MUNISPORT LANDFILL
NORTH MIAMI, DADE COUNTY, FLORIDA
APPENDIX A: SITE MAPS AND SAMPLING LOCATIONS
 Figure 1. |  Figure 2. |  Figure 3. |
 Figure 4. |  Figure 5. |  Figure 6. |
 Figure 7. |  Figure 8. |  Figure 9. |
 Figure 10. |  Figure 11. |  Figure 12. |
 Figure 13. |  Figure 14. |  Figure 15. |
 Figure 16. |  Figure 17. |  Figure 18. |
APPENDIX B: CONTAMINANTS LACKING SUFFICIENT TOXICOLOGICAL DATA
APPENDIX C: CONTAMINANT CONCENTRATIONS AND EXPOSURE PATHWAY TABLES
Table 1. Maximum Concentrations in On-Site Landfill Leachate
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled |
Comparison Value | |
| (mg/L) | Source | |||
| ammonia | NA | --- | --- | --- |
| benzene | ND | 0/1 | --- | --- |
| di(2-ethyl hexyl) phthalate | NA | --- | --- | --- |
| cadmium | ND | 0/1 | --- | --- |
| carbon disulfide | NA | --- | --- | --- |
| chloromethane | NA | --- | --- | --- |
| coliform bacteria | NA | --- | --- | --- |
| dieldrin | NA | --- | --- | --- |
| lead | 0.130 | 1/1 | 0.015 | FL MCL |
| methylene chloride | ND | 0/1 | --- | --- |
| pentachlorophenol | NA | --- | --- | --- |
| PCBs | NA | --- | --- | --- |
| styrene | NA | --- | --- | --- |
| vanadium | ND | 0/1 | --- | --- |
| zinc | 0.275 | 1/1 | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
FL MCL - Florida Maximum Contaminant Level
LTHA - EPA Lifetime Health Advisory
Source: 1982 Florida DER and Dade County DERM Summaries of Analytical Results, as quoted
in 1984 EPA Remedial Action Master Plan (9).
Table 2. Maximum Concentrations in On-Site Soil
| Contaminants of Concern | Maximum Concentration (mg/kg) | number positive* / total # sampled |
Background Concentration (mg/kg) | Comparison Value | |
| (mg/kg) | Source | ||||
| ammonia | 13 | 3/25 | ND | none | --- |
| benzene | ND | 0/25 | ND | --- | --- |
| di(2-ethyl hexyl) phthalate | 3.2 | 1/25 | ND | 0.03 | CREG |
| cadmium | ND | 0/25 | ND | --- | --- |
| carbon disulfide | ND | 0/25 | ND | --- | --- |
| chloromethane | ND | 0/25 | ND | --- | --- |
| coliform bacteria | NA | --- | NA | --- | --- |
| dieldrin | 0.064 | 1/25 | ND | 0.040 | CREG |
| lead | 87 | 18/25 | 180 | none | none |
| methylene chloride | ND | 0/25 | ND | --- | --- |
| pentachlorophenol | 21 | 2/25 | 21 | 5.8 | CREG |
| PCBs | 0.270 | 3/25 | ND | 0.090 | CREG |
| styrene | ND | 0/25 | ND | --- | --- |
| vanadium | ND | 0/25 | ND | --- | --- |
| zinc | 97 | 18/25 | 51 | none | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/kg - milligrams per kilogram
CREG - ATSDR Cancer Risk Evaluation Guide
Sources: 1984 EPA Site Investigation (6) and 1988 EPA Remedial Investigation (7)
Table 3. Maximum Concentrations in On-Site Surface Water
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled |
Background Concentration (mg/L) | Comparison Value | |
| (mg/L) | Source | ||||
| ammonia | 63 | 36/38 | none | 30 | LTHA |
| benzene | ND | 0/33 | none | --- | --- |
| di(2-ethyl hexyl) phthalate | ND | 0/21 | none | --- | --- |
| cadmium | 0.015 | 6/69 | none | 0.005 | EMEG |
| carbon disulfide | 0.096 | 14/21 | none | 1 | RfD |
| chloromethane | 0.011 | 4/33 | none | 0.003 | LTHA |
| coliform bacteria | 5,400/ 100 mL | 10/10 | none | 1 per 100 mL | FL MCL |
| dieldrin | ND | 0/21 | none | --- | --- |
| lead | 0.063 | 3/69 | none | 0.015 | FL MCL |
| methylene chloride | ND | 0/33 | none | --- | --- |
| pentachlorophenol | ND | 0/33 | none | --- | --- |
| PCBs | ND | 0/33 | none | --- | --- |
| styrene | ND | 0/33 | none | --- | --- |
| vanadium | 0.020 | 2/33 | none | 0.020 | LTHA |
| zinc | 0.210 | 19/77 | none | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed, ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
LTHA - EPA Lifetime Health Advisory
EMEG - ATSDR Environmental Media Evaluation Guide
RfD - EPA Reference Dose
FL MCL - Florida Maximum Contaminant Level
Sources: 1982 Florida DER and Dade County DERM Summaries of Analytical Results, as
quoted in 1984 EPA Remedial Action Master Plan (9), 1984 Remedial Action Master Plan (5),
and 1988 EPA Remedial Investigation (7).
