Evaluation of the Surface Water Contact Advisory Removal Program

Brittany SchuchCandidate for the degree

Master of Public Health – Program for Experienced Professionals

College of Public Health The Ohio State University

Columbus, Ohio, October 2015

Dr. Elizabeth Klein, AdvisorDr. Michael Bisesi, Second Reader

Abstract

Contact advisories have historically been posted on streams and rivers near or in areas of egregious contamination. Currently, in the State of Ohio, there are four contact advisories in place on rivers across the State. A more formalized and consistent approach to evaluate the removal of contact advisories was determined to be a need, and this evaluation was created to provide recommendations for consistent decision making. Its design is a mixed approach of a formative and process evaluation. The scope of this evaluation is to recommend a consistent approach for reevaluating and removing contact advisories when justified. Primary data sources include in-depth, qualitative interviews and a standardized survey on Region V staff. Secondary sources of data included peer-reviewed literature on impacts of contamination and remediation efforts, Ohio EPA risk assessment documents, existing water quality and sediment data, and agency website and publications.

The results from this evaluation will be an asset to Ohio Department of Health (ODH) to review in a consistent manner in order to make a decision whether or not to remove a contact advisory after a contaminated site has been cleaned up and remediated. The recommendations include using visual inspections as the key element of information to remove the contact advisories, create a visual inspection form, create a checklist process for contact advisory re-evaluation for each contaminant of concern, and improve communication between ODH and related agencies regarding sampling plans.

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Table of Contents: Page

List of Abbreviations 4

List of in Text Tables 4

Introduction 5

Literature Review 8

Environmental Program Evaluations 9

Issuing Contact Advisories 12

Completed Ohio Case Studies 13

Remaining Contact Advisories 22

Contaminants of Concern 23

Ongoing Remediation and Re-evaluation Case Study 25

Remediation Standards 29

Agency/Organization Description 32

Evaluation Design 34

Methods 39

Ethics 42

Results 42

Discussion and Recommendations 50

References 58

Appendices 62

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List of Abbreviations:

ASTDR Agency for Toxic Substances and Disease Registry

DERR Ohio EPA Division of Environmental Response and Revitalization

DSW Ohio EPA Division of Surface Water

NPL National Priorities List

ODH Ohio Department of Health

Ohio EPA Ohio Environmental Protection Agency

PAHs Polycyclic Aromatic Hydrocarbons

PCBs Polychlorinated biphenyls

USACE United States Army Corp of Engineers

U.S. EPA United States Environmental Protection Agency

USGS United States Geological Survey

List of in-Text Tables: Page

Table 1. Current contact advisories in the State of Ohio 22

Table 2. Case comparison table for Black River and Middle Fork Little Beaver Creek 42

Table 3. Table display of qualitative data from two interviews of Ohio Department of Health

decision maker 44

Table 4. Survey Response to Questions from Region V states 47

Table 5. Comparison of sediment data for re-evaluation of contact advisory. Data sets from the

Little Scioto River and Black River case studies 48

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Introduction

Statement of Problem

Contact advisories have historically been posted on streams and rivers near or in areas

with egregious contamination, and currently in the State of Ohio, four contact advisories are

still in place on various rivers across the State. So far, three complete contact advisories have

been rescinded by ODH. In the past few decades, remediation efforts have aided the cleanup

and remediation of the four remaining sites, and Ohio EPA and ODH have been assessing the

sites to determine at what level of remediation the contact advisories can be lifted. The four

sites that currently have contact advisories are the following: Little Scioto River, Ottawa River,

Dicks Creek, and Mahoning River. All these sites are in different stages of remediation,

recovery, and re-evaluation, and eventually the goal for these sites is to rescind the contact

advisories post remediation and establishment.

Purpose

To formalize a more consistent approach to evaluate the removal of contact advisories,

a program evaluation was undertaken to help create more effective and efficient programs for

consistent decision making. The goal of this evaluation is to help determine which program

aspects or activities are most needed to enable Ohio Department of Health (ODH) decision

makers decide whether it is appropriate to remove the contact advisory.

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Rationale

The results of the evaluation may influences changes in operation and review of

collected data to enable a consistent review of information prior to making a decision to either

designate or remove an advisory. Indeed, the results of this evaluation are intended to aid staff

to create successfully a formal program to remove contact advisories in the future.

In supporting this evaluation, several specific aims have been identified and are listed

below, and three specific evaluation questions were created for this project. Each aim describes

the specific activity, and the specific outcome for each activity is defined.

Specific Aim 1: Determine how other entities (State and Federal governments, universities)

have reviewed and assessed streams with contact advisories by conducting a review of

literature related to contact advisory development and removal.

Activity: a review of literature related to contact advisory development and

removal with associated stakeholder involvement

o Outcome: determine themes on how other entities have determined a

site is safe again for human contact

Specific Aim 2: Determine what ODH considers the most important when evaluating

information to suggest removal of a surface water contact advisory (Evaluation Question 1).

Activity: a semi-structured interview of ODH staff responsible for making the

recommendation to remove a contact advisory

o Outcome: to interpret and identify common themes from decision maker

Specific Aim 3: Determine how other contact advisory removals have occurred in Midwestern

states

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(related to Evaluation Question 3)

Activity: a broader survey of other program staff in Region V states who are

engaged in activities related to contact advisory assessment

o Outcome: to interpret and identify common themes from decision

makers in other Midwestern states

Specific Aim 4: Determine what pieces of each Ohio case study are consistent and which pieces

are not consistent (Evaluation Question 2)

Activity: development of a checklist with a side-by-side comparison that visually

shows what the two cases have in common and what they don’t have in

common

o Outcome: the two case studies examine the mechanisms used in the past

to evaluate sites to remove contact advisories

Specific Aim 5: Determine the “big picture” schematic of the current process and players

involved with the contact advisory removal process

Activity: development of a logic model to describe the overall process of contact

advisory removal

o Outcome: make recommendations to streamline process for efficiency

and consistency through the development of a flowchart

The purpose for this evaluation is to suggest recommendations to ODH to aid in the

development of a formal program. This will help ODH identify the items throughout the contact

advisory process that should be considered when making a final decision regarding the contact

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advisory. The principle audience for the evaluation is an internal audience composed of Ohio

EPA and ODH staff.

Literature Review

Background

Completing program evaluations on environmental programs is a new concept that is in

its infancy in implementation. The purposes of program evaluations are to study systematically

how well a program is working and to create more effective and efficient programs after the

results of a program evaluation are determined. Program evaluations can assist decision makers

to make better program management decisions, entertain new and innovative ideas for

programs, and continuously improve programs. Formative evaluations are intended to furnish

information that will aid in program development. The target audience for these types of

evaluations is typically program planners, administrators, or funders, due to the interest in

optimizing the program’s effectiveness (Rossi et al., 1999). Typically, the evaluator works closely

with these individuals when designing, conducting, and reporting the evaluation (Rossi et al.,

1999). The purpose of a formative evaluation is to clarify activities in order to organize better

activities and procedures for the development of a more formal program.

The type of program evaluation conducted should align with the program’s maturity and

should be driven with the program’s maturity and the purpose for conducting the evaluation

(NCEI et al., 2009). The evaluation questions should also be considered when determining the

type of program evaluation to use (NCEI et al., 2009). Completing an evaluation on a program’s

design can be helpful when a program’s goals are less defined, if only a few staff members are

charged with developing the program, or if uncertainties exist about a program’s intended

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activities (NCEI et al., 2009). In summary, the type of program evaluation chosen should align

with the program’s maturity and should be driven by the evaluator’s purpose for conducting

the evaluation and the questions to be answered (NCEI et al., 2009). Because of this program’s

infancy and complexity, a blend of a formative and process evaluation was chosen for the

evaluation design. The formative aspect of the design aids to help produce recommendations

for the creation of a program to reevaluate and remove contact advisories. The process aspect

of the design aids to further study specific features of the contact advisory process to suggest

recommendations for consistent and efficient decision making.

Environmental Program Evaluations

There are several examples of evaluations that have included the review of complex

environmental programs with many stakeholders and associated goals. One such evaluation

was completed for the Office of Water, Office of Policy, Economics and Innovation, and Total

Maximum Daily Loads (TMDL) Innovations Workgroup. TMDLs are complex calculations that are

used to determine the maximum amount of pollutants that can go into a body of water. This

evaluation assessed how TMDLs can be developed and established to make it easier for

relevant parties to implement (IEc, 2007).

To evaluate this program, evaluators collected and analyzed information by conducting

a review of literature, completing two surveys, and doing case studies on seven TMDLs (IEc,

2007). The review of literature consisted of reviewing documents related to TMDL development

and associated stakeholder involvement. One survey was directed to the U.S. EPA TMDL staff

from U.S. EPA Regions and the other survey was directed to other U.S. EPA program staff from

U.S. EPA Regions engaged in activities related to TMDLs. The surveys contained quantitative

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and qualitative questions designed to elicit insights into the nature and quality of stakeholder

participation and implementation plans during the development of the TMDLs (IEc, 2007). The

case studies on the seven TMDLs further explored how elements contributing to the

development of TMDLs impacted approaches to watershed protection (IEc, 2007). The case

studies focused on how stakeholder involvement and implementation planning drove the

outcome of the TMDL. The final report organizes the discussion of results by the six overarching

evaluation questions; qualitative and quantitative results were discussed and recommendations

were made to improve the TMDL process (IEc, 2007).

U.S. EPA’s Office of Resource Conservation and Recovery (ORCR) and the Office of

Policy’s Evaluation Support Division (ESD) conducted a program evaluation to assess the

WasteWise program. In January 1994, U.S. EPA launched WasteWise, which is an

environmental program designed to help businesses, government, and non-profit organizations

find practical methods for reducing municipal solid waste (MSW) (IEc, 2010). WasteWise

currently has over 2,000 partners representing over 50 sectors who commit to reduce and

recycle MSW and select industrial and commercial wastes (IEc, 2010). Partners include large

corporations, small- and medium-sized businesses, schools, colleges, universities, hospitals,

state and local governments, tribes, and other institutions. WasteWise uses a broad range of

approaches to encourage prevention, recycling, and reuse of waste, and the program activities

include various forms of technical assistance and recognition (IEc, 2010). The goal of the

program evaluation was to assess changes in waste management behavior at partner

organizations and explore how to improve performance measurement moving forward (IEc,

2010).

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U.S. EPA’s Office of Resource Conservation and Recovery (ORCR) and the Office of

Policy’s Evaluation Support Division (ESD) were interested in conducting an evaluation on the

WasteWise program because this program involved a variety of partners and sectors (IEc,

2010). Because of the numerous players involved, U.S. EPA contractors used a mixed methods

approach to collect information for this evaluation. Their sources of existing information

included existing data and documentation on the WasteWise program, including data and

documents related to partners’ use of WaseWise program activities and services, such as the

WasteWise website, helpline, annual conference, and awards program, peer-reviewed

literature on impacts and attribution issues associated with voluntary programs, company

websites and publications, and websites of selected U.S. EPA partnership programs (IEc, 2010).

