. Tell me what is the problem? And what is causing it to happen?

LOPH/SEET Response:
We cannot tell what the problem is from this information. The water from the tap comes from the New Orleans municipal water supply and it does not come into contact with the soil at the ASL site. Does the odor seem to come from the tap water or from the drain? A plumber would have to check these potential sources of odors.

The other possibility would be that the odor is coming from the ground and traveling along theoutside of the pipes and into your home. In this case, the odor may be strongest under the sink,near where the pipe enters the wall or floor. From the EPA's sampling of indoor and outdoorair in the 1994, volatile organic compounds were not found to be migrating from the soil. However, if you suspect this is occurring , please contact the EPA remedial project manager orcall LOPH at 504-568-8537.

Comment # 41:
The exposure levels are based on soil levels at 0-3 inches. This is not appropriate in this area due to subsidence, cracking of soil, and human activity. We know that even higher levels of contaminates (and a wider range of chemicals) can be found at soil levels beyond 3 inches.

LOPH/SEET Response:
The PHA did evaluate exposure to subsurface soil also, but the exposure is so limited (such as workers occasionally digging) that this did not represent a health threat. We did focus on the top few inches of soil since this is what residents will come into contact with daily. Subsidence can cause the soil to sink deeper, but the exposure would still be to the top of the soil.

Comment # 42:
Long-term indoor exposures to air and dust were not adequately addressed. Volatiles were detected in the air samples. It is inappropriate to base decisions on a health assessment that considers only short-term exposures. There is a need to calculate long-term exposure. The members of this community are living here for the long-term.

LOPH/SEET Response:
The findings of the short-term air analysis did not show any elevated levels of VOCs. The levels found were comparable to the levels and types of compounds found in most urban environments. Additionally, there was no correlation found between the organic compounds in the soil of the ASL site and the VOCs found in the air. Therefore, if there are no elevated levels of VOCs in short-term tests, it is very unlikely that there would be significant levels found with long-term tests, especially since the VOCs detected were not site related.

Comment # 43:
The entire assessment lacked consideration of what types of exposure are possible due to soil subsidence and disruption of soil integrity. Moton School had the lowest amount of contamination in a number of areas of the report. If you only looked at 0-3 inches, this should have been the new soil cover. It should not have been contaminated unless contaminates are moving around on the site. Dioxin was found in the soil at 0-3 inches at the school. How did it get there if this was clean soil?

LOPH/SEET Response:
Subsidence is a common problem in New Orleans. However, this is not a probable method for high concentrations of contaminants to rise to the surface. This is especially unlikely since subsidence in a sinking phenomenon.

Dioxin is a common environmental contaminant and is present in many urban areas at lowlevels. The very low level of dioxin found at the school (.0003 ug/kg or ppb) does not necessarilyindicate that contaminants migrated from deeper soil. Dioxin can be present in ambient air orcould have been present in the fill material when the school was built.

Comment # 44:
The health complaints listed in the ATSDR Health Assessment are unusual and high and have not been addressed. Problems identified by the Xavier University health survey must be more fully investigated. The survey concludes that this is a "community that suffers from an inordinate number of health complaints".

LOPH/SEET Response:
As stated in the Health Investigation Activities section, the health survey, conducted the Deep South Center for Environmental Justice at Xavier University, cannot be used to determine if illnesses are more frequent in the ASL community. The conclusions are not supported by comparing this population with any other.

However, the survey does represent the health complaints of people in the area. The Environmental Health Services project currently being developed by ATSDR will address some of thesehealth concerns. Please call Dalton Savwoir, Jr. (with LOPH at 568-8537) for more information.

Comment # 45:
Why should be believe your figures and your results? The city has never been honest with us about the health risk it poses.

LOPH/SEET Response:
We cannot force you to believe something. All we can do is present the facts and our evaluation as objectively as possible and invite you to make an informed decision. As public health professionals, we do not have a vested interest in the outcome of the site and feel we can offer our assessment to the community in an unbiased manner.

Comment # 46:
The PHA states there is grass cover on the playground at the school. This grass cover will not exist if the school is reopened and students are allowed to transit this area.

LOPH/SEET Response:
It is true that a portion of the grass may die due to frequent traffic, but the majority of the playground will remain covered with grass. Additionally, the soil around the school is very clean and exposure to the soil would not represent a health risk to children at the school.