Table 4. Maximum Concentrations in On-Site Sediments
| Contaminants of Concern | Maximum Concentration (mg/kg) | number positive* / total # sampled |
Background Concentration (mg/kg) | Comparison Value | |
| (mg/kg) | Source | ||||
| ammonia | 370 | 5/6 | none | none | --- |
| benzene | ND | 0/18 | none | --- | --- |
| di(2-ethyl hexyl) phthalate | ND | 0/18 | none | --- | --- |
| cadmium | ND | 0/18 | none | --- | --- |
| carbon disulfide | ND | 0/18 | none | --- | --- |
| chloromethane | ND | 0/18 | none | --- | --- |
| coliform bacteria | NA | --- | none | --- | --- |
| dieldrin | ND | 0/18 | none | --- | --- |
| lead | 80 | 5/18 | none | none | --- |
| methylene chloride | ND | 0/18 | none | --- | --- |
| pentachlorophenol | ND | 0/18 | none | --- | --- |
| PCBs (1242) | 0.90 | 2/18 | none | 0.090 | CREG |
| styrene | ND | 0/18 | none | --- | --- |
| vanadium | 26 | 13/18 | none | none | --- |
| zinc | 430 | 13/18 | none | none | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/kg - milligrams per kilogram
CREG - ATSDR Cancer Risk Evaluation Guide
Sources: 1984 EPA Remedial Action Master Plan (5), 1988 EPA Remedial Investigation (7), and
1989 EPA Water Quality and Toxic Assessment Study of Mangrove Preserve (12).
Table 5. Maximum Concentrations in On-Site Ground Water
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled |
Background Concentration (mg/L) | Comparison Value | |
| (mg/L) | Source | ||||
| ammonia | 561 | 35/36 | 0.27 | 30 | LTHA |
| benzene | 0.002 | 3/20 | ND | 0.001 | CREG |
| di(2-ethyl hexyl) phthalate | ND | 0/20 | ND | --- | --- |
| cadmium | 0.011 | 1/73 | ND | 0.005 | EMEG |
| carbon disulfide | ND | 0/20 | ND | 1 | RfD |
| chloromethane | 0.001 | 1/20 | 0.007 | 0.003 | LTHA |
| coliform bacteria | 2,400/ 100 mL | 31/106 | 7 per 100 mL | 1 per 100 mL | FL MCL |
| dieldrin | 0.00008 | 1/20 | ND | 0.000002 | CREG |
| lead | 0.90 | 57/127 | 0.17 | 0.015 | FL MCL |
| methylene chloride | ND | 0/20 | ND | --- | --- |
| pentachlorophenol | 0.006 | 2/20 | ND | 0.0003 | CREG |
| PCBs | ND | 0/20 | ND | --- | --- |
| styrene | ND | 0/20 | ND | --- | --- |
| vanadium | 0.054 | 9/20 | 0.032 | 0.020 | LTHA |
| zinc | 12 | 76/114 | 9.1 | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
LTHA - EPA Lifetime Health Advisory
CREG - ATSDR Cancer Risk Evaluation Guide
EMEG - ATSDR Environmental Media Evaluation Guide
Rfd - EPA Reference Dose
FL MCL - Florida Maximum Contaminant Level
Sources: 1984 EPA Remedial Action Master Plan (5), 1987 Ross Report (10), and 1988 EPA Remedial Investigation (7).