Their new information sources included forming focus groups with representatives from a

sector participating in WasteWise and conducting surveys on select staff (IEc, 2010).

The methodology selected by the U.S. EPA contractors hired to conduct the evaluation

had its strengths and weaknesses like any study. The greatest strength was that this evaluation

included a multitude of information sources including data collection and analytical methods, a

literature review, a focus group, a survey, interviews, a best practices review, and analysis of

existing data (IEc, 2010). Using multiple sources of information to address the evaluation

questions provided the opportunity for findings from one source to validate or contradict

findings from another source (IEc, 2010). When findings are validated by more than one

information source, it results in increased confidence in the research findings. However, the

biggest limitation in this methodology was that certain sources of data could not be quantified,

such as changes in waste management attitudes and behaviors. (IEc, 2010). It was difficult for

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evaluators to determine recommendations given the complex way this program shares

information and influences behavior (IEc, 2010).

Several recommendations were provided to U.S. EPA as an outcome of this evaluation.

The evaluators recommended increasing communications from U.S. EPA to WasteWise

partners, and this recommendation came from the interviews and focus group participants (IEc,

2010). Also, in regards to communication, the evaluators recommended promoting additional

communication among the actual WasteWise partners by providing an online venue for

networking (IEc, 2010). Regarding data for the program, evaluators recommended that the

value of current tools can be bolstered by ensuring underlying data is up to date (IEc, 2010). In

summary, by using a variety of data sources in the evaluation, a variety of recommendations

could be made to encourage improvement and efficiency for this program.

Issuing Contact Advisories

Contact advisories have been historically issued to sites that have experienced egregious

contamination (www.odh.ohio.gov). A contact advisory could be issued for a variety of reasons,

but by issuing a contact advisory, the public is advised against swimming and wading in the

impacted stream (http://www.epa.ohio.gov/dsw/SurfaceWater.aspx). Typically, the area is

demarked by the presence of “No Fishing, Wading, or Swimming” signs being posed

(http://www.epa.ohio.gov/dsw/SurfaceWater.aspx). The placement of a contact advisory is

completed by ODH based on the site conditions, including exposure, and determining that

contact with the surrounding environment could harm people’s health

(http://www.epa.ohio.gov/dsw/SurfaceWater.aspx). Currently, in the State of Ohio, four

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contact advisories are currently in place on various rivers.

(http://www.epa.ohio.gov/dsw/SurfaceWater.aspx).

Completed Ohio Case Studies

A 21-year-old contact advisory on the lower five miles of the Black River was lifted by

ODH in 2004. In 1983, ODH issued a contact advisory to avoid physical contact with sediments

along a stretch of the Black River reaching from the mouth of the river in Lorain, Ohio, to a

point 6 miles upstream (Ion, 2004). The advisory was issued over concerns of PAH

contamination to the river from coking activities at the nearby USX Steel Corporation (Ion,

2004). The issuance of the advisory was further motivated by the high liver tumor rates in

brown bullhead (Icaturus nebulosus) in the stream (Ion, 2004). The coking activities at USX were

terminated in 1983 and a Consent Agreement between U.S. EPA and USS/Kobe Steel mandated

the remedial dredging of the contaminated section of river that was most grossly impacted by

the PAH discharges from the steel plant (Ion, 2004). In 1990, 50,000 cubic yards of

contaminated sediment was removed from the river bottom (Ion, 2004). Dredging of the river

occurred in 1989 and 1990 and tumor prevalence was observed in fish sampled in 1992 and

1993, possibly due to the exposure of PAHs re-suspended during dredging (Ion, 2004). Fish

were continuously monitored in the 1990s and tumor prevalence rates declined as well as PAH

concentrations found in sediments (Ion, 2004). Over time, water quality and the fish community

gradually improved. A re-evaluation of the contact advisory was requested by Ohio EPA and the

Black River Remedial Action Plan (RAP) Committee because of the improvements in ecological

health and functions of the river (Ohio EPA, 2004). A re-evaluation was completed by ODH,

which led the State to lift the contact advisory (Ion, 2004).

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The re-evaluation report examined historical data on PAH levels in the Black River

sediments, historical data on hepatic tumor presence in bullhead, and included a quantitative

risk assessment in examining the cancer risk associated with dermal exposure to carcinogenic

PAHs in sediments (Ion, 2004). ODH fully characterized the impacted region, which included a

general description of the study area, and discussed the steel facility’s operations and history of

contaminant loading (Ion, 2004). The re-evaluation also discussed a description of remedial

dredging that occurred by the U.S. Army Corps of Engineers (USACE) (Ohio EPA, 1999).

Historical sediment data was available from Ohio EPA, USACE, and the United States Geological

Service (USGS) for the years 1983, 1984, 1988, 1992, 1996, 1997, 1998, and 2001; this data was

compared and analyzed in the re-evaluation (Ion, 2004). Control sites, Ohio reference lakes

were compared against the Black River sediment data to establish a baseline for PAH

concentrations (Ion, 2004). Historical data on hepatic tumor prevalence in Black River brown

bullhead was reviewed through a review of the applicable literature (Ion, 2004). A preliminary

cancer risk assessment was calculated based on direct dermal exposure to PAH-contaminated

sediments using different exposure scenarios (Ion, 2004). Because of the nature of PAH

photoinduced toxicity, special consideration was applied when calculating dermal risk. (Ohio

EPA, 1999).

PAH concentrations in the Black River sediments declined significantly after dredging.

The first post-dredging sediment data was available in 1992 (Ohio EPA, 1999). Several locations

downstream of the steel plant’s discharge point continue to have elevated PAH sediment levels,

which could be attributed to residual contamination or continuing inputs of PAHs from the steel

plant (Ion, 2004). Even though the re-evaluation supports that PAH sediment levels in the Black

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River are the lowest measured, they are still significantly higher than the sediment PAH levels

recorded in the Ohio reference lakes (Ion, 2004). Most of the PAHs measured in the re-

evaluation were above the threshold effect level (TEL) in 2001 but below the probable effects

level (PEL) (Ion, 2004). Individual PAHs and total PAHs recorded near the steel plant’s discharge

point were recorded at levels 2 to 4 times higher than the probable effects level (PEL) (Ion,

2004).

The re-evaluation report did not discuss in detail the steel plant’s discharge or whether

the outfalls were still in use. According to the re-evaluation report, the outfalls for the steel

plant are located throughout the remediated site (Ion, 2004). Currently, there is a permit issued

to United States Steel Corporation Tubular Products Division (Permit Number 3ID00074*ED)

that uses the outfalls previous under USS/Kobe Steel

(http://www.epa.ohio.gov/dsw/permits/index.aspx). Under the permit, the permittee is

required to sample for specific PAHs and the facility is currently in compliance with these

parameters (http://www.epa.ohio.gov/dsw/permits/index.aspx).

The last year of available data for this re-evaluation was 2001, and total PAH

concentrations ranged from 0.67 to 16.4 mg/kg (Ion, 2004). Even though no PAHs were

detected at 10 of the 26 sites sampled by Ohio EPA at the time, concentrations were the

highest at RM 3.43 at 17.0 mg/kg, which is the site just downstream of the historical coking

operation discharge point at the steel plant (Ion, 2004). USACE also sampled in 2011, and the

highest concentration of PAHs was at RM 2.77, which had a concentration of 16.4 mg/kg; this

site is also immediately downstream of the same discharge point (Ion, 2004).

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The prevalence of hepatic tumors in bullhead was studied in the re-evaluation support

the removal of the contact advisory (Ion, 2004). In 1982, the data suggests that 38% of the

bullhead population had hepatic cancer and by 1987, the percentage of cancer fell to 10% (Ion,

2004). The remedial dredging began in the late 1980s and concluded in 1991, and cancer levels

were shown to increase in 1992 (Ion, 2004). This was likely due to the fish becoming exposed to

re-suspended levels of contaminants (Ion, 2004). In 1994, the fish were resampled and cancer

levels fell to the levels recorded in 1987 (Ion, 2004). The results of the last sampling campaign

in 1999 demonstrated that cancer prevalence rates were continuing to decline and were

approaching levels seen in reference populations (Ion, 2004).

Calculated cancer risks were conducted for both wading and swimming scenarios and

most risks were within the bounds of acceptable risk (Ion, 2004). Cancer risks were calculated

using several different methods: oral toxicity slope factors (IRIS method and PRG method),

dermal slope factors, and reasonable maximum exposure (RME) calculations for both wading

and swimming (Ion, 2004). Cancer risks calculated using the dermal slope factor were

approximately 5 times higher than those calculated for the oral slope factors (Ion, 2004). All

cancer risks were within the bounds of acceptable risk (range: 1.13*10-5 to 8.72*10-6) with the

exception of the RME wading scenario (risk level of 1.92*10-4) (Ion, 2004). The risk was higher

for wading than for swimming due to the higher likelihood of contact with contaminated

sediments (Ion, 2004). There was a considerable amount of uncertainty when conducting the

risk assessment due to assumptions made when calculating the dermal absorbed dose,

assumptions made underlying the use of toxicity equivalency factors, and the use of oral slope

factors for calculating risk from dermal exposures (Ion, 2004). Carcinogenic risks associated

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with dermal exposure to PAH-contaminated sediments were assessed using U.S. EPA’s risk

assessment guidance (Ion, 2004). The baseline human risk assessment process involves the

following steps: site characterization, exposure assessment, toxicity assessment, risk

characterization, and uncertainties (U.S. EPA, 2001). At the time of the re-evaluation, there

were no approved toxicity factors for cancer risks associated from dermal exposure to PAHs;

when this occurs, U.S. EPA guidance recommends the use of toxicity estimates, such as oral

slope factors, as a replacement (U.S. EPA, 2001).

To justify the removal of the contact advisory, ODH made several conclusions to prove

that PAH concentrations in Black River sediments declined considerably relative to recorded

samples in the 1980s (Ohio EPA, 2004). Routine sampling and monitoring of PAH concentrations

were recommended to support the removal of the contact advisory (Ohio EPA, 2004).

Continuous sampling was recommended to document PAH concentration trends to help

identify any new input if they should arise (Ion, 2004). The re-evaluation documents

inconsistency in the choice of sampling sites and sample collection methods when reviewing

data from all previous methods (Ion, 2004). The re-evaluation recommends that sampling

locations should be chosen in a more consistent fashion and the same sites should be sampled

for every survey (Ion, 2004). This would capture more accurate temporal comparisons of PAH

concentrations on the impacted stretch of river. The re-evaluation also recommended routine

sampling of bullhead populations to ensure the decline of hepatic cancer prevalence continues

(Ion, 2004). The re-evaluation also recommended further sampling of shoreline and near shore

sediments at likely river access points to study more in depth dermal exposure risks (Ion, 2004).

