RCRA RECORDS CENTER

CORPORATION 19 CROSBY DRIVE

•=ORC3, MASSACHUSETTS O1 73O INTERNAL CORRESPONDENCE S7S-S37O C83-2-3-67

TO: P. HYNES U.S. ENVIRONMENTAL PROTECTION AGENCY

DATE: FEBRUARY 16, 1983

3FK FEDERAL BUILDING, RM 1903 BOSTON, MASSACHUSETTS 02203

FROM: G. ROSCOE (TOXICOLOGIST) NUS CORPORATION 19 CROSBY DRIVE BEDFORD, MASSACHUSETTS 01730

COPIES: FILE P. CLAY R. DINITTO

SUBJECT: RECOMMENDATIONS OF ACTIONS LEVELS FOR PCS CONTAMINATED SPORT FISH - HOUSATQNIC RIVER TDD NO. Fl-8212-0* 0300.01

• Introduction

A comprehensive review of Housatonic River study data, toxicological data, and federal and state actions was recently conducted by NUS/FIT. A summary of this review has been prepared for submission to the U.S. EPA.

As a consequence of conducting this review, and as requested by EPA, this memorandum addresses recommendations for action levels and responses for regulating consumption of PCB contaminated sport fish.

» Recommendations

When FDA was evaluating subject matter for the establishment of PCB tolerances in food and food related materials, they were presented with valid arguments which suggested that the tolerance should be both raised and lowered. In making recommendations concerning sport fish, the same situation will exist. The recommendations which follow represent a "toxicological opinion". There is no valid mechanical or mathematical approach which will address this problem. The following recommendations are based upon evaluation of current scientific data, however it should be noted that other interpretations of the data are possible.

In evaluating the process by which the Food and Drug Administration derived both the current 5 ppm tolerance and the proposed 2 ppm tolerance, it is evident both from the process and by the FDA's own admission that these levels may not be appropriate for use in restricting consumption of sport fish, nor in prelecting the health of individuals who consume sport fish. Therefore, individuals who consume sport fish from the Housatonic River may be subject to potential adverse health effects, the nature and probability of which cannot be accurately defined. Based on this assessment the following recommendations are made:

' A Halliburton Company

\

C-583-2-3-67

MEMO TO: PAT HYNES FEBURARY 16, 1983-PAGE TWO

1. An active educational program should be undertaken by both Massachusetts and Connecticut to inform the public of the nature and extent of the contamination problem. This could be done at the time of fishing license procurement in the form of an advisory which is included in the regulations.

2. In river areas where the PCB load or PCB concentration in sediment is high, warning signs should be posted.

3. Identify those fish species and river areas where PCB levels in the fillets exceed 1 ppm and caution against consumption of fish from those areas.

4. Identify subgroups such as pregnant women and young children which may be at greater risk and recommend against consumption of any contaminated sport fish.

5. Educate the public in cooking methods which tend to reduce PCB levels in the portion of the fish which is consumed. It has been shown that cooked fish show lower levels of PCB than uncooked fish. The reduction is probably due to oils containing PCBs which "sweat" from the flesh during cooking. Fish with PCB levels exceeding 1 ppm in the edible fillet should not be consumed. Fish with lower levels should be skinned, and cooked in a manner which maximize drainage of oils and fat from the meat ( such as broiling).

Rationale

The Massachusetts portion of the Housatonic River is reported to be relatively scarce in sport fish and is probably not heavily fished. However, individuals do undoubtedly fish this portion of the river. Therefore the extent of possible exposure may be low in sheer numbers, but should not be overlooked.

Studies have indicated a correlation between PCB levels in sediment and those found in fish. Therefore areas of highest contamination should be clearly marked to educate those individuals as to the extent of PCB contamination and as a safeguard to reduce the possibility of individuals catching and consuming fish having very high levels of PCBs.

C-583-2-3-67

MEMO TO: PAT HYNES FEBRUARY 16, 1983-PAGE THREE

The FDA felt that toxicological data indicated that in an ideal situation, it would be preferable not to have PCBs in food at any level. However, because of their obligation to consider the extent of unavoidability and the economic impact on commerce and certain parts of the fishing industry, tolerances were established weighing economic impact and public health.