Table 6. Maximum Concentrations in On-Site Air
| Contaminants of Concern | Maximum Concentration (ppm) | number positive* / total # sampled |
Background Concentration (ppm) | Comparison Value | |
| (ppm) | Source | ||||
| ammonia | NA | --- | NA | --- | --- |
| benzene | 0.562 | 8/8 | NA | 0.00003 | CREG |
| di(2-ethyl hexyl) phthalate | NA | --- | NA | --- | --- |
| cadmium | NA | --- | NA | --- | --- |
| carbon disulfide | NA | --- | NA | --- | --- |
| chloromethane | 0.0006 | 1/8 | NA | 0.4 | EMEG |
| coliform bacteria | NA | --- | NA | --- | --- |
| dieldrin | NA | --- | NA | --- | --- |
| lead | NA | --- | NA | --- | --- |
| methylene chloride | 0.002 | 1/8 | NA | 0.00006 | CREG |
| pentachloro-phenol | NA | --- | NA | --- | --- |
| PCBs | NA | --- | NA | --- | --- |
| styrene | 0.261 | 4/8 | NA | 0.10* | EMEG* |
| vanadium | NA | --- | NA | --- | --- |
| zinc | NA | --- | NA | --- | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
ppm - parts per million
CREG - ATSDR Cancer Risk Evaluation Guide
EMEG - ATSDR Environmental Media Evaluation Guidelines
* - EMEG for styrene: No Observable Adverse Effect Level for humans following long-term
inhalation exposure (1ppm) X safety factor of 10.
Source: 1991 EPA Environmental Response Team Report on Air Sampling Performed at the
Munisport Landfill (11).
Table 7. Maximum Concentrations in Off-Site Surface Water
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled |
Background Concentration (mg/L) | Comparison Value | |
| (mg/L) | Source | ||||
| ammonia | 11 | 27/45 | 0.070 | 30 | LTHA |
| benzene | ND | 0/15 | ND | --- | --- |
| di(2-ethyl hexyl) phthalate | ND | 0/15 | ND | --- | --- |
| cadmium | ND | 0/21 | ND | --- | --- |
| carbon disulfide | 1.9 | 10/21 | 0.023 | 1 | RfD |
| chloromethane | ND | 0/15 | ND | --- | --- |
| coliform bacteria | 190/100 mL | 5/5 | NA | 1 per 100 mL | FL MCL |
| dieldrin | ND | 0/15 | ND | --- | --- |
| lead | ND | 0/22 | ND | --- | --- |
| methylene chloride | ND | 0/15 | ND | --- | --- |
| pentachlorophenol | ND | 0/15 | ND | --- | --- |
| PCBs | ND | 0/15 | ND | --- | --- |
| styrene | ND | 0/15 | ND | --- | --- |
| vanadium | 0.092 | 13/15 | 0.110 | 0.020 | LTHA |
| zinc | 0.150 | 9/24 | ND | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
LTHA - EPA Lifetime Health Advisory
RfD - EPA Reference Dose
FL MCL - Florida Maximum Contaminant Level
Sources: 1982 Florida DER and Dade County DERM Summaries of Analytical Data, quoted in