The calculated dermal absorbed dose in the re-evaluation assumes a 24 hour exposure period

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and the cancer risk can be greatly minimized by washing off sediments after being exposed

(U.S. EPA, 2001). ODH suggested that appropriate risk reduction information should be

communicated through signs and written material to express this risk reduction preventative

measure (Ion, 2004). U.S. EPA was in the process of revising its approach to risk assessment of

PAHs at the time the Black River re-evaluation was completed (Ion, 2004). Additional risk

characterizations would need to be revised when the new risk assessment information became

available. Overall declining PAH concentrations, dramatically reduced tumor prevalence in

bullhead, and acceptable risk estimates from a quantitative risk assessment suggest that a ban

on contact with Black River water and sediments was no longer required (Ion, 2004).

Another contact advisory has been recently removed on the Middle Fork of Little Beaver

Creek (MFLBC). The contact advisory was placed on the MFLBC in March 1988 by ODH due to

concerns with exposure to mirex contamination in the stream (T. Wymyslo, Director’s Journal

Entry, February 11, 2011). Mirex is a man-made compound that was used as a pesticide and the

mirex in the impacted areas of the MFLBC originated from releases from the former Nease

Chemical manufacturing facility, which is located upstream of the original advisory zone (T.

Wymyslo, Director’s Journal Entry, February 11, 2011). A series of sampling events conducted

by the Ohio EPA and consultants detected mirex in fish, sediments, and flood plain soils in the

1980s (T. Wymyslo, Director’s Journal Entry, February 11, 2011). The contact advisory was

issued due to the physical presence of the compound in a variety of media and the

uncertainties with regards to its’ ability to affect the health of people who might come into

contact with the creek (T. Wymyslo, Director’s Journal Entry, February 11, 2011). The

Endangerment Assessment used standardized risk assessment methodologies and the direct

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contact risks were shown to be below the U.S. EPA threshold (T. Wymyslo, Director’s Journal

Entry, February 11, 2011). As a result, U.S. EPA and Ohio EPA petitioned to ODH to lift the

contact advisory from the MFLBC. On the basis of U.S. EPA’s and Ohio EPA’s petition, the

contact advisory was rescinded in 2011 (T. Wymyslo, Director’s Journal Entry, February 11,

2011).

Mirex in the MFLBC is postulated to originate from the former Nease Chemical

manufacturing site in Salem, which was located at the upstream extent of the advisory zone.

The former Nease Chemical manufacturing site is a Superfund site consisting of 44 acres along

State Route 14, two and a half miles northwest of Salem on the Columbiana-Mahoning county

line. Between 1961 and 1973, Nease Chemical produced various household cleaning

compounds, fire retardants, and pesticides, some of which included mirex. The company used

ponds to treat waste water from the manufacturing process. Surface water runoff from the

ponds previously flowed into Feeder Creek, which is a tributary of the MFLBC. The ponds were

decommissioned by placement of backfill in the 1970s. Extensive and continuing investigations

of the extent of mirex in the MFLBC and surrounding areas have been undertaken under the

direction of U.S. EPA and Ohio EPA over the past several decades. These investigations have

shown that mirex can be transported in the environment with fine grained sediment material,

but consistent with its lack of solubility, mirex is not present in surface water at concentrations

that would be of concern to human health. The investigation fieldwork included sediment,

floodplain soil, surface water, and fish sampling events in 1982, 1983, 1985, 1987, 1990, 1997,

1999, and 2001. The highest detection of mirex in sediment was 2,820 ug/l at Station 12 near

the western crossing of the MFLBC by Middletown Road. A total of 21 surface water samples in

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2001 have been collected from the MFLBC and tributaries, all of which were non-detect for

mirex.

Since the contact advisory was issued in 1988, various measures have been taken at the

Site, under the direction of U.S. EPA and Ohio EPA, to mitigate potential releases of

contaminants to the MFLBC. Structures installed on-site at Nease Chemical provide for surface

water detention with sediment control outlet structures, including berms, aggregate and fabric

filters, and elevated outlet control pipes, and surface water diversions to route runoff around

the Site so that runoff does not become contaminated. Multiple fabric barriers were also

placed in Feeder Creek so that any sediment escaping the on-Site outlet control structures is

captured by this secondary mechanism (RNC, 1996). These structures have been maintained

and enhanced since 1990, including periodic inspections and sediment cleanout with

appropriate off-site disposal.

The potential risk to human health associated with mirex in the MFLBC was assessed via

a formal Endangerment Assessment (EA) that was extensively reviewed and approved by U.S.

EPA and Ohio EPA in August 2004. The EA used health-protective assumptions in assessing

potential risks associated with exposure to the MFLBC (Environ, 2004). Considering the full

length of the MFLBC within the advisory area and beyond, the risks associated with reasonable

maximum exposures (RMEs) were assessed using U.S. EPA methodologies (Environ, 2004). This

assessment concluded that possible risks from direct contact exposure to mirex in MFLBC were

acceptable, for both adults and children (Environ, 2004). The calculated risks are based on

children, whereas they would be higher than those for adults. For example, non-cancer risks

due to ingestion are based on children alone, whereas cancer risks due to ingestion are based

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on combined lifetime exposures of children and adults (Environ, 2004). Portions of the EA

relevant to the contact advisory are summarized below.

The EA included assessment of risks to both residents and recreational visitors who may

contact the creek assuming that an advisory was not in place. Direct contact exposure routes

that were evaluated included ingestion of surface water, dermal contact with surface water,

ingestion of sediment, and dermal contact with sediment (Environ, 2004). Because mirex was

not detected in surface water, no mirex risk was calculated associated with ingestion or dermal

contact with surface water (Environ, 2004). The risk calculations, for ingestion and dermal

contact respectively, were prepared based upon U.S. EPA toxicity data, and a reasonable

maximum exposure concentration of 519 ug/kg of mirex in sediment was determined (Environ,

2004). Combining the risks from the dermal and ingestion pathways, a non-cancer hazard

quotient of 0.00354 and a cancer risk of 5.33x10-8 were calculated for mirex exposure (Environ,

2004). U.S. EPA identifies hazard quotients less than or equal to 1.0 and cancer risks not

exceeding a range of 1x10-4 to 1x10-6 as acceptable (U.S. EPA, 2001).

Extensive sampling of the sediment and surface water of the MFLBC has been

undertaken since the contact advisory for mirex was first issued in 1988 (Environ, 2004).

Controls have also been put in place at the Nease site to mitigate further releases to the MFLBC

(RNC, 1996). These activities, together with a formal EA, have been undertaken under the

direction of U.S. EPA and Ohio EPA. Using the risk assessment methodologies contained in the

Agency-approved EA, which assume that an advisory is not in place, direct contact risks within

the advisory area have been shown to be acceptable and well below U.S. EPA threshold criteria

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(Environ, 2004). As a result, it was considered that a contact advisory is no longer necessary for

the MFLBC (T. Wymyslo, Director’s Journal Entry, February 11, 2011).

Remaining Contact Advisories

In the past few decades, remediation efforts have aided the cleanup and remediation of

the four remaining sites, and ODH has been assessing the sites to determine at what level of

remediation the contact advisories can be rescinded. Remediation efforts often occur in phases,

as it is not uncommon for site investigation and cleanup to exceed tens of millions of dollars

(Bridges et al., 2006). The four sites that currently have contact advisories are the following:

Little Scioto River, Ottawa River, Dicks Creek, and Mahoning River (Table 1). All these sites are in

different stages of remediation, recovery, and re-evaluation, and eventually the goal for these

sites is to lift the contact advisories, as was done at the Black River and Middle Fork Little

Beaver Creek sites.

Table 1: Current contact advisories in the State of Ohio

Body of Water Area Under Advisory ContaminantDicks Creek River mile 4.1 (1 mile

downstream from North Branch Dicks Creek), Middletown to the Great Miami River (Butler County)

PCBs

Little Scioto River State Route 739, near Marion to Holland Road, near Marion (Marion County)

PAHs

Mahoning River NW Bridge Road (Warren) to Pennsylvania State Line (Mahoning and Trumbull Counties)

PAHs and PCBs

Ottawa River, Toledo Eastern Interstate 475 bridge to Lake Erie (Lucas County)

PCBs

PAHs=polycyclic aromatic hydrocarbonsPCBs=polychlorinated biphenyls

22

Source: http://www.epa.ohio.gov/dsw/fishadvisory/index.aspx#145214736-do-not-wade-or-

swim

Contaminants of Concern

As displayed in Table 1, the remaining contaminants of concern are PAHs and PCBs.

PAHs have been extensively studied in waterways. PAHs consist of hundreds of separate

chemicals and they have a variety of sources including tire particles, motor oil, vehicle exhaust,

asphalt, coal gasification, sealants, and other sources (Bridges et al., 2006). Various scientific

studies have documented detrimental impacts from PAHs on aquatic organisms. Studies in

Texas determined that loss of species and decreases in the number of streams occur when

PAHs are present (Metre et al., 2010). Crustaceans and fish metabolize PAH compounds

efficiently, whereas bivalve species, such as mussels, clams, and oysters, readily accumulate

PAHs (Garrett, 2004). However, some sensitive fish species, such as brown bull head catfish,

have been documented to display carcinogenic effects due to exposure to PAHs (Garrett, 2004).

Like most chemical interactions in the aquatic environment, interactions between aquatic

organisms and PAHs are complex. There are many factors to consider including sensitivity of

species, bioavailability of PAHs, and exposure to sunlight (Garrett, 2004). In regards to human

exposure to PAHs, the most significant effect of PAHs toxicity is cancer. There are documented

increased incidences of lung, skin, and bladder cancers associated with occupational exposure

to PAHs (USDHHS, 1996). Mammals absorb PAHs through inhalation, contact with skin, and

ingestion (USDHHS, 1996). PAHs have a low degree of acute toxicity to humans; therefore,

concerns for short term exposure are minimal (Gitipour et al., 2011).

23

PAHs are classified differently according to different agencies. The International Agency

for Research on Cancer (IARC) classifies two PAHs as probable human carcinogens and three as

possible human carcinogens (USDHHS, 1996). U.S. EPA classifies seven PAHs as probable human

carcinogens, and the State of California classifies 25 PAHs as carcinogenic PAHs (U.S. EPA, n.d.).

For environmental studies, benzo(a)pyrene is often used as an environmental indicator for

PAHs (U.S. EPA, n.d.).

The other chemical of concern is PCBs, and PCBs belong to a broad family of organic

chemicals. PCBs were manufactured in the United States from 1929 until 1979, when their

manufacture was banned (PCB TMDL, 2011). PCBs were used in capacitors and transformers,

but they had a wide variety of applications such as paints, sealants, and building materials. PCBs

are highly stable and persistent in the environment, and they tend to bioaccumulate in living

organisms (PCB TMDL, 2011). PCBs are classified by U.S. EPA as probable human carcinogens

and are listed as one of U.S. EPA’s most toxic chemicals (PCB TMDL, 2011). Fish consumption is

the major pathway of exposure for humans. PCBs do not break down in the environment easily,

and they can bioaccumulate in the fatty tissues of fish and mammals (Drouillard et al., 2006).

Also, people living near hazardous waste sites may be exposed to PCBs by consuming PCB

contaminated sport fish and game animals, breathing in PCBs in the air, or by drinking PCB

contaminated well water (PCBs, n.d.).

