UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGIONS

77 WEST JACKSON BOULEVARDCHICAGO. IL 60604-3590

Via Facsimile KPIY TOT* ATTENTION OF:

August 10, 1994(M>0?MV/V

Joseph A. HeimbuchDeMaximis, Inc.Civic Center Plaza, Suite 10433300 Five Mile RoadLivonia, Michigan 48154

RE: Ecological Assessment Report Comments; Fields Brook Site

Dear Mr. Heimbuch:

This letter provides EPA comments to FBPRPO's 6/94 draftV Ecological Assessment report for the Fields Brook site.

As you will note, EPA has significant comments to andconcerns regarding this report. EPA requests to tentatively meetwith FBPRPO the week of 8/29/94 to discuss these comments, futuredirections for finalization of an Ecological Risk Assessmentreport for this site, and, potentially, risk managementalternatives for the Fields Brook wetlands/floodplains area. Atentative date and location for such a meeting could be 8/31/94at one of the Cleveland airport hotels (e.g., Airport Sheraton,216-267-1500). Several of EPA's commenters have tentatively setaside that date for such a meeting.

Please contact me at (312) 353-9228 if you need additionalinformation or have any questions regarding these comments(however, as you are aware, I'll be out of the office from

t~ 8/10/94 to 8/22/94 on vacation). I'll plan to call you on8/22/94 to confirm whether a meeting can occor on 8/31/94.

EdwarcKJ. Hanlon

Enclosures

cc: R. Williams, OEPA (via facsimile) S. Golyski, USAGE (via fax)M, Mischuk, CH2M Hill (via fax) M. Berman, EPA-ORCJ. Dingledein, Hill (via fax) P. Felitti, EPA-ORCD. Charters, USEPA-ERT (via fax) W. Curry, USFWS (via fax)D. Henne, USDOI (via fax) A. Fritz, NOAA (via fax)P. Delahunt, WCC (via fax) M. Schmidt, WCC (via fax)C. McConnel, Bechtel (via fax) P. Clifford, EA (via fax)

Printed on Recycled Paper

e

Enclosure 1

EPA Review Comments to Ecological Risk Assessment for FieldsBrook Floodplains and Wetlands/ EA Engineering, Science, and

Technology, Inc., June, 1994

I. General

1} Several of the components of the EA risk assessment aresimilar to the U.S. EPA Work plan for Fields Brook (1994);however, significant differences are also present. Several areasof difference are highlighted below.

S • Although some components of problem formulation areprovided other aspects such as the development of aconceptual site model, including pathway analysis anddiscussions of fate and transport, is not provided.

»/ • Reference to U.S. EPA's Work plan Endpoints are made,but assessment and measurement endpoints are notclearly stated.

/• Presentation of the information in a format proposed byEPA framework document (U.S. EPA, 1992a) and U.S. EPAapproved work plan for Fields Brook (U.S. EPA, 1994)would make this document easier to follow i.e, ProblemFormulation, Effects and Exposure Assessment, and RiskCharacterization.

2) Several inappropriate conclusions are drawn which do not agreewith the data. For example, while acute earthworm toxicityexists, these results are disregarded and overly optimistic-conclusions were drawn since no chronic risk could be shown

3) The data itself need to be reorganized and reviewed for/salvageability. For example, the detection limits for PCB's andHCB's are unacceptably high, and in some cases exceed 100 ppm./This should be discussed in coordination with the similar ongoing"discussions and responses from FBPRPO on this issue for thesediment and source control operable unit.

4) While many specific comments are provided in this letter,FBPRPO should be aware that there are numerous additional agencycomments not provided herein to various statements throughout the

•"report. These agency comments are not included since they wouldbe overly burdensome to provide at present. The agencies wouldbe willing to discuss them at the 8/31/94 meeting to tentativelyoccur.

II. Specific Comments

1. Introduction

• This section provides a good general discussion of sitebackground and setting* Project objectives are alsodefined, which in general coincide with the U.S. EPA(1994) Work plan for the site* More .details concerning

__;>NPL listing and reasons for clean"fas presented in theinitial RI/FS and SQDI Phase I investigative summarywould assist the Risk Manager 'to develop a totalpicture of the site problems. All tasks, identified inthe U.S. EPA Work plan to meet project objectives, donot appear to be satisfied in regards to rare,threatened and endangered species and critical habitats(wetlands).