1984 EPA Remedial Action Master Plan (9), 1984 EPA Remedial Action Master Plan (5), and
1988 EPA Remedial Investigation (7).
Table 8. Maximum Concentrations in Off-Site Sediments
| Contaminants of Concern | Maximum Concentration (mg/kg) | number positive* / total # sampled |
Backround Concentration (mg/kg) | Comparison Value | |
| (mg/kg) | Source | ||||
| ammonia | 620 | 9/9 | 9 | none | --- |
| benzene | 0.002 | 1/16 | ND | 24 | CREG |
| di(2-ethyl hexyl) phthalate | ND | 0/16 | ND | --- | --- |
| cadmium | 4.1 | 1/16 | ND | 25 | EMEG |
| carbon disulfide | 0.003 | 1/16 | ND | 5,000 | RfD |
| chloromethane | ND | 0/16 | ND | --- | --- |
| coliform bacteria | NA | --- | --- | --- | --- |
| dieldrin | ND | 0/16 | ND | 0.040 | CREG |
| lead | 110 | 6/16 | 27 | none | --- |
| methylene chloride | ND | 0/16 | ND | --- | --- |
| pentachlorophenol | 0.4 | 1/16 | ND | 5.8 | CREG |
| PCBs (1260) | 0.077 | 1/16 | ND | 0.090 | CREG |
| styrene | ND | 0/16 | ND | --- | --- |
| vanadium | 23 | 11/16 | 36 | none | --- |
| zinc | 1,600 | 9/16 | 33 | none | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/kg - milligrams per kilogram
CREG - ATSDR Cancer Risk Evaluation Guide
EMEG - ATSDR Environmental Media Evaluation Guide
RfD - EPA Reference Dose
Sources: 1984 EPA Remedial Action Master Plan (5), 1988 EPA Remedial Investigation (7), and
1989 EPA Water Quality and Toxic Assessment Study (12).
Table 9. Maximum Concentrations in Off-Site Ground Water
| Contaminants of Concern | Maximum Concentration (mg/L) | number positive* / total # sampled |
Background Concentration (mg/L) | Comparison Value | |
| (mg/L) | Source | ||||
| ammonia | 78 | 39/39 | 0.27 | 30 | LTHA |
| benzene | ND | 0/13 | ND | --- | --- |
| di(2-ethyl hexyl) phthalate | ND | 0/13 | ND | --- | --- |
| cadmium | ND | 0/52 | ND | --- | --- |
| carbon disulfide | ND | 0/13 | ND | --- | --- |
| chloromethane | 0.008 | 1/13 | 0.007 | 0.003 | LTHA |
| coliform bacteria | 1,420/ 100 mL | 1/47 | 7 per 100 mL | 1 per 100 mL | FL MCL |
| dieldrin | ND | 0/13 | ND | --- | --- |
| lead | 0.037 | 24/61 | 0.17 | 0.015 | FL MCL |
| methylene chloride | ND | 0/13 | ND | --- | --- |
| pentachlorophenol | ND | 0/13 | ND | --- | --- |
| PCBs | ND | 0/13 | ND | --- | --- |
| styrene | ND | 0/13 | ND | --- | --- |
| vanadium | 0.029 | 2/13 | 0.032 | 0.020 | LTHA |
| zinc | 0.12 | 19/31 | 9.1 | 2 | LTHA |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/L - milligrams per liter
LTHA - EPA Lifetime Health Advisory
FL MCL - Florida Maximum Contaminant Level
Sources: 1982 Florida DER and Dade County DERM Summaries of Analytical Results quoted in
the 1984 EPA Remedial Action Master Plan (9), 1984 EPA Remedial Action Master Plan (5),
and 1988 EPA Remedial Investigation (7).
Table 10. Maximum Concentrations in Off-Site Biota
| Contaminants of Concern | Maximum Concentration (mg/kg) | number positive* / total # sampled |
Background Concentration (mg/kg) | Comparison Value | |
| (mg/kg) | Source | ||||
| ammonia | NA | --- | --- | --- | --- |
| benzene | NA | --- | --- | --- | --- |
| di(2-ethyl hexyl) phthalate | NA | --- | --- | --- | --- |
| cadmium | ND | 0/8 | ND | --- | --- |
| carbon disulfide | NA | --- | NA | --- | --- |
| chloromethane | NA | --- | NA | --- | --- |
| coliform bacteria | NA | --- | NA | --- | --- |
| dieldrin | 0.024 | 1/8 | ND | none | --- |
| lead | ND | 0/8 | ND | --- | --- |
| methylene chloride | NA | --- | NA | --- | --- |
| pentachlorophenol | NA | --- | NA | --- | --- |
| PCBs (1254) | 0.44 | 5/8 | 0.091 | none | --- |
| styrene | NA | --- | NA | --- | --- |
| vanadium | 0.21 | 1/8 | ND | none | --- |
| zinc | 1,400 | 8/8 | 3,100 | none | --- |
* Positive = any detection of the contaminant
NA - not analyzed
ND - not detected
PCBs - polychlorinated biphenyls
mg/kg - milligrams per kilogram
Source: 1988 EPA Remedial Investigation (7).