There have been many studies regarding the effects of PCBs on human health. Some of

these exposures have investigated people exposed in the workplace and others have examined

members of the general population (PCB TMDL, 2011). There are documented cancer and non-

cancer effects regarding exposure to PCBs in humans. U.S. EPA has done extensive literature

24

reviews on the carcinogenicity of PCBs in animals as part of their toxicity assessment (PCB

TMDL, 2011). The literature presents overwhelming conclusions that PCBs cause cancer in

animals. PCBs have been documented to cause non-cancer effects such as effects on the

immune system, reproductive system, nervous system, and endocrine system (PCB TMDL,

2011). In summary, PCBs have consistently shown that exposure in the human population can

lead to serious health effects (PCB TMDL, 2011).

Ongoing Remediation and Re-evaluation Case Study

Of the remaining sites with a contact advisory posted, the Little Scioto River site has

been extensively studied by various organizations and agencies. The Little Scioto River is

located in Marion County and the Little Scioto River site encompasses approximately 8.5 river

miles of the Little Scioto River, 1.5 miles of North Rockswale Ditch (NRD), and 2.2 miles of

Rockswale Ditch (HAS, 2012). The section of the Little Scioto River site begins at the State Route

309 bridge and extends to the confluence with the Scioto River at Green Camp, Ohio (HAS,

2012). The Little Scioto River is unrestricted and can be accessed from farm fields, bridges,

recreation areas, and wildlife areas (HAS, 2012).

Sediments are contaminated as a result of historic discharges to NRD and the Little

Scioto River from the former Baker Wood Preserving/Creosoting (BWC) site. The BWC site is

located at the northwest corner of Holland Road and Kenton Street (State Route 309) Marion,

Ohio (HAS, 2012). The BWC site is approximately ½ mile northwest of downtown Marion. The

former BWC site operated as a preserver of lumber products in Marion from approximately

1890 through the late 1960s (HAS, 2012). ODH, acting as Ohio EPA’s predecessor, first cited

25

BWC as a contributor of contamination to surface water on September 4, 1946 (HAS, 2012).

ODH indicated in a letter on December 4, 1946 that coal-tar creosote was being discharged

from the BWC site directly to the combined sewers that drain into NRD and the Little Scioto

River (HAS, 2012). BWC was ordered to install a waste treatment system, but the treatment

system was not put in place until 1953 (HAS, 2012). BWC ceased operations sometime in the

late 1960s (HAS, 2012).

Sediment samples were collected from the Little Scioto River and Scioto River by Ohio

EPA in 1988 (Ohio EPA, 2008a). These samples were collected to assess levels of contaminants

present in stream sediments around the area of study (Ohio EPA, 2008a). In October 1991, Ohio

EPA conducted an investigation of the BWC site to determine whether hazardous substances

existed on the property and if they were migrating off the site (Ohio EPA, 2008a). The

investigation revealed that polycyclic aromatic hydrocarbons (PAHs) were present on the

property, yet it was undetermined at the time whether PAHs were migrating off the property

(Ohio EPA, 2008a). From August 1992 to February 1993, Ohio EPA conducted a biological

community, fish tissue, biomarker, sediment, and surface water sampling survey of the Little

Scioto River (Ohio EPA, 2008a). Conclusions from this investigation determined severe

degradation was present in a four mile stretch of the Little Scioto River, a ½ mile portion of

NRD, Rockswale Ditch, and a smaller portion on Columbia Ditch (Ohio EPA, 2008a). On March

20, 1992, ODH issued a contact advisory against swimming, wading, and eating fish caught in a

four mile length of the Little Scioto River, west of the city of Marion from Holland Road south to

the State Route 739 bridge (HAS, 2012).

26

Ohio EPA Division of Surface Water issued a second investigation report in 1998, in

which sediment sampling results collected during the 1998 event for the Little Scioto River

confirmed the previous 1992 results (Ohio EPA, 2008a). The comparison of the 1992 and 1998

data results demonstrated no improvement in the sediment quality of the lower section of the

Little Scioto River (Ohio EPA, 2008a). In 1999, U.S. EPA initiated removal activities at BWC site

(Ohio EPA, 2008a). A total of 3,565 tons of creosote contaminated soil was excavated from the

site and disposed; an additional 3,000 tons of contaminated soil was excavated from areas east

and northeast of the direct site (Ohio EPA, 2008a). U.S. EPA installed five shallow groundwater

monitoring wells, and in September 2002, an additional four wells were installed deeper in the

limestone bedrock (Ohio EPA, 2008a). In 2003, an Expanded Site Inspection was completed and

it concluded that the direct BWC site was no longer posing as a threat to the Little Scioto River

(Ohio EPA, 2008a). The groundwater analysis from the monitoring wells demonstrated that the

creosote contaminants were present in very low concentrations in the shallow ground water at

the site (Ohio EPA, 2008a).

From 1999 to 2000, U.S. EPA focused its efforts on conducting a removal site

assessment for the Little Scioto River and NRD for the removal of creosote contaminants

suspected to be from the BWC site (Ohio EPA, 2008a). Their study indicated that four miles of

the Little Scioto River and ½ mile of NRD were contaminated with creosote (Ohio EPA, 2008a). A

project funded by the Coast Guard Inland Spill Fund initiated removal of contaminated

sediments, approximately 48,565 tons, from the BWC site, 2,800 linear feet of the NRD, and

2,900 linear feet of the Little Scioto River from June to December 2002 (Ohio EPA, 2008a). In

27

2006, a project funded by Ohio EPA and U.S. EPA removed an additional 36,115 tons (2,800

linear feet) of contaminated sediments from the Little Scioto River (Ohio EPA, 2008a).

In 2007, a Site Inspection (SI) for the Little Scioto River was finalized by Ohio EPA under

cooperative agreement with U.S. EPA Region V (Ohio EPA, 2008a). This work was performed to

determine if the remainder of the contaminated area could be added to the National Priorities

List (NPL) (Ohio EPA, 2008a). It was determined that un-remediated portions of the Little Scioto

River still pose a substantial threat to human health and the environment (U.S. EPA, 2009). The

Little Scioto River site was listed as final on the NPL in September 2009 (U.S. EPA, 2009).

In February 2012, U.S. EPA completed follow-up data collection at the site. The results of

these sampling events were compiled into a remedial investigation (RI) report (HAS, 2012). The

2012 results confirmed that PAHs from the former Baker Wood Creosoting site on Holland Road

are still present in the river (Meier et al., 2013). As part of the RI report, U.S. EPA returned to

the Baker Wood property to update information regarding soil and groundwater samples (HAS,

2012). Results from these samples show that further cleanup will be needed because

contaminated soil, groundwater, and source materials remain onsite (Meier et al., 2013). U.S.

EPA is currently working on a feasibility study that will be completed in the near future (HAS,

2012). The results from this study will present a recommended cleanup plan that will be

reviewed for public comment and review (HAS, 2012). In conclusion, U.S. EPA postulates that

previous cleanup attempts removed the immediate Challenges of damage to the environment

and public health, but additional information should be collected to determine the extent of

contamination and its’ effect on the river systems (HAS, 2012).

28

U.S. EPA is currently working to determine if there are human exposures to

contaminants at this site (HAS, 2012). Currently, the Little Scioto River site is considered to have

“insufficient data to determine human exposure control status” because U.S. EPA is still

reviewing validated data from the recent sampling events to complete a baseline risk

assessment (HAS, 2012). Currently, potentially unacceptable human exposures may result due

to recreational use near the site (HAS, 2012). ODNR recently created a bike trail, the Marion

Tallgrass Trail, adjacent to the contaminated portion of the river at RM 6.5, and the trail has

areas for people to dismount their bikes and wade into the river (HAS, 2012). The trail is under

construction, with approximately 2 miles of trail already completed (HAS, 2012). The trail will

eventually stretch 12 miles, from the trailhead site at 2093 Holland Road, just west of Marion,

to the Hardin County line (HAS, 2012).

Remediation Standards

Remediation consists of a series of objectives: development of remediation objectives,

characterization of the potential challenges of a pollutant to human health, identification of the

potential remediation alternatives that may be applied to the site, evaluation of identified

remediation alternatives, and establishing cleanup actions (Miller et al., 2007). For every

contaminated site where some action is necessary, a concentration must be defined above a

specified standard for the risks to be considered unacceptable (Miller et al., 2007). The nature

and magnitude of risks in regards to soil contamination are dependent on the site specific

conditions (Bridges et al., 2006).

29

Selecting a remediation standard is usually based on one or more criteria. The most

frequently used criteria include geochemical background levels, health or risk based standards,

site specific human or ecosystem risk assessments, levels achievable by best available

technologies, and soil extraction and leaching tests (Miller et al., 2007). The use of background

standards cleans sites up where contaminate concentrations are being returned to conditions

that existed prior to the release of the substance in the river system (Miller et al., 2007). Many

favor a conservative approach to remediate a site, in which all the contaminants released into

the river are extracted; however, this is impractical in many cases (Miller et al., 2007). It pushes

the limits of current technology, and it adds significantly to the time and costs of cleanup while

only providing minimal additional benefits for human health (Miller et al., 2007). Using health

or risk based methods represent a single value that may be applied from one site to another

(Miller et al., 2007). A site would be cleaned up to this value, but established standards often

vary between regulatory bodies (Miller et al., 2007). This method does not consider the unique

aspects of the site which may be important when assessing the effects of the contaminant on

human health (Miller et al., 2007). Site specific risk assessments looks at a site more specifically

to determine the extent to which a contaminant threatens human or ecological health (Miller

et al., 2007). This method often involves a toxicity assessment and an exposure assessment,

and it tends to be very cost effective (Miller et al., 2007). Soil extraction and leaching tests were

originally designed for waste disposed in landfills, and these tests assess the potential mobility

of contaminants (Miller et al., 2007). This analysis is very costly and may only apply to very

specific sites and parameters (Miller et al., 2007). Establishing a standard based on contaminant

levels that are achievable by using the best technologies is rarely done due to its limited

30

applicability (Miller et al., 2007). Establishing an effective clean up level often uses a blend of

these techniques and it is established by the goal of the remediation (Miller et al., 2007).

The goal of completing a risk assessment on a contaminated site should be to inform

decision makers about the pathways of exposure, identify human and animal populations at

risk, and determine the risks with implementing different engineering practices to remedy the

contamination (Bridges et al., 2006). One study suggests that the use of adaptive management

would be the best alternative to calculate formally risk and remediate at a site. This author

suggests that adaptive management emphasizes the role of performance monitoring and uses

the results of monitoring to make adjustments in management and remediation actions over

time (Bridges et al., 2006). This method helps account for some of the uncertainty of a

traditional risk assessment process where data is collected and analyzed, and a site is

remediated from that process (Bridges et al., 2006). Adaptive management practices allow for

more flexibility in remediation and may be a good tool for sites that take decades to recover

(Bridges et al., 2006).

When examining soil and groundwater contamination at the Tehran Oil Refinery site in

Iran, researchers evaluated a cleanup level based on U.S. EPA guidelines for PAHs (Gitipour et

al., 2011). The cleanup level was established from accidental ingestion of contaminated soils.