2. Study Area Investigation

• Section 2 of the risk assessment document provides ageneral description of investigation methods. Althoughadditional details are provided in the Appendix,descriptions of some study methods appear to lackspecifics. For example methods used to evaluatetoxicant effects to vegetation or wildlife includingstructural or behavioral abnormalities are not providedin detail. Information such as location and frequencyof observations are not given.

• The U.S. Fish and Wildlife Services HEP procedures wereemployed to support receptor of concern (ROC) selectionand evaluate wetland habitat value for key species ofconcern. Details on cover types, habitat variables,etc. are not described. Previous comments on the HEPanalysis regarding potential bias in sampling methodsremain.

3. Study Area Characterisation

• Problem Formulation (Stressor characteristics,Ecosystem potentially at risk, and Ecological effects)What are the principal site-related stressor? What arethe potential non-site-related stressors that may causean adverse response in the ecosystem? Additional textwould help clarify these important aspects of the riskassessment.

• Ecosystem potentially at risk. Characterization ofbiological communities of the Fields Brook site areassessed qualitatively. Maps of habitat quality onlyprovide an indication of major cover types. Althoughvegetation throughout the f loodplain as characterized

as providing medium quality habitat, the basis for thischaracterization is not provided. The U.S. Fish andWildlife Services HEP procedures appear to have beenused but results of the study are not provided.

Information regarding yara^ threatened and endangeredspecies is lacking.

\Information on critical habitats (wetlands,specifically the type of wetlands and locations) arcnot detailed enough.

General conclusions regarding the health of the wetlandecosystem are throughout the document. For example theassessment characterizes the present ecosystem as"robust" and that the number of small mammalscollected suggests a population which is not beingadversely impacted by site related contaminants. Ingeneral, this conclusion is not supported by theinformation provided. Population studies of smallmammals to determine species richness, diversity,abundance or other population parameters were notconducted. It was also concluded that there is noevidence of overt toxicant impact to Fields Brookf loodplain/wetland flora and fauna f however, the meansby which this conclusion is draw is not fully describedin the assessment.

Nature and extent of contamination. Discussions focuson the results of analysis of biological tissue. Asummary of the results of these analysis are notprovided in the text of the assessment. Evaluations ofcontaminant concentrations in biological samples appearto be based on comparisons with background. Upstreamsamples also appear to be treated in a similar fashionas background samples. The suitability of upstreamreaches of Fields Brook (Reach 8-2 and 13) asbackground is questionable. Also, in order to betterevaluate the nature and extent of contamination alldata on floodplain soils contamination from both SQDIPhase I & II should at least be summarized in text. Itis acknowledged that soil information is expected withthe WCC SQDI Phase II report, soil information and anycorrelations between soil samples and biologicalsamples would provide the Risk Manager with a betterpicture of the true extent of contamination.

Potential Exposure Routes. Not defined. On page 1-6it is stated that this document includes all componentsof an ecological assessment including * 'evaluatingexposure pathways" this does not appear to be thecase. Exposure pathway models are an important aspect

in the overall risk assessment* They identify possiblesources of contamination, potential transport media,and potential points where receptors may come incontact with the contaminants. It also presents apicture to the risk manager as to what routes are mostlikely to occur.

* What are the potential ecological effects to thefloodplain/wetland ecosystem. A brief description ofpotential effects would assist the Risk Manager inunderstanding what problems nay occur at the site.Examples would be: decrease in vigor and resistance tonatural stressors, reduction in vegetation productivityand animal biomass, shifts in species composition,decrease in overall population due to reducedreproduction, decrease in overall population due toindividual mortality.

rr- {• What are the assessment and measurement endpoints?V ( This should be presented in a table format instead of

scattered throughout the text. It will be much easierfor the risk manager to evaluate what the assessmentend points are, what the measurement endpoints are, howthe measurement end points relate to the assessmentendpoints, which assessment were chosen for theinvestigation, and the rational for assessment endpointselection or omission. Example: assessment endpoint(organism survivability), measurement endpoint(bioticmedia concentrations of COCs), relationship (Indirect:biotic media results would be compared to toxicologicalbenchmark values to determine exposure, uptake, andpotential organism health and survivability), chosen(yes), rational (biotic media concentrations mayprovide evidence of chemical releases being thecausative factor for the observed biotic

^ concentrations).