Table 11. Completed Exposure Pathways
| PATHWAY NAME | EXPOSURE PATHWAY ELEMENTS | TIME | ||||
| SOURCE | ENVIRONMENTAL MEDIA | POINT OF EXPOSURE | ROUTE OF EXPOSURE | EXPOSED POPULATION | ||
| Surface Soil | Munisport Landfill | Surface Soil | On the Landfill | Ingestion and Skin Contact | Children trespassing on site | Past Present Future |
| Surface Water | Munisport Landfill | Surface Water | Landfill lakes |
Ingestion and Skin Contact | Children swimming in on-site lakes | Past Present Future |
| Fish and Oyster * | Munisport Landfill | Fish and Oysters | Residence | Ingestion | Biscayne Bay Fish and Oyster Eaters | Past Present Future |
| Ambient Air | Munisport Landfill | Air | Nearby Residences | Inhalation | Highland Village Residents | Past and Future |
* It is unlikely that this site is the source of PCB contamination of Biscayne Bay.
Table 12. Potential Exposure Pathways
| PATHWAY NAME | EXPOSURE PATHWAY ELEMENTS | TIME | ||||
| SOURCE | ENVIRONMENTAL MEDIA | POINT OF EXPOSURE | ROUTE OF EXPOSURE | EXPOSED POPULATION | ||
| Stormwater Run-off | Munisport Landfill | Stormwater | Highland Village | Skin Contact | Highland Village Residents | Past and Future |
| Landfill Leachate | Munisport Landfill | Leachate | On the Landfill | Skin Contact | Children Trespassing on the Site | Past |
| Surface Soil | Munisport Landfill | Surface Soil | On the Landfill | Ingestion and Skin Contact | On-site Workers | Future |
| Soil Gases | Munisport Landfill | Air | Highland Village | Inhalation | Highland Village Residents | Future |
APPENDIX D: SUMMARY OF PUBLIC COMMENT ON THE DRAFT PUBLIC HEALTH ASSESSMENT AND FLORIDA HRS RESPONSE
In August 1992, Florida HRS mailed a one page "fact sheet" to 150 people on the EPA Munisport Landfill Superfund mailing list. This fact sheet summarized the findings of the draft public health assessment, announced its availability, and solicited public comments. The EPA mailing list included all residents who had previously attended public meetings, all involved governmental agencies, local television stations, radio stations, and newspapers. We also mailed a copy of the draft health assessment directly to six community leaders. A story regarding the draft assessment appeared in the August 23, 1992 Neighbors edition of the Miami Herald. The Munisport Dump Coalition also summarized the draft assessment in their November newsletter. The deadline for comments on the draft was September 25, 1992. In September, we mailed a second "fact sheet" to everyone on the mailing list. This fact sheet again summarized the draft public health assessment and announced that due to the extensive hurricane damage in Dade County, we were extending the deadline for public comment to October 30, 1992.
We received six sets of comments on the draft public health assessment. Following is a summary of these comments and our responses:
Comment #1
One person pointed out that the March 20, 1992 Consent Decree defined the Superfund site as 30 acres, not 291 acres.
Response:
Florida HRS and ATSDR are not bound by the site definition contained in the Consent Decree. Our definition of the site (Figure 2) includes all potential sources of contamination that may affect public health.
Comment #2
One person felt the draft failed to give adequate attention and credence to the 1987 H.J. Ross Associates Site Investigation Report that showed the landfill consisted of construction debris, yard trash, and household garbage. This person contends this report and the 1988 Remedial Investigation Report demonstrate that Munisport is a typical landfill and not a hazardous waste site.
Response:
H.J. Ross Associates observed material in 38 soil borings and 71 exploratory trenches in the landfill. They failed, however, to collect any samples for chemical analysis. Many of the contaminants of concern at this site are only detectable by chemical analysis. The 1988 EPA Remedial Investigation also failed to collect any samples from the fill material. Therefore, we are unaware of any sampling of the fill material to determine if it contains hazardous chemicals.
In the 1988 Remedial Investigation, EPA did collect and analyze 10 surface soil samples from the landfill cover. These samples, however, were of the cover material, not the fill material. Ten cover soil samples from the 170 acre landfill (1 sample/17 acres) are inadequate to full characterize the extent of contamination in the cover material. These two studies failed to demonstrate this site does not contain hazardous chemicals.