When completing the site assessment, areas chosen for remediation were selected based on

the soil analysis results and whether the area had a PAHs concentration higher than the cleanup

standards (Gitipour et al., 2011). In accordance to the U.S. EPA guidelines, the cleanup level was

determined by an equation that included target cancer risk level, weight of the average person,

31

Ohio Department

of Health (decision maker)

Ohio EPAU.S. EPA

Funding

ASTDR

DSW

DERR

Consultants

WQ/Biological info

Remediation info

Enforcement

Consent Order for cleanup

Superfund

NPL

Funding

average time, exposure frequency, exposure duration, contact rate, and cancer slope factor

(U.S. EPA, 1998). Human cancer risks related to PAHs tend to be evaluated internationally by

the use of benzo(a)pyrene relative potencies because the carcinogenicity of benzo(a)pyrene is

well understood (Crane, 2013). Even though there are consistent procedures for calculating

benzo(a)pyrene equivalents, public health and environmental health agencies from different

jurisdictions develop their own guidelines based on different exposure scenarios (Crane, 2013).

Agency/Organization Description

ODH, through the Bureau of Environmental Health, has the final decision making

authority for removing contact advisories. However, many other agencies and organizations are

involved with the whole process. Below is a very basic schematic describing the roles of the

various organizations and how they are relevant to ODH’s assessment of the contact advisory

removal process.

32

Figure 1. Schematic depicting the relationship between several state and federal agencies.

Contact advisory removals involve a coordinated response from multiple agencies and

organizations. ODH Bureau of Environmental Health is the final decision maker, and ODH works

closely with ASTDR, U.S. EPA, and Ohio EPA to obtain information and funding necessary to

complete assessments and evaluate the contact advisory. The mission of the section at ODH

that completes the assessments and evaluations for the contact advisories is to serve the public

through responsive public health actions and prevent harmful exposures.

Ohio EPA provides technical information to ODH including water quality information,

biological information, and remediation information. This information could include sampling,

results and analysis, and conclusions and recommendations. Ohio EPA may have consultants

that also acquire information related to the contact advisory. U.S. EPA provides technical

information as well as funding and enforcement to support the remediation efforts required to

clean up contaminated sites. The areas that currently have contact advisories posted are either

involved in the Superfund program, in enforcement, or both.

Research/Evaluation Design

Non-experimental designs are best suited for answering evaluation questions for

formative and process evaluations (NECI et al., 2009). This evaluation was designed to be a

formative evaluation to aid in the development and design of a program. Non-experimental

designs do not typically include comparison groups. Instead, this design focuses on measuring

various elements of a logic model and describing these elements, rather than correlating them

to other elements in the logic model. This type of design can yield qualitative or quantitative

data, and both types of data were used for this evaluation.

33

This formative evaluation involves a mixed methods approach to collect information for

the evaluation. The sources of existing information include existing data and reports, peer-

reviewed literature on impacts of contamination and remediation efforts, risk assessment

documents, and agency website and publications. New information sources include in-depth

interviews and a broader survey on selected staff pertinent to this program. The results from

this evaluation will be an asset to ODH to consistently review criteria to make a decision

whether or not to remove a contact advisory after a contaminated site has been cleaned up and

remediated.

The purpose for this evaluation is to suggest recommendations to ODH to aid in the

development of a formal program. This will help ODH identify the items throughout the contact

advisory process that should be considered when making a final decision regarding the contact

advisory. The principle audience for the project results will be an internal audience composed

of Ohio EPA and ODH staff.

The following evaluation questions and designs were studied:

1. What elements of information are the most important for effective review and

recommendation of removal of a contact advisory? (program objectives question)

Method to Answer Question: A semi-structured interview with ODH staff was completed to aid

ranking the utility of various elements of information needed to make a determination. Data

collection was qualitative and the focus of the interview was to identify and interpret common

and recurrent themes. The purpose of the interview was to fully understand the decision

makers’ experiences and impressions of the process. A broader survey was administered to the

34

additional staff involved with aspects of decision making in this process for other Region V

states.

Threats to Validity: Interviews produce results that may be hard to compare against other

types of data or additional interviews that may be completed in the future. Interviews can also

produce bias responses based on the interviewer’s technique. Another issue is that the

interviewee may have difficultly recalling information or the interviewee may recall inaccurate

information. This is a valid issue for this evaluation since the timeframe for reviewing,

remediating, evaluating, and removing contact advisories may take decades. In addition, there

are very few people involved with this process, so the sample size for the broader survey is

small. Self-selection bias is a concern because the survey participants have a choice as to

whether they would like to participate.

Solutions for Future Studies: The best solution to address these biases would be to increase the

number of people included in the survey and the interview process. Once the program is

developed, more people may be involved with various aspects of the program. A follow up

survey could be beneficial to capture more data to improve the program in the future.

2. How does variation in the availability, quality, and analysis of data influence the ODH

evaluation process for removal of past advisories? (program organization question)

Method to Answer Question: The two case studies have been compared to examine what

factors were used to remove contact advisories in the past. The overall processes for the

completed case studies (Middle Fork Little Beaver Creek and the Black River) have been

compared against each other in a case study comparison table. Specifically, the sources of data

collected, sampling methods, risk assessment determinations, timelines for remediation and re-

35

evaluation, and time/resource constraints for each case study were compared against each

other. A document objectives table has been prepared to compare the two case studies. The

purpose of this exercise was to provide a comprehensive look at the elements of the entire

program and to provide a full depiction of the program operation.

Threats to Validity: Case studies are very time consuming and they have difficulty capturing a

broader view of the elements fundamental to a program. These particular case studies also

dealt solely with existing data; no new data was generated. The existing data in itself may have

separate biases, but the evaluator has no control on these biases.

Solutions for Future Studies: As more contact advisories are removed and more cases are

complete, future case studies can focus on one or two elements in more detail, rather than try

to capture the whole picture through a broad view. This practice will aid in analyzing specific

processes to adjust and improve them. This practice will also reduce the amount of time

needed to analyze each case study.

3. What is the most effective way for Ohio EPA and other partners to provide sufficient

environmental data related to sediments for remediation measurement and evaluation

purposes? (program effectiveness question)

Method to Answer Question: ODH has expressed interest in dermal exposure to sediments.

This was determined through a study plan meeting to design the evaluation. Sediment data was

collected and analyzed in the past for all the sites that had or currently have contact advisories

in place. The data used was from the Black River case study and the Little Scioto River case

study since these cases concern the same contaminant (PAHs). The last data set before the re-

36

evaluation was used to determine if similar metrics were evaluated to lift the advisory. The

purpose of the data analysis was to yield information useful for accountability purposes.

Threats to Validity: The largest threat of validity is the assumption that the quality of data is

ensured. The quality of data collected is not under the control of the evaluator since it was

collected in the past. The sizes of samples, methods, and sampling locations are not in the

evaluator’s control. However, this threat is also something the evaluator would like to know for

future recommendations. There may be a threat where the variable was measured differently

between the two groups.

Solutions for Future Studies: Gathering a larger sample size will enable the evaluator to control

instrumentation bias through the developing subgroups of data. In addition, a larger sample

may enable the evaluator to draw a random sample from groups of data to further analyze the

data.

A logic model was developed to capture the relationship between the program’s

activities and the desired result (NECI e al., 2009). A logic model is a diagram and text that has

seven basic elements: resources/inputs, activities, outputs, target decision makers, short term

outcomes, intermediate term outcomes, and long term outcomes (NECI e al., 2009). Resources

and inputs include what is needed to run the program (NECI e al., 2009). Activities include what

the program does and outputs focus more specifically on what products and services the

program produces (NECI e al., 2009). The target decision makers include groups or individuals

that the program aims to affect (NECI e al., 2009). The three tiers of outcomes have different

meanings: short term outcomes depict changes in decision makers’ knowledge, attitudes, or

skills, intermediate term outcomes depict changes in target decision makers’ behavior,

37

practices, or decisions, and long term outcomes depict changes in public health and/or the

environment as a result of the program (NECI e al., 2009). Also included in this logic model are

external influences beyond the program’s control that can affect how the program operates.

This logic model is essential to capture the clear picture of the current contact advisory

removal program. The logic model was used to determine which aspects of the program to

evaluate and which questions would be most useful to ask in order to improve the program.

The logic model also helps describe the logical relationship among all the program elements.

Information from the logic model was used to make recommendations to streamline process

for efficiency and consistency through the development of a flowchart tool.

Methods

Evaluation Questions

The methods included asking specific evaluation questions aligned with the specific aims for

the project.

1. What elements of information are the most important for effective review and

recommendation of removal of a contact advisory? (program objectives question)

2. How does variation in the availability, quality, and analysis of data influence the ODH

evaluation process for removal of past advisories? (program organization question)

38

3. What is the most effective way for Ohio EPA and other partners to provide sufficient

environmental data related to sediments for remediation measurement and evaluation

purposes? (program effectiveness question)

Analysis of Case Studies

The two case studies were analyzed for the literature review portion of the project. In

addition, the methods involved review of all reports and papers available for each case. This

includes both published and internal literature. The substantive findings as well as the

methodological contributions of each paper were recorded. During the literature review

process, key elements were identified and recorded to capture the whole process of

establishing a no-contact advisory to removing a no-contact advisory. The purpose of this

portion of the project was to look at these key elements of the entire process. The dependent

variables are aspects of this case comparison portion that are subject to performance

measurement; these are defined as “Items” in the case comparison table. The measured

aspects that caused an observed change are recorded in each column for the separate cases

and these have been coded as qualitative data. The purpose of creating this table was to make

comparisons between the two completed cases and to identify any patterns that require

further investigation.

Interviews

Two separate interviews were conducted with ODH staff. The first interview was

conducted April 15, 2015, and this interview had specific questions to be answered, but was

structured in a more informal manner. A semi-structured interview with ODH staff was

39

completed July 8, 2015. The interview questions for this interview were categorized to capture

information for the whole contact advisory process. The variables of interest were to capture

the experiences and impressions of the current process from the perspective of the ODH staff

decision maker. Hard copies of the questions were brought to both interviews and answers to

the questions were recorded via note taking. Once the two interviews were complete, the data

was processed and recorded immediately via typed detailed notes. These notes can be found in

the appendix of this report.

Upon initial review of the data, the data was reviewed for themes and patterns that

were exhibited. For the qualitative data to be analyzable, it was grouped into meaningful

categories based on the themes of the questions. Once the questions were categorized, a

content analysis was conducted for the answers of each question. During the content analysis,

the data was coded for certain content pieces, patterns in the answers were identified, and

meanings to the patterns were determined. This type of coding was done by going through all

the text and labeling works and phrases that related to the questions of interest. After

identifying content patterns, the data was compressed into a table display that aids in

identifying patterns and relationships within the groups of data.