4. Characterization of Exposure

Documentation to support the use of the paired comparisontechnique (PCT) in the selection process for COCs and ROCs inrisk assessments is lacking. Current literature used inecological risk assessments (Bartell et al., 1992; Calabreseet al., 1993; Suter et al., 1993; and U.S. EPA, 1989a 1989b,1991, 1992a, 1992b) do not cover this technique. Although thetechnique may have merit, it is hard to judge whether or not itshould be used without such documentation.

Selection of COECs

• All contaminants from the media to be remediated shouldbe considered in the process of COC selection. It is

important to include all site related chemicalstressors as potentially contributing to the impairmentof structure, function, and health of the site ecology*Cleanup goals (CUGs) for human health risk assessmentcould be used as a criteria, but it should be notedthat CUGs are not part of the ecological assessment atthis time.Statistical comparisons of background concentrationswith on site concentrations using a parametric methodsuch as the Students T-test may not be valid ifassumptions are violated. Collection of biological andnonbiological samples was not conducted randomly(biased samples).

Selection of ROCs

• Selection of ROCs was conducted using the same PCTtechnique used in the selection of COCs. Although the

(~~ final list of ROCs in the EA assessment differ fromthose identified in the U.S. EPA Work plan (1994), theyare also similar in many respects. Aquatic organisms,previously identified to be of concern to OEPA, are notincluded.

5. Risk Characterization

An ecological risk assessment model was developed basedon consumption rates, contaminant concentrations, etc.All aspects of model calculations do not appear to befully described. As a result, some information used toconstruct individual species models appearsquestionable. For example, home range sizes of robinsare known to be considerably smaller than the 211 havalue reported in the assessment. How this is adjustedfor in the model is unclear. It is indicated thatadjustments to calculations, such as those for timespent in a particular Reach were made but are notfully described. In some cases, food consumption ratessuggested for the mink are approximately half thevalues (0.150 kg/kg bw/day) reported in the literature*Concentrations of contaminants in plants and animalsobtained from specific reaches were to be used directlyin the calculation of doses to receptors. Thisinformation is provided in Appendix F. Some datapoints in the Appendix do not appear to correspond toconcentrations described in the text of the assessment.For example, concentrations of Aroclor 1260 in mammaltissue from Reach 5-2 was reported in the text as11.0 ppm. The data for mammal tissue reported inAppendix F for Reach 5-2 is 1.9461 ppm. The reason forthis discrepancy is unclear.

• Development of Hazard Quotient's values. The

calculation of HQs follows a common method for riskassessment. But, ecological receptors are exposed tomultiple chemicals and the effects caused by thecontaminants may be additive. An adjustment such as aecological toxicity index may be more appropriate toallow for additive effects (Barnthouse et al., 1986).This would be appropriate since some of the target ROCshave home ranges that would fall outside a singlereach.

• Earthworm Bioaccumulation/Toxicity Tests. Results fromthe bioassay tests suggest some toxic response. It wassuggested that observed toxicity was patchy an that thepotential contaminant was not one associated with area-wide contamination. This is probably true in part,since soil contamination results also suggests highlyvariable concentrations within the watershed. But, what

_ it also suggests is that some soils contain enoughr contaminant to cause mortality possibly an additivev. effect. A conservative approach when reviewing the

earthworm bioassay would suggest a potential problem.

Summary of CommentsMany areas of the report [EA Engineering, Science andTechnology's Ecological Risk Assessment for Fields BrookFloodplains and Wetlands Vol. 1 and 2 (Draft, June 1994)) werefound to indicate a generally comprehensive assessment ofconditions at the Fields Brook site. However, although similarin several respects, the EA risk assessment differs from theU.S. EPA Work plan for Fields brook in structure and content. Inaddition, it appears that all available information concerninganalytical results, endangered species, and other sources werenot included in the assessment, and must be provided.

The assessment concludes that there appears to be no risk toecological receptors at the site as a result of exposure to siterelated contaminants. This conclusion does not appear to befully supported by the information provided. There is enoughevidence presented to suggest potential ecological risk. EPAwill be prepared to discuss these issues with FBPRPO at a meetingto occur tentatively the week of 8/29/94.