States are not under the constraint of having to conisder the economic implications of establishing action levels, because there is a minimal impact associated with sport fish. In addition, the amount of PCBs in environmental samples sufficient to produce toxic effects either acutely or long-term is not known (although estimates have been made, their validity is in question). Therefore, because there are few economic implications and PCBs are considered potentially hazardous, it is desirable to restrict their consumption to the lowest level possible. An action level of 1 ppm should significantly reduce consumption of PCBs. It should not be inferred that consumption of fish wi th< l ppm is safe. However, occasional meals at these levels should not provide significant exposure to PCBs. It should be stressed that regardless of the level, the public should be aware they could be consuming fish which may contain a potentially hazardous contaminant.

To further reduce exposure to PCBs through consumption of sport fish, the proper cooking method can reduce PCBs which may be present. It is anticipated that proper cooking techniques in conjuction with a 1 ppm action level will greatly reduce the ingestion of PCBs from contaminated sport fish.

• Summary

It is recommended that an action level be adopted which would recommend against consumption of sport fish which exceed PCB levels of 1 ppm in the edible fillet and the public should continually be educated as to the nature and extent of the contamination problem.

nla Attachment

v U-* r. x ' ^ Bi— v_^ ,,

'' •>: ••"• \ Steven C. Schioael 3 BBi-Narragansett

»»

The following Copies ara1 addressed: rr r"

• • -O - o newly-hatched striped bass, by Anon., 1971). However, no freshwater

studies specifically address the issue at hand. One could suggest that if §

trout or bass were as sensitive toAroclor* 1254 as thesheepahead minnow, |

"%and the ratio of the PCS in whole-body fish to eggs were similar, those f -5C

trout or baaa containing 10 pptu and greater »ay suffer significant reproductive £

effect*. Baaed on Table 5-3, page 5-8 of the Houaatonic Mver Report, > jp > >?i

trout from stations IB, 2, 3, and 5 contained PCBs in excess of 10ppta; / :| 2S

bass exceeded 10 ppm in stations 3 , 4 , and 5. s| M̂.

The Rousetonic River Study states, and the scientific literature || •_!?'

substantiates the statement, that the amount of PCB« in fish are dependent '| W

upon a auab«r of factors including: Species, length of tine ofexposure, |

siae, feeding habits, reproductive state (or tiae of year), acd lipid j|

content. Ba*ed on aome of these factors, the larger, adult fish should be

at higher risk, 1 »

It would appear that the condition factor of fish shovn in Tables 5-8

and 5-9 from the study are were well within expected limits, however, the

fact that a fish-condition factor ia acceptable does not necessarily iaply

that reproduction would be successful. Nearly all of tbe sheepshead minnows

in the study by Hansen et a! (1974) that suffered poor reproductive success ^

ware aot emaciated «nd appeared normal. Bowever, onecould only speculate ||

that the fish, particularly trout, with high PCS concentrations would suffer f|

adverse reproductive or genetic effects. ' -?• m

Regarding the second issue dealing with the "silting-over" phenomenon, g it

the contention in Section 3 of the report that thelower concentrations of |

PCBg in the upper 2 inches of sediment in many areas is a result of con- ^35 •»•,*'#

tandnated sediments being covered by clean sediments. This mechanism, the &_ i*

report claims, nay serve to control and isolate PCBs, This aay be the case, J|

. .m...

• • o • . . , one should be aware that upper-most sediments., being In direct

contact with over-lying water and subject to bioturbation and physical

^disturbance, will be in equilibrium with the over-lying water allowing FCBs

to desorb more readily. Thus, the lower PCBa in the upper sediments may

not be a "silting-over" phenomenon by cleaner sediments, but a gradual i leaching of the contaminants (desorption) from existing sediments into the

over-lying water.

The third question was "Is it accurate to correlate PCBs in fish with

PCfe insediaent or would food chain factors be more relevant?" Since the

PCBs of concern are those with the most hydrophobicity (highest log P

values), they readily adsorb onto suspended particular material, organic

f ?