Survey

A two question survey was prepared and emailed to correspondents in Minnesota,

Illinois, Indiana, Michigan, and Wisconsin. These states are the other Region V states that are

under the same federal jurisdiction as Ohio. These states also have similar hydrological features

in streams that are similar to the streams in Ohio, and therefore may be evaluated for similar

40

characteristics. The survey targeted the decision maker equivalent for the other states. The

survey consisted of a series of yes or no questions as well as an open ended subset of questions

if they applied to the state. The respondents were given two weeks to respond to the survey.

The purpose of the survey was to document common themes in establishing and removing

contact advisories. The data was compressed into a table display to identify patterns between

the states.

Sediment Data Analysis

Data from sediment samples was collected through past reports for the following cases:

Little Scioto River and the Black River. The last data set before the re-evaluation was used to

determine if similar metrics were evaluated to support removing the contact advisory. The data

set from the Little Scioto River was collected in 2007 and the data set from the Black River was

collected in 2004. The data was collected from the sites at each study area that historically had

the most egregious contamination as defined by Ohio EPA. Both sites had been remediated at

these locations and the data sets are post-remediation data. The data sets all concern the same

contaminant, PAHs, and the data is paired by parameter, specifically the chemical compound

measured. Both data sets included collecting sediment samples via surficial samples; these

samples are collected from 0-4 inches from the surface of the stream bed. The raw data is

attached to the appendix of this report. Our measurement variable is the sediment

concentration, measured in ug/kg. Our nominal values are the sites, Little Scioto River and Black

River. The purpose was to compare the two different measurements that have been applied to

the same subjects, chemical compounds of PAHs. This evaluation is concerned with the

differences in the two sets of measurements.

41

Ethics

Verbal consent was received from the ODH interviewee to conduct the interviews and

create this document. This document created is intended for internal and interagency

distribution and will not be published in external publications or media. Advice regarding this

project’s need for review was obtained by Dr. Elizabeth Klein. Upon her review of the project,

she believed that the project proposal did not need to undergo review by the OSU Institutional

Review Board.

Results

Case Study

The two case studies have been compared to examine what factors were used to

remove contact advisories in the past. These cases are discussed in detail in the literature

review section of the report. The overall processes for the completed case studies (Middle Fork

Little Beaver Creek and the Black River) have been compared against each other in the case

study comparison table below. Similar themes have been identified, but there are some key

differences when comparing how the no-contact advisories were removed. The most significant

difference between the two cases is that remediation of the contaminants occurred in one

case, Black River, but not the other case, Middle Fork Little Beaver Creek. This difference caused

a completely different rationale when reviewing information to re-evaluate to remove the no-

contact advisory. The end result of both cases was to remove the no-contact advisory through a

Director’s Journal entry.

Table 2. Case comparison table for Black River and Middle Fork Little Beaver Creek.

42

Item Black River Middle Fork Little Beaver CreekContact Advisory Issued? Yes

1983 Yes

1988Under what conditions was the advisory placed?

Egregious contamination through visual observation inspection.

Visual observation inspection and unknown health effects of contaminant.

Contaminant of concern PAHs MirexSource of contamination identified?

YesCoking operations at USX Steel Corporation

YesReleases from Nease Chemical

Has the source of contamination be rectified?

Yes1983 Consent Order to cease coking operations

YesControls put in place at site to prevent further releases of mirex

Media of contamination identified?

Yessediments, fish

YesSediments, flood plain soils, surface water, fish

Ecological impacts of contamination identified?

YesTumor prevalence in bullhead

No

Samples collected on media of concern?

YesSediments and fish (tumor identification)

YesSediments, flood plain soils, surface water (no detect), fish

How many sampling events after the contact advisory was posted but before re-evaluation?

81983, 1984, 1988, 1992, 1997, 1998, 2001

41990, 1997, 1999, 2001

Control sites for contaminant of concern?

YesOhio reference lakes

No

Did remediation for contamination occur?

YesDredging activities to remove sediments

No

Toxicity testing post-remediation?

Yes N/A

Remediation occurred for the whole advisory area?

No~RMs 2.5-3.7 along the steel mill property

N/A

How many sampling events occurred before remediation?

3 N/A

How many sampling events occurred after remediation?

5 N/A

Visual observation inspection occurred as part of ODH’s re-evaluation?

Yes No

Report prepared for re-evaluation?

Yes2004 John Ion Report

Yes2004 Endangerment Assessment

Who prepared it? Master’s student for ODH Nease Chemical’s consultants

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for Ohio EPA and U.S. EPACause for contact advisory re-evaluation

Request from Ohio EPA and Black River Remedial Action Plan group

Pressure from Ohio EPA and U.S. EPA due to a new toxicity standard for mirex

Was the contact advisory formally rescinded by a Director’s Journal entry?

Yes Yes

Items considered for re-evaluation

Historical data on PAH levels in sediments

Historical data on hepatic tumor presence in bullhead

Quantitative risk assessment: adjusted for potential dermal exposure

Visual observation inspection

New toxicity information for chemical of concern for sediment exposure

Outside influences for decision? Minimal Ohio EPA and Black

River RAP

High Political pressure from

other agencies

Interview

Below is table display of the categories, questions, and content patterns identified via

the two interviews conducted with the ODH decision maker. The data has been arranged to

assist in identifying systematic patterns and interrelationships across content. The goal of this

aspect of the evaluation was to determine what ODH considered most important when

evaluating information to suggest removal of a contact advisory. The results of the data analysis

are described in the table below.

Table 3. Table display of qualitative data from two interviews of Ohio Department of Health decision maker.

Categories for Questions

Questions Content analysis

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Establishing No-Contact Advisory

Have both contact advisories that have been removed been memorialized through a journalized action at ODH?

Yes

How was a site identified as not being safe for human contact?

Ohio EPA Water Quality Assessments

How does ODH determine the length of stream covered by the no-contact advisory?

Ohio EPA Water Quality Assessments

Site Cleanup How involved is ODH in the site assessment and remediation process conducted by OEPA, U.S. EPA, and others?

Health Consultations to determine contaminants of concern and pathways of exposure

Support other agencies when needed

Re-evaluation (holistic) What documents does ODH use to re-evaluate sites to determine if exposure is safe for contact?

Visual observation inspection Pre- and post-remediation

data

What criteria are used to assess if the contact advisory can be lifted?

Observation of no egregious contamination

Not based on science

What elements of information are most important for effective review and recommendation of removal of a contact advisory?

Proof of ceasing source of discharge

Proof of remediation activity Pre- and post-remediation

sampling activity Visual observation inspection

What pieces of information are most important when making a decision to re-evaluate and potentially removal a contact advisory?

Source cleanup reports Visual observation inspection

notes

How does ODH determine when to re-evaluate a contact advisory?

Requested by Ohio EPA

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From your perspective, what challenges or concerns do you have with the current process?

Each site is unique Tough to standardize a process

From your perspective, what can be done to enhance this process in the future?

Same contaminant of concern=same process of re-evaluation

Re-evaluation (data collection)

How does variation in the availability, quality, and analysis of data influence your decision to remove/keep a contact advisory in place?

Same metrics that established for the contact advisory should be used when evaluating to remove it

Metric= visual observation inspection

What is ODH looking for when conducting a visual observation inspection?

Potential for dermal exposure to sediments

Smells

Is there a formal inspection form used for the visual observation inspection?

No

When completing a visual observation inspection, does ODH cover the whole stretch of the river covered by the contact advisory?

Yes

Are background (control) sites considered when evaluating surface water or soil sediment samples?

Not usually

If background sites are considered, how are they established?

Not sure Ohio EPA established these in

the past

What specific pieces of information are most important for ODH to make a decision?

Y/N is site is grossly contaminated

Determined via visual inspection

Have the same pieces of information been used

Yes

46

when removing a previous contact advisory?

Site specific Does ODH have a copy of the Endangerment Assessment (2004 Environ) that was used for the MFLBC contact advisory removal?

Yes Political pressure and changes

in acceptable toxicity levels caused removal of advisory

What happened with the Ottawa River contact advisory?

Miscommunication of what stretch of river the contact advisory covers

I-475 crosses the river twice Contact advisory was originally

posted by mistake for part of the river

Survey

A survey was created and sent to the Region V states with a two week request for a

response. Below summarizes the results and findings of the survey.

Table 4. Survey Response to Questions from Region V states.

Question 1 Has your state ever had any contact advisories in place for streams?

Answers NO: 3 YES: 2Question 2 Has your state ever removed and/or rescinded any contact

advisories?

47

Answers NO: 3 YES: 2

On the basis of the results of the survey, only two states have placed a contact advisory on a

stream: Michigan and Wisconsin.

Michigan has had one contact advisory and it was established after a massive million

gallon crude oil spill to Talmadge Creek and the Kalamazoo River in 2010. The contact advisory

was placed because there was an acute physical contact hazard and the oil spilled was emitting

levels of volatile organic compounds that presented an inhalation risk. There were also physical

hazards to recreational users as cleanup activities on the spill occurred. The State of Michigan

has also rescinded this contact advisory. It was rescinded when all levels of air contaminants

from the volatile organic compounds had fallen below health based screening values and all

physical hazards from the cleanup activity were mitigated. This spill was not under a court order

for cleanup and it was not considered a Superfund site.

Wisconsin has placed recommendations to not wade/swim or play in streams

contaminated with PCBs and PAHs above U.S. EPA recommended values. They do not

necessarily call these contact advisories and they do not track these recommendations.

Wisconsin does not know exactly how many there are or how many there have been, but at

least two sites were identified in the survey. These two sites were considered to be Superfund

sites. For the re-evaluation steps after the remediation phase, Wisconsin will review any new

data to determine if the stream is safe for contact. However, these re-evaluations are not

formally tracked, so the respondent did not know how many have been removed or rescinded.

Sediment Data Analysis

48

In the table below are the results of the data analysis. RM 6.5 is the data set from the

Little Scioto River and RM 3.43 is the data set from the Black River. The two data sets have been

compared against each other and against individual relative potency factors for the individual

PAHs. The relative potency values are estimates of the potency compared to benzo(a)pyrene,

which has a base value of 1.0.

Table 5. Comparison of sediment data for re-evaluation of contact advisory. Data sets from

the Little Scioto River and Black River case studies.

Parameter RM 6.5 LSR (ug/kg)

RM 3.43 BR(ug/kg)

Relative Potency a,b

Total PAHs 239 17000 n/aAnthracene 250 900 0.01 b

Benz(a)anthracene 250 1520 0.1 a

Benzo(a)pyrene 250 1710 1 a, b

Chrysene 77 1750 0.001 a

Dibenz(a,h)anthracene 250 900 1 aFluoranthene 250 3480 0.001 b

Fluorene 250 900 0.001 b

Naphthalene 81 1260 0.001 b

Phenanthrene 250 1380 n/aPyrene 250 2730 0.001 b

a: Estimate of potency relative to benzo(a)pyrene based on mouse carcinogenesis (U.S. EPA IRIS)

b: Toxic equivalency factor relative to benzo(a)pyrene, taken from Nisbit and Lagoy (1992).

Discussion and Recommendations

The two case studies were analyzed to determine how the variation in the availability,

quality, and analysis of data influences the ODH process for re-evaluating and removing contact

advisories. When the contact advisories were established, they followed a similar fact pattern.