References CitedBarnthouse, L.W., and G.W. Suter II (eds.) 1986. User's Manualfor Ecological Risk Assessment. ORNL-6251. Oak Ridge NationalLaboratory, Oak Ridge, TN.

8

Bartell, S.M., R.H, Gardner, R.V. O'Neill. 1992. EcologicalRisk Estimation. Lewis Publ. Chelsea, MI.

Calabrese, E.J. 1993* Performing Ecological Risk Assessments.Lewis Publ. Chelsea, HI.

Suter, G.W. II. 1993. Ecological Risk Assessment. Lewis Publ.Chelsea, MI.

United States Environmental Protection Agency (U.S. EPA), 1989a.Risk Assessment Guidance for Superfund—Environmental EvaluationManual. EPA/540/189/001. March 1989.

United States Environmental Protection Agency (U.S. EPA). 1989b.Ecological Assessment of Hazardous Waste Sites: A Field andLaboratory Reference. EPA/600/3-89/013. March 1989.

United States Environmental Protection Agency (U.S. EPA). 1991.(~ Ecological Assessment of Super fund Sites; An Overview. ECO

Update Vol. 1:2. EPA Pub, 9345.0-051, Washington, D.C.

United States Environmental Protection Agency (U.S. EPA). 1992a.Framework for Ecological Risk Assessment. EPA/630/R-92/001.Risk Assessment Forum, Washington D.C.

United States Environmental Protection Agency (U.S. EPA)Region 5. 1992b. Regional Guidance for Conducting EcologicalAssessments.

United States Environmental Protection Agency (U.S. EPA). 1994.Ecological Risk Assessment Work Plan, Sediment QuantificationDesign Investigation, Phase II, Fields Brook Sediment OperableUnit, Ashtabula, Ohio.

UNITED STATES ENVIRONMENTAL PROTECTION AOCNCYENVIRONMENTAL RESPONSE BRANCH

Edison, New Jincy 08837

August 8, 1994

V

Ecological Rifck Assessment for Fields Brook: Floodplainand Wetland*David V. charters, Ph.D.Environmental Response Team

SUBJECT!

FROM:

TOs

At your request, I have completed the preliminary reviev ofthe Geological Risk Assessment for Field* Brook Floodplain andWetlands, Ashtabula Colunty, Ohio. After a reviev of the datacollection procedures ahd interpretation, I am unable to agree withthe results of the rirt assessment. The document's assumptionsgive o vory optimistic fesBesin&Ant of risfc associated with the sitewhich the data (e.g., earthworm toxicity tests) do not support.Confusion with feeding group* and composite samples make the dataquestionable and unusable in many instances. I do not agree withthe assumptions upon which the ricOc model is based since it isbased on unacceptable data analysis and sampling procedures.

The basic premises on which the risk assessment is based arefaulty. Major inaccuraoiet in data collection and interpretationlead one to believe there is no risk associated vith the site, donot concur vith this rink oasoeennnt. Nothing In the riskassessment assists me in making a determination as to what anappropriate clean up goal would be for the ait*, Examples of theeamisinterpretations and inconsistencies include the fact that thebenthic macroinvertebrAte data ie not relevant to the assessment,there was no attempt to correlate soil community structure analysiswith contaminant levels, elevated detection limits, andmisapplication of the equilibrium partitioning model discussion(i.e. , soil moisture vas inappropriately propoeed ao beingequivalent to pore water) .

In addition, the conclusions of the risk assessment were baseden a presentation by Dr. Charles ftenzie to the water EnvironmentFederation (Kenzie et, al», 1993). According Dr. Menzie's model,only after conservative assumptions are applied to the data doe*the level of concern go from a hazard quotient of one to ten(Charles Menzie, pers6nal communication). This situation wasmi « interpreted in the document.

I havt given the risk assessment to a support contractor todetermine what if anything can be uaed as part ot an appropriate•co logical risk assessment to determine an ecological cleanup goal.I will Xeep you advised on the progress of tne contractor.

Specific comments on the ecological risk assessment follow*Comment^

•me reference locations (BX1, BK2J , are inappropriately designatedas background locations and do not appear to be representative ofthe other sampling locations. It is clear that substrate types(aud at ponded site and gravel/cobble at reference sites) arevastly different from one another and this probably explains thedifference observed in the benthic community analyses. Referenceareas should be selected to compare specific parameters* Forexample , a comparison of benthic community structure in a rocxcobble area to a muddy substrate area is not appropriate and noconclusions can be made as to impacts or a lack of impacts fromcontamination. In addition, the composition of the small mammaltrap data indicates the habitats are significantly differentbetween the two references and the site.