1

materials (lipids) etc., rather than water. Both the sediments and the

biota, therefore, "compete" for the PCS molecul*. Several studies have iS

investigated the relationship between concentrations of PCBs in sediment

«nd the concentrations of the infaun*! animals in the sediment. In summary, %i^JI'

clean eniaal* placed in field-collected PCS contaminated sediments accumulate

from frit-half to approximately two times the concentration measured in the /

sediment*. Studies in the Great Lakes she* that ?CB body burdens of certain

flab species vary with tba concentrations of the food that they consume but

laboratory studies (Kacek et *1., 1979; Scura and Theilacker, 1977) suggest

that food-derived uptake is qualitatively insignificant compared with

bioconcentratioa from water. Since the scientific community is not united

in it* opinion on the importance of food chains in the propensity to transfer

materials such as PCBe, it would be presumption for me to suggest otherwise.

However, it can be stated that contaminated sediments serve as a source of

PCBa to the water by desorption and through the food of fi.h mostly via the

infaunal invertebrates (woros, stream insects, etc.). As such, one is likely T£t$

It..

I

• o • o to see a relationship of PCB residues in sediments and fish caught in the

vicinity of those sediaent*. Obviously, if the fish being aaapled is one

that remains in a localised area and feeds predominantly on iafaunal species,

a relationship should exist. If the fish being sampled, ranges widely and

feeds mostly on planktonic species, one would expect little or no correlation.

In short, the correlation of fish residues and sediment residues would be \

aoat valid if the fiah rwaiti in th* localized area and fed on infaunal species. sf*-te

The lest issue was; "Giva an opinion as to the seriousness of PCB

contamination of fish and a xeco-aendation as to what assures should be - |

take*." The aost serious fish contamination is with the trout. Concentrations |

of PCB* in trout, collected from the stretch of river from Pittsfield to . g m

Highway 183 Bridge averaged well above the PDA action level. Oae large 1-sfc905g brown trout contained 240 Ppm of FCB*, «t weight (48 tiaes the action

lisit). Based on the laboratory data published by Hensen et *1. (1974),

the possibility exists that the fialfehaving ?CB concentrations greater than fes

10 ppm nay be suffering aoae adverse reproductive effects. Certainly, at

th» very least these fish should not be conauaed by humans. There is no

easy wethod to determine if reproduction in the fish is adversely affected;

this would entail a coaplex and expensive laboratory and field effort. It

eee»0 more appropriate to » that the source of PCS* from those areas of

greatest contaadaation should be defined and eliainated, if possible.

Reviewing the data fron Section 3 of the Bousetonic BAver Study> total 1 *4

aass of PCEs in the river is 39,000 pounds, 90X of which is in the 12.5 |

mile ragion fro. the CE plant to Woods Pond Dam, 70% between the CE plant g ?£>

and the headwaters of Woods Pond. However, as I read the study, this excludes | •£&

those in Silver Lake (63,600 pounds) which is nearly 621 of the total nass j

of PCBs present. The study contends that there is no significant input of |

..

• • o • o> v_.' PCBs from Silver Laki to the river and that the lake serves as an effective

trap for PCBs. This nay be the case but it seems judicious to attempt to .

X-itigate the problem of 63,600 pounds of PCBs in a localised area, particularly ir

at the outfalls of the CS plant in the lake containing 30,000 pounds. f

In general, it appears that the study addresses Silver Lake in a very |

superficial manner which is unwarranted considering the huge aaount of j|

material there (nearly 32 tons of PCB«). The superficial presentation of | l|l'

Silver Lake along with strong contentions that it is not a significant jj ?U

source of PCBa to the Housatonic River raises aor* questions thaa those ^ -C-'| =t s

answered: Soae questions that might be asked are: m

1. -Since the differing ratios of Iroclor* 1254 and 1260 in the lake g

compared to the river (Section 6.5) cannot be explained by solubility f

since Aroclor* 1254 is »ore soluble than 1260, what is the historical g

-§ record of release of the tvo oaterials? What is the liklehood of g

IS

another release point of 1260 by the plant to the river rather jj

than through the lake? J| w

2. -Sow i* th* T»fcg presently used? Considering the saount of materiel*

present, isn't tb*re « significant hazard to the city of Pittsfield?