Comment # 47:
If testing was done more thoroughly (more samples), would greater contamination be found?

LOPH/SEET Response:
The sampling done by EPA for the RRII report was very thorough and adequately represents the level of contamination. We do not feel that any significant differences would be found with additional sampling. The only exception to this was for the soil gas measurements. LOPH and ATSDR made recommendations for additional soil gas sampling to EPA during the public comment period of the Record of Decision (a copy of these comments are included in the Record of Decision document, appendix I, page1-31). EPA is currently conducting more soil gas sampling during their removal activities.

Comment # 48:
On Sundays, people go into recycling area on undeveloped land.

LOPH/SEET Response:
Thank you for this observation. We also noted a walking trail into the undeveloped land and mentioned this potential for exposure in the Pathways of Exposure section. In the past, LOPH has reported breaks in the fence to EPA, so they could repair it. Currently, since EPA is conducting removal activities on the undeveloped area, they have secured the area.

Comment # 49:
Why did the EPA declare our site a Superfund site? If this land is not toxic, why would the EPA declare this a Superfund site? Tell me why have the school been closed? Please don't tell me the land the school was built on is safe and not toxic. Be realistic, had it been non-toxic, the school would have never been closed.

LOPH/SEET Response:
Although LOPH/SEET can not speak for the EPA, it our understanding that the site was listed, based on preliminary studies, so that appropriate actions could be taken (further investigation and site characterization). The extensive sampling that was conducted in the remedial investigation (and the basis for our health assessment) was done after the site was listed on the NPL.

According to New Orleans Public School officials, the school was closed because of thecontroversy surrounding the site. Although school officials did not feel there was a problem withthe school, the anxiety and anger of the parents whose children attended the school created anenvironment that was not conducive to learning. It was therefore decided that it was in the bestinterest of the students to close the school and send the children to another school were theycould focus on learning.

Comment # 50:
No consideration was given for the potential of shallow ground water to carry contaminated soil to surface through cracks or fissures in soil.

LOPH/SEET Response:
The types of contamination present at this site do not flow well with water (they tend to stick to particles). It is unlikely that significant amounts of contamination would migrate in this fashion. Additionally, soil sampling done by the EPA does not show concentrations of contaminants that would be consistent with this type of migration.

Comment # 51:
Since the undeveloped area is classified as a public health hazard, wouldn't this pose a hazard to nearby school children and residents?

LOPH/SEET Response:
The undeveloped area is classified as a public health hazard, because of trespassers and the potential for future residential use. The undeveloped area does not pose a hazard to nearby school children and residents, because they do not have frequent exposure to the soil in the fenced-off area.

Comment # 52:
What is our property worth? Now that it is a Superfund site, is it worth anything now? Who will buy it if we decide we want to sell it? Will the value of our homes ever go up?

LOPH/SEET Response:
As a health agency, we have no knowledge of these issues and how they may change in the future. We do note that this is a important concern for many individuals and may cause increased stress.

Comment # 53:
The possibility of buried drums existing on the site has not been adequately addressed.

LOPH/SEET Response:
Although the possibility of errors exist when using GPR and Mag devices, LOPH/SEET is confident that the EPA's investigation of the site was as thorough as possible, and represents a comprehensive report sufficient to make a health determination. We have seen no evidence of buried drums on the site.

Comment # 54:
The undeveloped area of the site is classified as a public health hazard due to elevated levels of lead and arsenic. If this area were to be developed for future residential use, exposure to lead, arsenic, and polycyclic aromatic hydrocarbons would pose an unacceptable risk to residents. With this in mind, why then would there even be any consideration to reopen Moton School? Would not the safety of the school children, faculty/staff, and residents immediately adjacent to the undeveloped site be placed in jeopardy by any future remediation activity on the undeveloped area?

LOPH/SEET Response:
The issues facing the current residents of ASL would be the same as those of faculty and students at Moton School if it were reopened.

Any future remediation of the undeveloped area will need to be evaluated if and when thoseplans are made. The public health hazard classification of the undeveloped area is based oncontact with the contaminated soil. Any plans must limit this contact. The current EPA removalactivities are being done in such a way as to not increase the community's exposure. Dustsuppression techniques are utilized and air monitoring is in place to ensure that no contaminants are being released.

Four Areas Comprising the Agriculture Street Landfill Site
Figure 1. Four Areas Comprising the Agriculture Street Landfill Site


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