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PUBLIC HEALTH ASSESSMENT

PETRO-PROCESSORS OF LOUISIANA INCORPORATE
BATON ROUGE, EAST BATON ROUGE PARISH, LOUISIANA


APPENDICES

APPENDIX A: Figures:

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 E: Health Advisory

APPENDIX F: Response to Public Comment


APPENDIX A


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

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

APPENDIX C

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 1974by Charity Hospital at New Orleans as a cancer registry for the New Orleans area and as aparticipant of the National Cancer Institute, (NCI). In 1979, it was transferred to the state'sOffice of Public Health as a pilot for a statewide registry. The LTR is now provided by theLouisiana 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 by1988.

The LTR is composed of 5 regional registries; each responsible for the complete recording of allcancer cases diagnosed and/or treated within its region. A monograph was produced in 1990which includes all cases of cancer diagnosed during the period from January 1, 1983 throughDecember 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 averageannual 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 numberof cases grouped by cancer type, zip code and/or block group, age, and sex are maintained on acomputerized 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 since1877. At that time, the Louisiana Legislature transferred the Orleans Parish Vital RecordsRegistry to the Louisiana Board of Health. The office is a participator in the national birth anddeath registration system and provides stillbirth and marriage data to the National Center forHealth Statistics and Induced Abortion data to Centers for Disease Control. Certificates of vitalevents and reports of communicable diseases are listed by address, from 1960 to the present, andare available upon request. In addition, a monograph displaying trends in disease by Parish isproduced annually.

Table 11.

Standard Incidence Ratio of Cancer of the Trachea, Bronchus, & Lung (1983-1990)
ALSENa EAST BATON ROUGE
Age Cases
Observedb
PopulationRate per
100,000 c
CasesObservedbPopulationRate per100,000cExpected
Casesd
<50182
0.0
0
25011
0.0
0.00
5-90231
0.0
0
24388
0.0
0.00
10-140264
0.0
1
22955
0.55
0.01
15-190607
0.0
0
28264
0.0
0.00
20-240172
0.0
0
33798
0.0
0.00
25-340419
0.0
0
56797
0.0
0.00
35-440356
0.0
10
42513
2.94
0.08
45-541202
61.88
60
27020
27.76
0.45
55-640176
0.0
198
22750
108.79
1.53
65-744135
92.59
556
16274
427.06
4.61
75>468
735.29
924
9747
1185.00
6.45
TOTAL92812
40.01
1749
309517
70.63
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)
ALSENa EAST BATON ROUGE
Age Cases
Observedb
Population Rate per
100,000c
Cases
observedb
PopulationRate per
100,000c
Expected
Casesd
<50182
0.0
0
25011
0.0
0.00
5-90231
0.0
0
24388
0.0
0.00
10-140264
0.0
6
22955
3.27
0.07
15-190607
0.0
1
28264
0.44
0.02
20-240172
0.0
0
33798
0.0
0.00
25-340419
0.0
4
56797
0.88
0.03
35-440356
0.0
13
42513
3.82
0.11
45-540202
0.0
43
27020
19.89
0.32
55-640176
0.0
67
22750
36.81
0.52
65-741135
92.59
150
16274
115.21
1.24
75>068
0.0
344
9747
441.16
2.40
TOTAL12812
4.45
628
309517
25.36
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)
ALSENa EAST BATON ROUGE
Age CasesObservedbPopulationRate per
100,000c
CasesObservedbPopulationRate per100,000cExpectedCasesd
<50182
0.0
2
25011
1.00
0.02
5-91231
54.11
1
24388
0.51
0.01
10-141264
47.35
77
22955
41.93
0.89
15-190607
0.0
32
28264
14.15
0.69
20-240172
0.0
46
33798
17.01
0.23
25-340419
0.0
118
56797
26.00
0.87
35-442356
70.22
966
42513
284.03
8.09
45-544202
247.53
974
27020
450.59
7.28
55-648176
568.18
1108
22750
608.79
8.57
65-745135
462.96
2057
16274
1579.97
17.06
75>968
1654.41
4591
9747
5887.71
32.03
TOTAL302812
133.36
9972
309517
402.72
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)
ALSENaEAST BATON ROUGE
Age CasesObservedb Population Rate per
100,000c
CasesObservedbPopulationRate per100,000cExpectedCasesd
<50182
0.0
2
25011
1.00
0.02
5-91231
54.11
1
24388
0.51
0.01
10-141264
47.35
53
22955
28.86
0.61
15-190607
0.0
33
28264
14.60
0.71
20-240172
0.0
46
33798
17.01
0.23
25-340419
0.0
374
56797
82.31
2.76
35-444356
140.45
989
42513
290.79
8.28
45-543202
185.64
1077
27020
498.24
8.05
55-648176
568.18
1379
22750
757.69
10.67
65-7410135
925.93
2763
16274
2122.25
22.92
75>1368
2389.71
5517
9747
7075.25
38.49
TOTAL402812
177.81
12234
309517
494.08
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 inspecific media that are used to select contaminants for further evaluation as to potential publichealth effects. The values provide guidelines used to estimate a dose at which health effectsmight be observed. Below is a list and description of the comparison values used in the sectionEnvironmental Contamination and Other Hazards and in the Public Health Implications sectionsof 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 wouldbe expected to cause no more than one excess cancer in a million (10E-6) persons exposed over alifetime. CREGs are calculated from EPA's cancer slope factors.