3. -Bow were the aeaaureaents of PCBa during the stora taken?

4. -Bow severe was the stora event, and how auch rain fell?

5. -Considering that the lake serves to receive storm water runoff,

why was not the neasured particulate load higher than 5 to 10 ng/1

(Table 6-4)?

6. -What is the noraal flow out of the lake to the Bousstonic River?

Isn't 4 to 6 cu. ft,/oinute a relatively low flow considering the

lake's use?

i

o o Requests for Further Information

I believe that oost of the gaps in infomstion that are practical to

'fill relate alaoat entirely to answering the questions about Silver Lake in

the previous section.

Assuming no further input of PCBs to the Housfltonic river, the high

residues in fish collected from the river will only dioiaiah with time,

Perhaps so»e of the river "hot spots" of PCBa from Pittsfield inclusive of

Woods Pond can be cleaned up, but a cleaning of the entire river froto

Pittaf ield to and including Woods Poad epp«ars iapractical. Studies could

be undertaken to detferaine th« threshold concentrations of PCBs in fish

that would cauae reproductive failure, but if the PCBs austjreaain in the

river sediment a, it appears to be an acadealc_exerci8c. n In short, the only practical, cost-effective remedial neasure would s

to be the elimination of the highly contaminated sedinents fro* Silver Lake

s -

* 2fi

o . o . References

Anonymous. 1971. The striper-tbie century's dinosaur. Stripers Unlimited

•1971 Directory and Guidebook, pp 11-62.

Hansen, D.J., S,C. Schiaael, and J. Forester. 1974. Ajroclor* 1254 in eggs

of sh«epahead ainnows: Effect on fertilization success and survival

of eabryoe and fry. Proc. 27th Amer. Con*. Southeast. Asaoc. Gaae and

Fish Coaa, pp 420-426.

Johannason, H. . S» Jensen and M. OLaaon. 1970. PCB-itidicators of effects

on fish* In: "FCG Conference, Denver-Gren Center". Sept. 29, 1970.

pp 59-68. Katl. environ, ?rot. Bd., Stockholm,

Macek, K.J., S.R. Petrocelli, and B.B. Sleight, 112. 1979. Considerations

in assessing th* potential for, and significance of bioasgnification

of cheaical residues in aquatic food chains. In Aquatic Toxicology,

ASTM STP 667, L.L. Harking and R.A. Kiaerle, Eds. pp 251-268.

Scura, E.D* and C.H. Theilacker. 1977. Transfer, of the chlorinated

hydrocarbon PCB in a laboratory aarine food chain. Maria* Biol.

40(4): 317-325.

i o oThe Housatoalc River Study if' — • .|_>

John F. Paul & ERL-KarragansEtt

,•*»JRS-

Hy overall iapression after reviewing the report is that it appears g

that a lot of field work «as done, but that the results of this field work g

have not been organized in a foraat that aakes it easy to understand .what . j|

was done. It is difficult to understand the implications of the results g

because so awch of the reader's effort has to go into trying to organise §

the information. In other vords, I don't think the report is easy to read ji 1

and understand* K IS

lou had requested that I specifically review the eediaent transport . g

study and address specific.concerns that you had. To review the sediaent fe

transport study, I found it necessary to revlev the sections preceding that g

study* Ifeat I a» going to do is address your concerns and then give you wy jj

specific cosBsents on the first four ..sections of the report, up to and j|

including the transport study* §

Specific Concerns; ||

Is the study to Connecticut adequate to give a reliable estisiate of PCBe ||

transported to Connecticut in the sediacnt onan average annual basis? ||

There is a problem with howthe daily PCB discharges (and subsequently J|

the isean annual average value) are calculated, as discussed below. This ^

sprpblea should be corrected. g-Au alternative way to estimate the transport of PCSe %rould have been -fe

to develop and validate a siaple iwdel for river flow, suspended solids J|

transport, and PCS transport. This approach might have been better since f|

it could have been used to estimate the effects of reaedial action. g|

i

r̂ O,(j v_Is any further study needed to characterize or quantify eediaent and/or

s ||

^^ ^

PCS transport in the Hous*tonic River?