The reference sites for orayfishr fieh and "Kerptiles" pressntsmore evidence for dissimilarity among reference and site locations*Section 3.1.3.2 (pg 3»7) states "... again suggesting that thebackground locations are representative of conditions in the FieldsBrook floodplain/wetland". This is the first information thatsupports the reference locations ae being eimilar to the site. Tobase the selection of reference locations on this limited data, isinappropriate.*̂*It was noted that £PA designated theee sites in 1994 (EPA 1994) yetthe final investigation of the site is noted to be in October,1993, Which indicates the £P\ recommendation did not occur untilafter the initial data collection was completed.L 1 SV-JLV+** &* / * fy~ ^~>— f- — Sampling Procedures and Data AnalysisComposite sampling is a "liberal11 technique, as any samples from ahot spot would be diluted by individuals from otner areas. Anyindividuals that had a high residue level would be masked by thecomposite. Page 2-B infers that different species were compositedfor biological tissue analysis * Shrews , mice and voles werecomposited, and 20 composite samples of a "terrestrial plants"(specie* not reported) were collected. Composites should always belimited to same species, as differences in uptake and feedingcannot be interpreted with multi-species composite. In this case,the composite of mice and voles mix herbivores with omnivores. Theexposure route for these two feeding groups (noted to be similar)is through different pathways and concentrations will be minimizedby dilution, if there are any differences in actual exposure. *

i"he shrew composite would also be a problem aes1 have a wider diet and lower metabolism than Sore*. Since short-'.tailed shrews are carnivores, they also would have mice and volesin their diet, which would be an Invalid comparison,

Page 4-23 references similar feeding groups "i.e. mice and shrews"end shows that whomever is doing this part of the risk assessmentis unfamiliar with both nice and shrews. Previously mice and vole*were put in the cans feeding group, herbivores and omnivoree. Inaddition, two different types of shrews vhich have significantlydifferent feeding habits were linked. These linkages are notcorrect. Herbivores, omnivores, insectivores and species Known tokill and consuito email maicmals are not "similar feeding groups".

In addition, the terrestrial plant samples were not identified asto the species collected and what part of the plant was sampled(i.e., aged or roots and whether first or second year growth). Theproportions of species, by mass, in the sample were not noted*Without this information the data ie not interprstable. Theportion of the plants which herbivores and omnivores consume wouldnot necessarily b« equivalent and would further confound the dataanalysis (i.e., cross species, cross feeding group, and smallmammal composites).A trap night is actually a 24 hour set* Not a trap eet for onenight.

The note that "During the September 1993 field effort (when themajority of small maitmais vsre captured)..." leada me to believethat the composites were collected at different times in differentareas. Is this correct? Later in the document (pg 2-10) itbecomes apparent that the soil/sediment samples vere taken at adifferent time and location from the biota sampling. Clarification•As needed as to when and where these samples were actually taken*JLThe ufie of off-site composite samples from dissimilar habitats isquestionable.

On page 2-8 it appeare you did not utilize the Reach 8 samples.Why were these samples taken ? The differences in substrate shouldhave been apparent at the time of the sampling.

The use of the "liberal11 assumption of arithmetic nean forcalculation of exposure is not acceptable. Mean values are notconservative and do not represent the chronic exposure. The upper93% confidence limit should be used in calculations of exposure.The rational presented for this position and then using compositemethods takes on average of an average. This is confounded bytaking composites of crossing feeding groups which is unacceptable.

The table of biological parameters used in the ecological riskmodel (Table 4-5) contains misapplied information. For example,soil ingestion rates presented for red-tailed hawks and greathorned owls were based on literature generated for the Canada

o

The use of a series of Student's T-tests to compare concentrationsof COC in receptors is not ft statistically valid procedure (page 4-23). Analysis of variance (ANOVA) should be employed,t