Comment #3
Two people felt the draft public health assessment went beyond available information in asserting that residents' health complaints are unlikely to be site related. They pointed out that association of specific symptoms with exposure to toxic chemical is an inexact art.
Response:
We will explain the difficulty in excluding environmental chemical exposure as a cause of health effects reported by nearby residents.
Comment #4
One person felt the public health assessment should specify which agency should carry out each recommendation.
Response:
Since public health assessments are advisory not regulatory, other agencies are not required to follow our recommendations. Therefore, we have not specified which agency should carry out each recommendation. We will, however, work with all local, state, and federal agencies to ensure that our recommendations are carried out.
Comment #5
One person strongly agreed with our recommendation that the appropriate agency maintain a 15 foot buffer free of vegetation between the site and the Highland Village mobile home park. This person also strongly agreed that during any site remediation, construction, or development the appropriate agency control dust at the site and monitor air quality at the Highland Village mobile home park.
Response:
We will work with the appropriate local, state, or federal agency to ensure that our recommendations are carried out.
Comment #6
One person pointed out that in 1985 the site manager and his family lived in an on-site trailer and depended upon a nearby well for their drinking water. This person asserts during the time the landfill was in operation some residents of the Highland Village mobile home park also depended on wells for their drinking water.
Response:
Although prior to 1974 Dade County moved municipal water supply wells further inland because of saltwater intrusion, some individual may have continued to use shallow wells for drinking water and irrigation. Since there were no analyses of water from these wells, we can not assess the health risk.
Comment #7
One person pointed out that in 1987 the manager of a youth facility northeast of the site complained that several boys developed serious skin infections after being cut or scratched.
Response:
Although we can not determine the source of these infections, it is possible they were the result of swimming in the on-site lakes, especially if the levels of bacterial contamination had not changed since 1982.
Comment #8
One person observed that distance of residence from a hazardous waste site is a poor measure of exposure. This person also observed that the ZIP code used to survey cancer incidence around this site includes a large number of people who do not live close to the site. This person also points out that the failure to establish a link between the site and the health of nearby residents may be more indicative of the limitations of epidemiological methods than the lack of an effect. As a result this person does not feel that one can draw meaningful conclusion regarding the effects of this site on the incidence of cancer.
Response:
We agree that distance of a residence from a hazardous waste site is a poor measure of exposure. Distance from the site, however, is the only readily available measure of exposure we have. We also agree that use of the ZIP code to survey cancer incidence includes a large number of people who do not live close to the site. Unfortunately, ZIP code is the smallest geographical area searchable in the Florida Cancer Data System. This person is also correct that failure to establish a link between a site and the health of nearby residents may be more indicative of the limitations of epidemiological methods than the lack of an effect. We will highlight the limitations of the Florida Cancer Data System and epidemiological investigations in general.
Comment #9
One person stated that the assumptions used to calculate fish and shellfish consumption were not current and underestimate exposure 10 fold. This person also felt the draft relied too heavily on a limited set of fish-tissue samples and failed to consider bioconcentration.
Response:
Historically, a fish ingestion rate of 6.5 grams per day has been used as an average for both fish consumers and non-consumers. We agree that there are more current and appropriate fish ingestion rates. We will use 66 grams of fish and shellfish per day as the ingestion rate for recreational fishers in Biscayne Bay. This rate is based on an estimate by Pao et al. (13) of 132 grams per day (the 95th percentile daily intake averaged over three days for consumers of fin fish) multiplied by 50% (an estimate of the percentage of a individual's total fish consumption that comes from Biscayne Bay).
We also agree that eight fish and oyster tissue samples is a limited number and call for further investigation of the extent of PCB contamination of fish and oysters in Biscayne Bay. Since we relied on direct measurement of PCB concentrations in fish and oysters as opposed to modeling from sediment or water concentrations, the relative contributions of bioaccumulation and/or bioconcentration are irrelevant.
Comment #10
One person suggested that landfill gases that currently migrate upward and dissipate may migrate latterly into Highland Village mobile home park if significant areas of the site are paved. This person suggested that soil gas be monitored.
Response:
We agree that paving significant areas of the landfill could increase the lateral movement of soil
gases. We will recommend soil gas monitoring if significant areas of the landfill near the
Highland Village mobile home park are paved.