The sediment data should be analyzed by depth levels to give a better

distribution of the PCBs. The transport studies should ug« tb« entire

JJ

j r^S

g

available period of recor'd for flow instead of just 20 years. Again, it |J

night be useful to develop and validate a siaple model for transport.

Also, a range should b« specified for thevalues given. ?o* exanple, best

guess, low estimate, and high estimate.

on the phenomenon of "silting over" which is discussed in the report.

j *F

|

I§ £f.

What is called "silting over" is a direct result of tbe reduction in

and/or shut-off of the source of PCBs. Data fro. more than two sites should

be investigated if any major conclusions are to be drawn fro* this fact.

In particular, the "silting over" effect should be investigated to s«* if

it is statistically significant. , It should be recognised that even those

areas that have -silted over" still have significantly high levels of PCBe |

*•• in the upper two inches of the sediamnts* . Jf

Axe there specific areaa of PCS and sediment deposition identified in the

study for which remedial action (dredging, capping, etc.) should be

considered?

Silver Lake and th* areas downstrean to, and including, Woods Pond are

J

likely candidates for remedial action based upon the amounts present,

detailed raps of PCB concentration should be prepared for these areas.

tore

These «aps should be prepared by depth levels to give an indication of the

depth to which possible dredging aay be required.

1*?=, '.'5

1

-:: O O Introduction comments;

I found this section to be poorly referenced. There is a lot of

information that is presented in this section which, I have to assume, was

taken fro» other sources. It would be useful to know these sources.

In section 1.4.3, a discussion is given on the. bottom aaterial that

-rte apears in different reaches of the river. My first impression was that

§this information would b* useful in determining where to expect PCBs to g

accumulate along the river. However, a problea comes up for the upper |̂

segment of the rivsr, where the PCB« ate found in the small pools and j|

deposition areas, bat where the segment is characterised as composed of fg:

cobble and boulders. f|

At tb>e top of page 1-9, it reads that low flow occurs in the early J|

spring tod summer. I*this right? ||

Investigstiona •**.-.

In section 2.3,it is first stated that, typically. Aroclor*1242

comprised no more than 5X of th* total PCS. The implication being that

there were some samples with values greater than 51, The 5* level for

Aroclor* 1242 was then used as a cut-off for specific analysis for it.

Then it Is stated that actual Aroelor* 1242content iraa always le*s than SI

of the total PCS present. This part should b* rewritten to etete exactly

what the situation is.

In section 2.4.1on the determination of PCS aass ia bottom sediments,

it is not clear how the calculations are done. For one thing, I as not

quite sure what £ really is. More importantly, it is not clear if the

calculation is applied to each sampling location or if it ifi applied to

some aggregate of sampling locations. This point is important because the

,

§

c . c - .S actual results and the fors the results take can be affected. For exanple, f|

i if a straight arithmetic average of all samples for a specified region of J|

the river is taken, then this average value is biased according to the J|

density of the sampling scheme. A volume-weighted averaging scbeae could g.&

eliminate the bia*. Also, if the PCB n&sa were calculated according to the g

seapiing depths (0-16 cm, 16-32 ca, etc.), then information would be avail fe

eble for developing possible remedial alternatives. As anexample, the ||

actual volumes that would have to be dredged to reduce the PCB sediment J|

^^ values to specified levels would be available, H

Oa page 2-8, in the section on particle size distribution in bottom g

sediments, it is stated that 90X of the sediment load is medium to fine

grained sand. Do they mean sediment load or bottom sediments?

Bousatonic River Sediment Investigations

In section 3.2.3.1, the following statement appears, "It is significant

to note that in ell cases, the total PCB concentration in the top two-inch

increment of the core is the lowest of any of the samples in the study."

It i» not clear what is meant by this statement. Are they saying the top

two-inch increment is the lowest of any two-inch increment for the sample?

Sows tests on th« statistical significance of the results should be performed.

Mbre data, may be needed to see if this trend occurs at more than two locations.