Receptor Selection

The process used for determination of receptor organisms is notappropriate. The ranking process does not highlight any particularspecies fron another and in the end each ranking is basically thesame. The justification for the designation of a threshold asdisplayed in Figure 4-3 requires clarification. One would assumethat organisms above . the threshold would display somecharacteristics desirable for receptors, while those below wouldnot meet the needs according to the ranking criteria outlined inthis document. However, one npecias beaver was added because itwas there, is this one of the selection criteria?Use of the U.S. Fish and Wildlife Service Habitat EvaluationProcedure (HEP) to select receptors of concern is not Within thescope of the accepted applications of the model. HEP is based inindividual species models and habitat type* selected forevaluation. As the model requires that the species be chosenprior to the application of the model how does this assist in theselection of species. The model is highly subjective and does notnormally encompass all food web interaction* unless specificadaptations have been Incorporated. The model limitations outweigh the usefulness of this model given significant modificationare necessary to adapt this procedure for receptor identification.rhe assumptions of home range needs to be negotiated. Aconservative assumption would be the animals spend 100 percent oftheir time on the site.•me "lists of potential species appears to get a little loose whenspecies are snakes-land and snakes-water, and turtles-land (?)turtles-water and turtles-snapping if they can not be more specific'(see plant listings 3-5) they are not of much value.

Figure 4-4 illustrates the conceptual food web model ana indicatesthat aquatic pathways will be considered. However, no aquaticreceptors representative of lower trophic levels were selected*

WetlandsAlthough a phragmite*, wetland is considered of lower quality,comparatively to the naturally occurring wetland vegetation,phragmites systems are still productive wetlanda and are of value.Alterations in soil and/or hydrology, as well as contaminant

strtssors or physical disturbances, can bo rssponsibls forinfiltration by pfrragmites. in addition, comments on page 3-3indicate that the vetlands are not monoculture stands ofbut exist in concert with several otfier wetland plants. Therefore,even though the wetland systems nay not bo ideal, the vetlandssystems still represent productive natural resource arsat*value of the wetland should not be underestimated simply because ofthe presence of Phraqmites

The study area characterization is adequate if statements such as•There is no evidence of overt toxicant impact to Fields BrooXfloodplain/vstland flora or fauna* and "Herbaceous wetland areascharacterized by the presence of Phracnnites. . *n were eliminated.These statements either present no evidence of could be worded sothat wetland determinations do not appear to be based on a FACWspecies.Figure 1*2 indicates that the wetland boundary is outside the 100year floodplain boundary. This situation is not possible and theseissues require clarification. Are the lines reversed on the map?

Toxicity

l' assume that the soil saaplce froa the toxicity tests were taXenfrom the 6 to 8 Kg of soil for the toxicity tests and not relatedto samples taken previously in Phase II SQDI studies. Thestatements do not make this clear,

Please define the "control tests11* Define whether these tests were-testfi of the protocol, teats for matrix compatibility ordetermination of earthworm sensitivity.If there are indications of acute toxicity, the individualsremaining at the end ot the test are not appropriate for

, calculations of accumulation. As the mechanism of toxicity was notf v determined, how can it be shown that the acutely toxic compound did

not affect bioaccuaulatlon, The toxicity tests run for this riskassessment indicated toxicity**What was the nature of "worm behavior" whicn they are using as somejustification of the results (page iii and 4-53) .Section 4.6 states that earthworm toxicity tests displayed 100%mortality, 87.3% mortality and Ot mortality. This data wasinterpreted to mean that clean areas are patchy and not that theresponsible agent(s) are distributed in small patches. Your datachows that only three of eight tests did not show significanttoxicity and all areas studied shoved elevated mortality. Thisstudy ehows that the site is presenting a significant risk toearthworms* The fact that the reasons for the toxicity were notexplained or as put by the risk assessment "essentially lacking11shows that the rejection of acute and chronic toxicity as aselection factor for

- c

Contaminants of Concern (COC)It should be noted that many of the COCs are appropriate but themechanise for selection is not acceptable. I would like to see.acute and chronic toxicity addressed as a selection criteria./The logic for the selection of COC needs to be reworked as theprocedure noted makes little sense based on the three assumptionsbf bioaccuaulation potential, ubiquity, and statistical probability[that the concentrations of site contaminants in tissues and soils>ra significantly different from those observed in backgroundtissues and soils. Using bioaccumulation as selection criteriabecause "Some measure of analyt* toxicity was also considered butvas dropped because of lack of lexicological endpoints forecological receptors for the majority of contaminants" is notacceptable. The earthworm tests show acute toxicity, thereforetoxioity should be included as a coc election criteria.Many compounds exist which are not bioaccuroulative yet are acutelyor chronically toxic. Toxicity cannot be ruled out as a basis forevaluation of COCs oimply because the of "lack of toxicologicalendpoints for ecological receptors. Many compounds have endpointinformation and each compound should be evaluated with all theavailable information. In addition, toxicological endpoints forecological receptor* are not the only information vhich oan be usedto evaluate COC. fcnbient water Quality Criteria and sediment andsoil guideline and also be utilized to evaluate each compound.