The contact advisories were established after documenting egregious contamination through

visual observation inspections. Even though the contaminants of concern were different, the

49

source of the contamination was controlled in both cases and similar environmental media

were impacted. Numerous sampling events occurred in both cases. When it comes to a

remediation action taking place, the two cases differ drastically.

The Black River case study had a remediation action which involved removing all the

contaminated sediments in the delineated contact advisory stream section. After the

remediation occurred, sampling was completed to create a pre- and post-remediation data set

for the site. Therefore, ODH had a lot of available information to determine if the stream was

safe again for human contact. All of this information was used to support the removal of the

contact advisory for the Black River.

In the Middle Fork Little Beaver Creek (MFLBC) case study, remediation of contaminated

sediments did not occur. The company that caused the contamination argued that there was

new toxicity data available that demonstrated that the existing levels of the contaminant of

concern were truly safe for human contact. Consultants on behalf of the company were hired

to prove this through the development of a risk assessment. ODH received a lot of pressure

from other agencies and the company to reconsider the contact advisory and remove it from

the stream. Because of outside pressure, the contact advisory was removed despite the fact

that no remediation occurred. Even though the same end result occurred in both case studies,

outside influences altered how ODH processed the re-evaluation of the MFLBC contact advisory

and this process was vastly different than the process used in the Black River contact advisory.

o Recommendation: Outside influences on the process are items that ODH cannot

control and this dynamic is captured in the logic model. These situations will

50

continue to exist and cannot be controlled from an evaluation perspective.

However, these types of situations are not the norm, so a process protocol can

be developed for future contact advisories that will be undergoing the re-

evaluation process. One suggestion is to create a process protocol based on the

contaminant of concern since different factors may need to be considered for

sampling, remediation, and risk assessment. The current contact advisories in

place have two separate contaminants of concern: PAHs and PCBs. A protocol for

each contaminant could be developed and used once these sites undergo

remediation and become candidates for re-evaluation. This protocol could be

captured in a process flowchart.

The purpose of the interview portion of the project was to determine what elements of

information are the most important for effective review and recommendation of removal of a

contact advisory. Information regarding what the ODH decision maker considers the most

important when evaluating information to suggest removal of a contact advisory was captured

thoroughly in the interview process. As displayed in the results section of this report, common

content themes were identified by the decision maker. This discussion portion will be

subdivided by the categories of questions as displayed in the results table earlier.

Establishing the Contact Advisory: ODH relies on Ohio EPA to identify a site as being not

safe for human contact, but the contact advisory program is housed at ODH and

therefore they are responsible for establishing the contact advisory. Ohio EPA Water

Quality Reports are relied on heavily to set the stream length of the contact advisory. All

51

contact advisories that have been removed have been memorialized and rescinded via a

journalized action at ODH.

o Recommendations: This process is very easy to follow and standardized;

therefore, no recommendations are suggested.

Site Clean up: ODH is involved with the site cleanup if requested by other agencies, such

as Ohio EPA or U.S. EPA. Agencies have requested assistance regarding contaminants of

concern and pathways of exposures at sites. ODH conducts these studies and

memorializes the findings in a Health Consultation report. The purpose of ODH is to

evaluate the data from a public health perspective. If the data supports egregious

contamination, a recommendation from ODH and Ohio EPA will be sent to U.S. EPA for

priority cleanup. If the data supports contamination, but it is not super egregious, a

Superfund cleanup will be recommended.

o Recommendation: How ODH defines egregious contamination is not well

defined. A reference guide to categorize differing levels of contamination could

be developed to make this process more clear.

Re-evaluation (holistic): Even though there have been no formal tools developed to re-

evaluate contact advisories, the contact advisories that have been removed have been

done in a consistent way. The contact advisories have been established based on ODH’s

visual inspection of a contaminated site; this is based purely on observation and not

based on scientific data. Therefore, when re-evaluating the contact advisory, ODH will

conduct a visual observation inspection to support removal of the contact advisory, and

this is the primary basis to support removal of the contact advisory. There is no formal

52

inspection form for this process. Analysis of secondary data, if available, has been used

to support the removal of the contact advisory. The secondary data ODH reviews

included pre- and post-remediation data pertaining to sediments, and source clean up

reports. In addition, ODH wants information on the following to support the removal of

a contact advisory: proof of ceasing the source of discharge that caused the pollution,

proof of some sort of remediation activity to remove the pollution, pre- and post-

remediation sampling data to support the removal of the pollutant, and confirming the

removal of egregious contamination by conducting a visual observation inspection.

Because each site is unique, it is difficult to standardize a procedure to re-evaluate

streams to support removal of a contact advisory. However, one way to standardize a

process would be to create a process for each contaminant of concern. For example,

ODH plans to use the process in the Black River contact advisory for supporting the

removal of the Little Scioto River contact advisory since these sites have the same

contaminant of concern.

o Recommendation: ODH relies heavily of the visual observation inspection to

establish and remove a contact advisory. The person who has been establishing

the contact advisories and then recommending removing them has relied on his

or her memory to support the removal of the contact advisory. The development

of an inspection form would aid in standardizing how the visual observation

inspections are conducted and what parameters are evaluated during the

inspections. The idea is that this form could be used when the contact advisory is

established (pre-remediation) and when the contact advisory is being re-

53

evaluated for removal (post-remediation). ODH has expressed interest in

standardizing the method for removal of a contact advisory by pollutant of

concern. The remaining contact advisories have two pollutants of concern: PAHs

and PCBs. Two checklist tools could be developed to standardize the information

needed to re-evaluate the contact advisories for each of these contaminants.

Re-evaluation (data collection): Much of the data collection is done outside of ODH. This

data is collected by a variety of agencies and groups for differing reasons. However, as

discussed earlier, ODH primarily relies on the visual observation inspection to establish

and remove the contact advisory. From their perspective, this is the basis that the

contact advisory re-evaluation should be based on.

o Recommendation: As suggested earlier, a visual observation inspection form will

aid in standardizing the procedure used to conduct a visual observation

inspection. Lines of communication could be improved between ODH in regards

to how the secondary data is collected. ODH will review the secondary data

sources to support its recommendation to remove a contact advisory, yet some

information on how the data was collected is unclear to ODH. One way to

correct this is to keep ODH involved when the sampling plans are created;

therefore, ODH will be knowledgeable on how the sampling sites were

established and why these specific sites were selected.

Site specific: This section was to identify scenarios that were different from how contact

advisories were normally evaluated and removed in the past. The contact advisory for

the Middle Fork Little Beaver Creek was rescinded without any remediation action. ODH

54

claims that there was a lot of political pressure on behalf of the company that caused

the pollution to remove the contact advisory. Consultants were hired on behalf of the

company to state that the toxicity levels of the pollutant of concern were below

dangerous thresholds and therefore the contact advisory should not be in place. This is

further discussed in the literature review. Part of the Ottawa River contact advisory was

removed because it was posted in one area by mistake when I-475 was built. This was a

miscommunication error between Ohio EPA and ODH and is considered an isolated

incident.

o Recommendation: Even if the process of re-evaluating the contact advisory can

be more standardized and consistent, there will always be factors outside of

ODH’s control that will influence the removal of contact advisories. From an

evaluation perspective, there are no recommendations for this aspect of the

process.

The results of the survey were not surprising because the ODH decision maker that was

interviewed stated that he didn’t believe that the other Region V states had established or

rescinded contact advisories. The majority of the states that replied to survey had not

established or rescinded contact advisories.

The State of Michigan established a contact advisory based on unsafe levels of

contaminants present in the river during and immediately after the spill. When rescinding the

contact advisory, the State of Michigan used health based standards to determine if the contact

advisory should be rescinded. This was only considered after a remediation activity occurred.

Therefore, they used the same metric for establishing and removing the contact advisory. This

55

situation from the State of Michigan differs slightly from the current contact advisories in place

for the State of Ohio. Michigan’s situation was a short term pollution event and cleanup

occurred immediately. The examples in Ohio include long term pollution events where cleanup

occurs through some sort of long term funding plan, such as Superfund. Therefore, it may be

difficult to fairly compare the contact advisories in Ohio against the one in Michigan.

The State of Wisconsin has no formal mechanism to track contact advisories, so it is

difficult to compare their cases against the cases in Ohio. However, they have used consistent

standards to establish their contact advisories, U.S EPA values. They also use these same

standards to revise their recommendations post-remediation.

o Recommendation: The piece of information that is pertinent to this evaluation is

that both states who also have contact advisories used the same measurement

metric to remove the contact advisory that was used to establish the contact

advisory. Even though this metric is not a visual observation inspection, Ohio can use

this information to justify the need to remove a contact advisory based on how it

was established. The Ohio contact advisories were established by ODH due to

egregious contamination observed during a visual observational inspection.

Therefore, the primary metric used to justify the removal of a contact advisory

should be a follow up visual observational inspection.

The sediment data collected was from different cases, and upon a side by side

comparison, the streams were remediated a differing concentrations of PAHs. When reviewing

relative potency values, the PAHs that have been considered the most toxic relative to the

56

other PAHs were not removed at a lower concentration. The concentrations of PAHs at both

sites vary post remediation.

Some limitations of this analysis include the sample size of 11 pairs of data. The

evaluation used historical data and the sample size would not under control of the evaluation.

The tests requested to collect and analyze sediment samples tend to be expensive, so the

agencies responsible for collecting and analyzing these samples only collected what was

absolutely needed. Also, different laboratories were contracted and used for these data sets

and the laboratories may have slightly different methods and reporting limits for data analysis.

Limited information was available regarding the laboratory procedures for data analysis.

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Bridges, T., Apitz, S., Evison, L., Keckler, K., Logan, M., Nadeau, S., & Wenning, R. (2006). Risk-based decision making to manage contaminated sediments. Integr Environ Assess Manag Integrated Environmental Assessment and Management, 51-58.

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Health Assessment Section (HAS) (2012). Public Health Assessment for Little Scioto River Site, Marion County, Ohio. Prepared by the Ohio Department of Health HAS under a cooperative agreement with ATSDR. Retrieved June 5, 2015 from: https://www.odh.ohio.gov/odhprograms/eh/hlth_as/pha2.aspx

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Appendices:

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Appendix 1 - Interviews Q/A sheets

1. Have both contact advisories that have been removed been memorialized through a journalized action at ODH? Yes

2. What documents does ODH use to re-evaluate sites to determine if exposure is safe for contact? With the Black River Risk Assessment, ODH went on a visual observation inspection with Ohio EPA NEDO on a boat to assess potential exposure routes. Any technical documents that are relevant. Chemical information, past and present reports, environmental data, risk assessment info, etc. Pre- and post-remediation data is useful to determine the baseline and current conditions.

3. What criteria are used to assess if the contact advisory can be lifted?The contact advisories were established based on egregious contamination observations and not science.Black River: the ultimate determining factor to lift the contact advisory was a visual observation inspection completed by ODH staff with OEPA staff in a boat. Sediments were evaluated using a pole to penetrate the sediments to see if any chemicals were released. Data from previous reports was used as a secondary source.