EPA has not established a final cancer slope factor for benzo(a)pyrene. Therefore, thecomparison 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 drinkingwater (assuming that all exposure is from that medium) at which adverse, noncarcinogenic healtheffects 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 deemsprotective of public health (considering the availability and economics of water treatmenttechnology) over a lifetime (70 years) at an exposure rate of 2 liters of water per day (for anadult).

Maximum Contaminant Level Goals (MCLG) are drinking water health goals set at levels atwhich no known or anticipated adverse effects on the health of persons occurs and which allowsan 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 thepopulation. 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 aspecified duration of exposure. MRLs are based on human and animal studies and are reportedfor acute ( 14 days), intermediate (15-364 days), and chronic (365 days) exposures. MRLs arepublished in ATSDR Toxicological profiles for specific chemicals.

The Occupational Safety and Health Administration's Permissible Exposure Limit (PEL) in air isan 8-hour, time-weighted average developed for the workplace. The level may be exceeded, butthe 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 isunlikely to cause adverse health effects. However, RfDs do not consider carcinogenic effects.


APPENDIX D

OPEN HOUSE/INFORMATION HEARING ON PETRO-PROCESSORS OFLOUISIANA INC.

PERTINENT QUESTIONS:

  1. Is Springfield Road on the Map? It has been omitted from previous maps.

  2. Do you have a comprehensive map which includes the location of all houses, businesses, schools or other institutions, churches, parks, and any other places where people are likely to be within a three mile radius of both the Brooklawn and Scenic Highway sites?

  3. Do you know how many people are likely to be affected by an adverse accident in youroperation, their approximate location, and when these people would be expected to be there.

  4. Have you identified all land uses in the affected area, and in adjacent areas which may becomeaffected in the future. Some of these land uses are: residential, industrial, logging, hunting,fishing, oil and gas exploration, boating, hot air ballooning, hiking, etc.

  5. Have all people in the area, including residents, workers at Petro Processors, workers in nearby industries, people in businesses, pipeline workers, oil and gas explorers, loggers, hunters,fishermen, river boat workers, and any others, been properly educated as to the risks and dangers of being in the area?

  6. I understand that the level of chlorinated hydrocarbons in some samples from the area have been as high as 732 thousands parts/million. Do you have a catalog of all chemicals (includingheavy metals) that have been identified at the sites, the relative concentrations of each, and the known and suspected health effects of each?

  7. Which chemicals are known to have breached the site (the pits themselves, as well as the areawithin a one mile radius), how far they migrated, and where have they migrated?

  8. How much groundwater contamination is there? How deep does this groundwatercontamination go, and how far from the original site has it migrated?

  9. Have you done a community health assessment and risk assessment? When was this done? By whom was this done? We would like the results. If it has not been done, then when do youplan to do it?

  10. What species of fish and wildlife have been sampled for chemical contamination? Where were the samples taken and when? What impact had been made on organs?

  11. Are you planning to remove any waste from this site (Extraction wells)? If so, how will betransported, what route will it travel, where will it be transported, and what will happen to it when it reaches its destination.

  12. If you are going to leave some of the wastes on-site, what methods will be used to containthese wastes? As I understand it, the waste site is prone to flooding. Also, Mobile Ridge, wherePetro Processors is located, is eroding very badly. How will your containment methods beaffected by this. What is the pattern of overflow of water from the waste site? (Mobile Ridge, Baton Rouge Bayou, Brooks Lake, Brooks Bayou, and the Mississippi River?

  13. During the course of this new phase of operation, what will be considered tolerable levels ofexposure (Threshold Limit Values [TLVs]) ? How were these values determined. On what werethey based? What about residents who are here 24 hours? What is the long-term effect ofexposure to levels below the TLVs?

  14. During the course of this new phase of operation, are any off-site emissions expected? If no,can you guarantee this? What methods do you plan to employ to insure that off-site emissions donot occur? Could you erect a "cover" of some sort over the site that would site in Texas [north ofGalveston], uses a DOME.

  15. In the event of off-site releases ranging from those below the TLVs to the most severeemergency, What are your plans for notifying all people in the affected area, and of evacuating allpeople ant their pets and livestock? Are you aware of possible evacuation complications such as railroad tracks blocking dead-end lack personal transportation?