Complete information does not exist for some of the contaminants ofconcern yet bioaccumulation factor for soils were developed frombioconcentration lectors. It the claim is that BCF and BXF oreequivalent is to be accepted please support this importantposition, What is tne rational for this action?The use of ubiquity as a selection criteria is another unsupported"liberal" assumption. This assumes that there are no hot spots orareas of concern. Considering the sampling design, what is thelargest hot spot that could have been missed? An EA or KCCstatistician should be able to calculate this area.Page 4-3 states that statistical probability is more important thanJbioaccumulation potential because if the compound is present in lovconcentrations! bioaccumulation is of little relevance, This is asubjective Atatement assuming a very flat dose response curve andis not supported by any evidence in this risk assessment, pleaseremove it.

Pago 4-3 also reports a process with a "neutral parameter". Thl'lprocess is not inherently clear since it is stated that the"neutral parameter" is "defined always as the poorest choice11. Hovcan this parameter be neutral if it is poor.

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- 7

The statement that "The degree of elevation of these analytes abovebackground concentrations (whan observed) does not suggest thatnobility of these analytes in the food web occur* in a sufficientlywidespread mannar to warrant concern** is not supported by anyinformation at thia stage and in fact the PCS levels axcaad theGraat Lakes pray based numbers for tha protection of raptors by upto a ordars of magnitude. All indications are at this point thatthere is an significant risk in some areas of the site.The leap in logic that equilibrium partitioning todtl(BqP)(AVs/SEM) would b« relevant to soils shows a complete lack ofunderstanding of tha assumptions of the tfgP model. Soil moistureis not equivalent to pore water, please eliminate any reference tothis model.

Detection LimitsPlease highlight the quantification levels of different analytes.I am particularly concerned with the 99 tog/kg UJ PCBfl ctted.

The issue of statistical differences between the areas using 1/2detection limits when there are difficulties with high levels ofdetection make the comparisons irrelevant* with the 99 mg/kg UJPCBs cited would the "background levels11 be assumed to be ttrrppm?

-5~0General Comments

The term surrogate needs to be defined, surrogate is usedon pages 2-6, 2-7, 2-9 as a representation of baseline conditionswhich are expected to be obtained post remediation, in other wordsa reference* Surrogate is used to denote both contaminants orreceptor species as in pages 2-7 and 2-8, respectively*Consistency in the use of tills term is necessary for understandingits meaning.

In section 2.2.1, it is stated that behavioral anomalies were to benoted. What were the field crews instructed to interpret asbehavioral anomalies?iThe risk of remedy sections are premature in that the type ofremediation has not been discussed in this document. How can therififc of remady be evaluated not knowing what the remedial actionwould entail, It appears dredging with no attempt at restorationis the comparison remedy, and the assumption is that the floodplainwould become an open Phragjnites wetland. Or does this only involveremediation of the brook in which case, why IB it in this document?

The conolueions drawn with respect to cleanup on page 5-16 are notappropriate* Many of the comments in this section are prenatureand based on faulty logic. For example, it is premature to statethat "only hot-spot areas of contamination should bs remediated tolimit cleanup impacts on the Field* Brook floodplain/vetlandecosystem."

The risk assessment appeared to treat the site as one unit and notas a gradient of contamination across the ait*.In section 2.1.4,, please cnange possible taxon to practicabletaxon.Section 2.1.5 , discusses the issue of inserting the anticipatedchanges in the brook related to the floodpialn and wetland ri»xassessment is inappropriate. Comparisons between these differenthabitats is invalid.Statements such as "... abundant populations of snail mammals at thesite." (pg 3-4) are subjective and data is not presented to supportthe statement.Section 3*1.3 states that fish and macroinvertebrates species foundAt the eite were indigenous to the area [redundant]...included...crayfish.... The next sentence states that crayfish were notfound at the site. The sentences contradict each other.