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MFLBC: consultants hired by Nease Chemical completed a lot of the technical data collecting and reporting. Ohio EPA and U.S. EPA approved the data but there was a lot of pressure from Ohio EPA and U.S. EPA to remove the advisory. ASTDR was contacted and ASTDR agreed that if U.S. EPA has approved and recommended removal then ODH should support that decision. Political pressure caused the removal of the advisory. Sawyer Park Marion: a visual inspection post-remediation and good pre-post sampling data supported the removal of the contact advisory

4. Does ODH have a copy of the Endangerment Assessment (2004 Environ) that was used for the MFLBC contact advisory removal? Probably, they are looking for it. Consultants were hired by Nease Chemical (Environ, Rudgers Organics, Golder Associates) to perform toxicity testing. The consultants argued that the mirex concentrations were acceptable in the current situation. No remediation had occurred to remove the contaminated media. The toxicity levels for mirex had changed and U.S. EPA supported this change. The change in acceptable toxicity suggested that the contact advisory was no longer needed. ODH contacted ASDTR as to what to do and they supported U.S. EPA’s decision to accept the new toxicity standard. No remediation had occurred, no visual inspection occurred, due to political pressure and the change in toxicity for mirex exposure, the advisory was lifted.

5. What happened with the Ottawa River contact advisory?The advisory was in place before I-475 was built (1990s?) When I-475 was built, there was a mistake as to how the advisory was posted. I-475 crossed the stream twice and the upstream part where the advisory was posted was posted by mistake. This was accidently communicated in a fish advisory handout and continued ever since. The University of Toledo called ODH asking what had to be done to remove the advisory and when they became involved, ODH went out there to do an investigation. That is when the mistake was identified. The advisory was lifted on the area that never needed the contact advisory in the first place. The rest of the advisory is still in place due to an Ottawa River landfill on the river bank having transformers leaking into the river.

6. How does variation in the availability, quality, and analysis of data influence your decision to remove/keep a contact advisory in place? Since the contact advisories were in place and set due to gross visible contamination, the same metrics should apply when considering the sites for removal of the contact advisory. A visual inspection after a remediation is the tool used to assess the sites to determine if the advisory should be removed. All other data is secondary information.

7. What elements of information are most important for effective review and recommendation of removal of a contact advisory.

a. First, information regarding the control of the source of discharge. This should be done prior to remediation

b. Second, some sort of remediation/removal actionc. Sampling information from before and after remediationd. Last, a visual inspection should occur to officially keep/lift an advisory

Other items:

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MFLBC-SuperFund site

Ottawa River-AOC

Mahoning-nothing in place

LSR-Superfund site

Dicks Creek-Superfund/CO?

PAHs and PCBs don’t really break down in the environment. Need to be physically removed. Higher molecular weights cause them to not break down; attach to fats.

Revised interview questions:

Written/verbal consent

Establishing contact advisory

1. How was a site identified as not being safe for human contact?(Looking for specific criteria, matrices for determining if site is unsafe, also looking for who informs ODH of the sites)

In the past, Ohio EPA WQ Assessments and sediment data were used in to in reports. Ohio EPA would then notify ODH of its findings from the assessments. ODH epidemiology and toxicology program would then make a recommendation to the Director of ODH to establish the contact advisory.Health Consultation in Sawyer Run was used to establish a contact advisory as well.

2. How does ODH determine the length of stream covered by the contact advisory?

The length was determined from the information in the Ohio EPA WQ Assessments and sediment data reports.

Site clean up

3. How involved is ODH in the site assessment and remediation process conducted by OEPA, U.S. EPA, and others?(Are they copied on reports? Are they called in for technical advice? What, if any, is their involvement?)

ODH is involved if requested. ODH has been asked to aid in site assessments, specifically facilities discharges, through the development of Health Consultations. The Health Consultations help determine the contaminants of concern and potential pathways. Ohio EPA will then complete the sampling for the whole picture of the site. ODH’s and Ohio EPA’s information is sent to U.S. EPA for Superfund designation to support clean up. ODH will evaluate all the data from a public

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health perspective. If the data supports egregious contamination, a recommendation will be sent to U.S. EPA for priority cleanup (used to be SACUM and now it’s time removal action fund via unilateral orders to PRP). If the data supports contamination but it is not super egregious, Superfund cleanup will be recommended.

Re-evaluation

4. What pieces of information are most important when making a decision to re-evaluate and potentially removal a contact advisory?

-Source cleanup-Visual inspection to support removal of contact advisory

5. How does ODH determine when to re-evaluate a contact advisory?(is the re-evaluation requested by someone? If so, who?)

Re-evaluation has historically been requested by Ohio EPA. Ohio EPA has requested it for post-remediation scenarios in Sawyer Park and Black River cases. Sawyer Park-Ohio EPA post-remediation asked ODH to re-evaluate issued contact advisory that was based on Health Consultation concerns noted at site.

Data collection for re-evaluation

6. What is ODH looking for when conducting a visual observation inspection?

Sediments-what was the basis of the advisory. ODH has traditionally covered the whole stretch of river covered by contact advisory to check sediments and potential for dermal exposure, smells as well. BL-before had grey smelly stuff-not visualized after remediation

7. Is there a formal inspection form used for the visual observation inspection?No.

8. When completing a visual observation inspection, does ODH cover the whole stretch of the river covered by the contact advisory?Yes.

9. Are background (control) sites considered when evaluating surface water or soil sediment samples?

Not usually. There was no science used to establish the contact advisories so there was no science utilized to remove them. This could be something to entertain in the future. Health based recommended standards have been extremely conservative and almost impossible to achieve even at background sites. Hard to establish background levels for certain pollutants, such as PAHs, since PAHs are ubiquitous in the environment. Multiple sources of the pollutant.

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10. If background sites are considered, how are they established?(within the same watershed? On the same river? Sites that were previously contaminated with same contaminant but have been restored?)

Not sure. Ohio EPA picked recommended numbers in BR scenario that they considered normal.

11. What specific pieces of information are most important for ODH to make a decision?Y/N if the site is grossly contaminated. That should be the removal rationale. Sampling data history is good secondary information. Ideally, the site should be cleaned up to levels that existed before it was contaminated.

12. Have the same pieces of information been used when removing a previous contact advisory?Yes. Visual inspections with the aid (sometimes) of Health Consultation reference if applicable. Not necessary to remove based on science since that is not how it was established.

Overall process

13. From your perspective, what challenges or concerns do you have with the current process?Each site is unique so it is tough to standardize the process. Sites contaminated with PCBs and PAHs (remaining contact advisories) need to have the stuff dug up and removed for remediation. These contaminants will not break down in the environment over time.

14. From your perspective, what can be done to enhance this process in the future?Look at how things were done in the past to use in the future. Example, PAHs both contaminants of concern in BR so same metrics should be considered when removing contact advisory from LSR site. Look at contaminant of concern in the past for examples to create a removal template.

No other states have contact advisories.

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Appendix 2 - Survey sheet

An evaluation is being conducted in Ohio on the process in place to re-evaluate streams to remove a contact advisory. Information from other Region V states related to this process will aid the evaluation. Ohio currently has four stream segments that are currently under a contact advisory. The waters and/or sediments in these areas have high levels of contaminants. It is recommended that a person not swim or wade in these water body sections. Below is a table of the current contact advisories in place for the state of Ohio. Please review and answer the following questions below. A response by _____________ is requested.

Body of Water

Area Under Advisory Contaminant

Dicks Creek River mile 4.1 (1 mile downstream from North Branch Dicks Creek), Middletown to the Great Miami River (Butler County)

PCBs

Little Scioto River

State Route 739, near Marion to Holland Road, near Marion(Marion County)

PAHs

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Mahoning River NW Bridge Road (Warren) to Pennsylvania State Line(Mahoning, Trumbull Counties)

PAHs, PCBs

Ottawa River, Toledo

Eastern Interstate 475 bridge to Lake Erie(Lucas County)

PCBs

PAHs = Polycyclic Aromatic HydrocarbonsPCBs = Polychlorinated Biphenyls 

1. Has your state ever had any contact advisories in place for streams?

Yes No

If Yes, how many?______

If Yes, within the past 5 years, are any of the streams or corresponding sites with contact advisories considered to be Superfund sites?

If Yes, within the past 5 years, are any of the streams or corresponding sites with contact advisories under a court order for cleanup?

If Yes, what criteria were evaluated to establish the contact advisory?

2. Has your state ever removed and/or rescinded any contact advisories?Yes No

If Yes, how many?_______

If Yes, what criteria were evaluated to removed/rescind the contact advisory?

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Appendix 3 Raw sediment data

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Parameter RM 6.5 LSR 2007 surficial samples (0-4")Total PAHs 239 LSR 2008 TSDAnthracene (ug/kg) 250Benz(a)anthracene (ug/kg) 250Benzo(a)pyrene (ug/kg) 250Chrysene (ug/kg) 77Dibenz(a,h)anthracene (ug/kg) 250Fluoranthene (ug/kg) 250Fluorene (ug/kg) 250Naphthalene (ug/kg) 81Phenanthrene (ug/kg) 250Pyrene (ug/kg) 250

RM 3.43 (ug/kg) composite surface grab samples consisting of at least 2 sub samples per composite sampleTotal PAH (mg/kg) 17 17000 BL 2001 Ion 2004 reportAnthracene (mg/kg) 0.9 900Benz(a)anthracene (mg/kg) 1.52 1520Benzo(a)pyrene (mg/kg) 1.71 1710Chrysene (mg/kg) 1.75 1750Dibenz(a,h)anthracene (mg/kg) 0.9 900Fluoranthene (mg/kg) 3.48 3480Fluorene (mg/kg) 0.9 900Naphthalene (mg/kg) 1.26 1260Phenanthrene (mg/kg) 1.38 1380Pyrene (mg/kg) 2.73 2730

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Appendix 4 - Logic model

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Resources Activities Outputs Stakeholders Intermediate Long Term

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ODH staff

Ohio EPA/ODNR/consultants

ASTDR funding

Federal/State grants for remediation

Historical site knowledge

Sampling equipment

Facility discharge information

Sampling

Visual observation inspections

Remediation efforts

Data analysis

Laboratory work

Risk assessment calculations

Technical support documents2

(DSW/ODNR)

Risk assessment documents1

(DERR/U.S. EPA)

Public Health Assessments

Public using water resource

U.S. EPA/Ohio EPA

ODNR

Consultants/contractors

Watershed groups

Local governments

Citizen groups

External Factors: political pressure, law suits, consent decrees, budget, Superfund

1: TSDs, TMDL, WQ reports, ODNR water resource reports 2: ASTDR risk calculations, DERR Expanded Site Inspection Reports, Misc. U.S. EPA reports (RI/FS), DERR Endangerment Reports (?)

Consistent sampling methods and locations

Consistent risk assessment determinations for pollutant of concern

Strategic planning for delegation of work

Re-evaluation and removal of the contact advisory completed in a consistent manner by ODH

Improved efficiency in agency collaborations

U.S. EPA/consultants

Environmental laboratory staff

ODH