It is stated that the implications of these findings are discussed in

section,3.4. I could not find this discussion. If

Figure 3*6 could have been more useful if the log of the PCB concentration jj

had been plotted. -!£

In the discussions in section 3.3, it is not clear if averages are J|

simple arithmetic averages or volume-weighted averages. It would be useful p

£5 51

o • . c to show PCB loads by depth for each river unit, and also to give a range of

uncertainty for the load estioates*

In section 3,3.1, a significance ie taplied about tie Uskaaet Srook,

Is it expected that PCBs aay be coming ia to the river fros the brook?

Section 3.4.1 should state explicitly that the quantity of PCEs does

not include the aaount in Silver Lake.

On page 3-26, the following stateaent appears, "When one considers

that PCB« were used at the GE plant for 40 years, this represents an average

migration of less than 0.3 mile/year." This statement is not really based

on information presented and appears to b* irrelevant. A hidden assuaption

in this stateaent is that all of the fCB* discharged into the Bousatonic

River are still in the section of the river that lies in Massachusetts.

This aasuoption can only be tested if the historical record of PCB discharges

into the river is available.

Except for conclusion 1 in section 3.4.2, I don't see how these

statements are baaed on inf orastion that has been presented. Where does

conclusion 2 coae f ro»t It is not based on inf oraation in this section.

Conclusion 3 should say that the source of PCBs haa been reduced or ehut

off. Conclusion 4 should say that these areas h*v* acted a* traps but are

potential sources of FCBa for the downstreaa reaches of the river. One

very aajor stora could release a large aaount of FCBe. I don't know where

conclusion 5 caae froa.

Suspended Solids and PCB Transport Study Coaaeots;

Section 4.2.3 starts oat soundiog like a "boaat" of what they did. I

do not think detection levels of 30 ppt are stete-of-the-art. A few ppt

are the current state-of-the-art. The terminology that is employed to describe

I

.

• o o i what 'is really the dissolved and particular concentrations is confusing g

fe and is difficult to keep straight if you have never seen this used before, g

§S Appendix 4.2 does not give a comparison of aethod details, as is stated jj

fe in section 4.2.3.- The appendix describes the U8G8 aethod. . g

If they are using state-of-the-art techniques, I find it hard to H ^~t

baliive they could only do particle size distributions when the suspended g £S

—aX

solids concentrations exceeded 40 s^/1 (section 4,2,4), j| ^te

A common problem in section 4.2.4,1 (and aost other ssctions of the & fe

report) is that no dates are given when dsts are presented and/or discussed. j| ••7SJP

Thia makes it very difficult to understand the results. Another problem is tj

that it is difficult to find out what the actual dates of the short-term y.

transport studies w*re, ISt •is

The st&temant on page 4-7 on why FCBe are on the larger particle sizas jj

can only b« made if the PCB size distributions are known for more than one site. ff ft

It is difficult to understand w&ere the first observation on page 4-8 jj

came fro» when the stream velocities are not presented. Observation 2 can |f&5~

only be dravn if the information is available at more than one site. j|

Observation 3 on page 4-iO ie difficult to make without doing a mess

balance on the suspended solids.

Why is no discussion given on PCS adsorption/desorption in section 4.4?

Section 4.4.1 references Appendix 4.4, which does not exist. I think

they mean Appendix 4.3

I do not agree with the rationale in section 4.4.1*1 for only using 20

years of the data. The low frequency-of-occurrence high flows are the ones

that can transport the majority of the aeterial in the river. By limiting

the period of record, some of these significant high flows could be ignored.

One coament 1 have on section 4,4.1.2 is on the use of only 20 years

m

O . . O . ' of data for flow rates. /Another one concern* how they calculate the daily

PCS discharges. This was calculated by aultiplying daily PCB to suspended * sclids ratio by the daily discharge of suspended solids. Tney should have

calculated it by »ultiplying the ratio by the daily discharge for each U

of thfi occurrence and then Sttradng up. They have probably underestimated

the P€5 load. This calculation should b* redone.

They say in section 4.4,1.2 that the PCB loads were calculated for all

stress flow conditions. Tbey only calculated it. for the stream flows that

occurred during the 20 year period of record.

Table 4-30 would be wore useful if some error bars could be placed on

the values presented.

The conclusion* in section 4.6.2. appear fco follow fro* what has been

presented in the report.

fe

§ 1

I t3