  16. Few residents of this area were informed of this meeting. We want a presentation that isproperly advertised, and which addresses these specific questions.

APPENDIX E

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

APPENDIX F

Comments on Petro-Processors Inc, Public Health Assessment

LOPH received numerous comments from the public during the comment period on the releaseof the Petro-Processors Inc. public health assessment. All comments were noted and manycomments were addressed by making changes or additions to the text and/or tables. Othercomments are addressed by LOPH separately in this appendix. If the same comment was madeby several sources, the comment and response was listed only once.

Comment 1:Not enough community involvement in preparing the healthassessment.

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 therelease of chemicals in the environment, it does not predict health effects. However, newmethods are being developed to better address the potential health effects of chemicals releasedfrom several industries (Comparative Risk Analysis of the TRI Data as an EnvironmentalIndicator-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 healthintervention were not performed.

LOPH/SEE and ATSDR will continue to provide information regarding the exposure ofcontaminants 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 RecommendationPanel (HARP) at ATSDR, suggests a health professional education program to be conducted toadvise local community members and health professionals of possible health effects.

Comment 4:The selected study population for health outcome data did notrepresent the exposed population.

The health outcome data has been revised to better represent the exposed community. Toaddress this, current information was obtained by the Louisiana Tumor Registry and VitalStatistics 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 thesite 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 outcomedata.

Comment 5:Off-site migration and contamination of groundwater and air was notaddressed adequately.

Recommendations provided in this health assessment and suggested by the HARP for follow-uphealth activities included the assessment and impact of off-site contamination from groundwaterand 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 iscurrently being reviewed by ATSDR. Results and recommendations will be provided in a healthupdate in the future.

Comment 7:The choice of health outcome data was inadequate , miscarriages,incidence of low birth weight, birth defects, overall live birth incidencewas not addressed.

An analysis of the health outcome data including cancer incidence, low birth weight, and othervital statistics did not demonstrate an increased number of health effects over the comparisonpopulation.

Comment 8:The window of time chosen to study cancer was too limited and anextensive survey of all known health effects is needed.

Health outcome data has been revised to better represent the community exposed and has beenexpanded to cover data from 1983 to 1990. The results included cancer information availableand are presented in Appendix C, with a discussion of results on page 42.

Comment 9:The toxicological evaluation is unrealistic and should address totalexposure, repeatedly for a long period of time.

The toxicological evaluation for the contaminants of exposure at the PPI site, covered onlyexposure scenarios specific for the site. This is a limitation of the field of study in environmentalhealth where very little information is known about combined exposures and synergistic effectsto populations located in urban environments and/or industrial corridors.

Comment 10:Recommendations in the health assessment are good, but not extensiveenough (do not address the total environmental problems within thecommunity.

The recommendations in the Public Health Assessment are part of an ongoing active process ofhealth evaluations for the community. Assessments of health impacts to the community iscontinuous and updates or site reviews are conducted periodically.

Comment 11:Hunting and fishing activities in Devil's Swamp should be addressed toinclude educational approaches as well as policing the area to keeppeople out.

A health advisory exists for the Devil's Swamp area (Appendix E) recommending the limiting offish consumption of all species of finfish to two meals per month. LOPH place a public serviceannouncement in the Baton Rouge Advocate in 1993. In addition, several articles have beenwritten regarding the fishing and hunting in Devil's Swamp. A fact sheet is currently beingprepared.

Additionally, available data regarding crawfish and mammals obtained from Devil's Swamp, andtested for contaminants has been analyses by Tulane School of Public Health in cooperation withLOPH. The levels of contamination for HCB and HCBD were below levels that might pose anadverse health effect. While there is no advisory for consumption of crawfish and mammalsobtained in this area, further sampling is recommended by LOPH/SEE and ATSDR.

Comment 12:Inorganics were removed from this edition of the Public HealthAssessment.

Within the public health assessment, chemicals released from operations that occurred on the siteare 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 theScenic Site (+ 40 ft MSL and + 20 ft MSL). Residents across the siteare served by private water wells not accounted for in the assessment.

A recommendation included in this document and suggested by the ATSDR Health ActivitiesRecommendation Panel is a follow-up report on the residential well use.

Comment 14:Surface water exposure in Bayou Baton Rouge between the railroaddrainage ditch at PPI Scenic site and the upstream property boundaryof Schuykill Metals was not addressed.

The informational health advisory for Devil's Swamp and Bayou Baton Rouge is for the limitedconsumption of finfish and exposure to surface water including swimming (Appendix E). Theadvisory includes the area bound on the north by Hall Buck Marine Road, the east by the bluffsand 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 frequentflooding. Further sampling has been recommended.

Comment 15:The Health Department should consider expanding the advisory toinclude crawfish and other animals, as well as finfish.

Examination of available crawfish data to date, by LOPH in cooperation with Tulane School ofPublic 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 hasbeen 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, furthersampling 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 amonth) should be addressed.

Please review the above comments 14 and 15, as well as the advisory in Appendix E. Theadvisory is based on a wide margin of safety to reduce the risk of cancer or other diseases due toexposure 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 preparingand 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 atthe sites from 1965 to 1980.

While exposure to air has been listed as a completed exposure pathway as defined by the ATSDRGuidance Manual for Public Health Assessment. It is possible to predict exposure from on andoff-site exposures to volatile organic compounds during the release of volatile compounds in1987, however it is not possible to accurately determine low chronic exposure during the1965-1980 time period.

Comment 18:Risk associated with the incinerator operated on-site to treat the wasterecovered from the recovery wells and sumps should be addressed.

The air emission data for the incinerator, including the trial burn and routine fence-linemonitoring has been submitted to ATSDR for review. Results will be made available when theanalysis 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 ahealth professional education program designed to advise public health professionals. The focusof this approach is to enable the medical community to better address the current needs of thecommunity.

Comment 20:Population data, and cancer incidence data of residents alongSpringfield road, including data from 1983-1987 were not addressed.

As mentioned in response to comment 4 above, health outcome data has been revised to includeresidents 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; communityhealth 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 aremade (inhalation, ingestion, dermal contact, etc.), the dose is calculated. This involvescomparing chemical concentrations to a standard value, below which adverse health effects areunlikely, The EMEG's and RMEG's are comparison values derived for health effects withnon-cancer end points, while the CREG comparison values are estimated contaminantconcentrations based on one excess cancer in a million persons exposed over a lifetime. Thesevalues are very conservative and provide for a wide margin of human safety. If the concentrationexceeds this comparison value, then a dose is determined that takes into consideration levels ofcontaminants (usually maximum levels), weight of the exposed individual, the rate at which thecontaminant could enter the body and the duration of exposure. If the chemical of concern isnon-carcinogenic, the dose is compared to a standard reference dose (RfD), or other standarddepending on the medium in which the chemical is contained (soil, water, air). A complete listof these standards and explanation of how they are developed is presented in Appendix C. Thestandards are based on research and determined to provide a wide margin of safety. If the doseexceeds this value, recommendations are made to minimize exposure to these chemicals. Manyother 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 aphysician, nurse and two public health investigators. In addition, health education activities forthe entire Baton Rouge Parish, were conducted in January 1995, including a physician educationpacket 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 themedical community. Also attempts were made to implement health education through theschools 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. Exposurescenarios for these hazardous substances are considered when implementing the informationalhealth survey for Devil's Swamp and Bayou Baton Rouge, limiting the consumption of finfish totwo meals per month and avoiding water contact. See Appendix E for the complete healthadvisory.

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 thehydrology maps to be consistent at this level.

Comment 25:The definition and assumptions of MRL, RfD, EMEG and CPF'sshould be made understandable.

Acronyms such as these describe standard values established by ATSDR and EPA to use ascomparison values below which adverse health effects are unlikely. However, this does notmean that values above the comparison value will pose adverse health effects. A complete list ofthe 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 bepresented.

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 werenot 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 calculatecomparison values. Use of these lower parameters result in a wider margin of safety. However itmust be remembered that other factors influence the health outcome such as genetic, diet andlifestyle.

As more information on exposure and health effects become available, these comparison valuesare updated to better evaluate potential health effects.

Comment 28:LOPH/SEE appears to have based all their calculations for a givenchemical on the highest detected concentration.

Since it is impossible to determine the exact amount of exposure and chemical uptake into thebody, the highest concentration of the chemical determined from sampling, is used to calculatethe dose for each route of exposure and is totaled for all routes of exposure. This method isconservative in approach to provide the maximum safe limit possible.

Comment 29:LOPH/SEE did not take into consideration an EPA approved Air EmissionRisk Assessment performed in 1993.

The 1993 Air Emissions data to include the trial burn for the incinerator located on-site as well ascurrent fence-line data, is being evaluated and assessed by the Agency for Toxic Substances andDisease Registry (ATSDR). Information will be made available as soon as the evaluation iscompleted. However, while data on past emissions is not available, inhalation exposure isconsidered a completed pathway.

Comment 30:LOPH/SEE Public Health Assessment does not follow the guidelinesestablished by ATSDR for writing Public Health Assessments.

The Public Health Assessment Guidance Manual published by ATSDR is designed to provide aframework to evaluate public health exposures and their effects. It provides latitude to the healthassessor to develop new approaches and allows for incorporation of professional judgement anddiscretion that better addresses the unique issues associated with a particular site.


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