J.The entire bonthio community structure section should be removed as '*"the eite was not evaluated other than reach 8-2 which is upstreamof the contaminated portion of the site* The issuas of samplingdifferent habitat in reach 6 and the "background" remain.

Hazard quotients greater than one should indicate ecological risk,not the over ten value suggested in thie document on page 4-24,through Menzie et. al., 1993. Xenzie (personal communication) doesnot support the risk assessment * s interpretation of hispresentation.There is an ongoing review of the literature values cited.

O

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION V

DATE: July 28, 1994

SUBJECT: Ecological Risk Assessment for Fields Brook Floodplains andWetlands, Ashtabula, Ohio

«

FROM: Ed Karecki, U.S. Fish & Wildlife Service BiologistTechnical Support Section

TO: Ed Hanlon, RPMMN/OH Remedial Response Section

Thank you for the opportunity to review the above mentioned report. The following general~^ comments are based primarily on previous recommendations made by the SuperfundQ; ) Ecologist and BTAG for the ecological risk assessment for this site:

Page ii - The section which describes how many "detects" occurred in tissue samples shouldindicate what the total number of samples was for each.

The 4-methylphenol concentration in mice is described as "low", yet the concentrations ofother compounds detected in tissues are not qualified. If terms such as low or high arc usedthen they should be defined and referenced to literature.

Is the description of PAH distribution referring to tissue samples, soil samples, watersamples, or all samples?

The sentence which states that "volatile organics were not detected in any great abundance"^ ^ should indicate how many "detects" occurred out of the total.

In previous correspondence it was recommended that octachlorostyrene be analyzed for intissue samples, was a valid reason presented for excluding this compound?

Section S.3P page 5-4 - In previous correspondence it was suggested that AVS/SEM analysisis not appropriate for sediments which are not continuously inundated. The uncertaintyassociated with using AVS/SEM analysis to predict toxicity in this situation should bediscussed here.If you have any questions or would like to discuss the site, please give me a call at 3-3202.Also, please take a minute to complete the enclosed critique form and return it to SteveOstrodka(5HSRLT-5J).

cc: Steve Ostrodka, TSS

CENCB-CO-0 5 August 1994Pickard/swp/4404

MEMORANDUM THRU

Chief, Operations BranchChief, Construction-Operations DivisionChief, Engineering and Planning DivisionChief, Environmental Analysis and Engineering BranchChief, Site Remediation Section/Mr. David ConboyChief, Planning BranchChief, Plan Formulation/Technical Management Section

FOR Mr. Stephen Golyski

SUBJECT: Review of Ecological Risk Assessment For Fields BrookFloodplains and Wetlands

1. References:

r • a. USEPA, Office of Superfund Facsimile, dated 21 June1994, SAB.

b. USEPA, Office of Superfund Facsimile, dated 3 August1994, SAB.

2. As requested in the above referenced facsimiles, I havereviewed the subject draft report and provide the followingcomments:

*• General:

(1) Recommend that organization of the subject reportconform to the format provided in USEPA's Frameworjc forEcological Work Assessment. The document, as presented, issomewhat difficult to follow.

f J,v- (2) The risk assessment lacks information in State or ^Federal, rare, threatened or endangered species.

(3) The report essentially concludes that the informationpresented therein show that contaminants within Fields Brookwetlands/floodplains present no risk to ecological receptors. Itis my view that there are data (i.e., the earthworm bioassays)that suggest potential ecological risks.

_ *>• Specific:

(1) Page 2-4, Subsection 2.1.2, Paragraph 1 - Referencesmade to Figures 2-la through 2-ld are confusing since these arehabitat quality maps that are also being used to illustrate thesampling transects. This should be clarified in the text.

-2-

SUBJECT: Review of Ecological Risk Assessment For Fields BrookFloodplains and Wetlands

(2) Fag* 2-5, Subsection 2*1.3, Paragraph 1 * The habitatrequirements for the ROCs should be addressed.

(3) Page 2-8, Subsection 2.2.3, Paragraph 2 - Fourthsentence in this paragraph should read ". . .presented in EA(1993a) and in the SOP presented in Appendix A.N

(4) Pages 3-1 through 3-2, Subsection 3.1*1 - The habitatquality naps are too general and wetlands information in the textis vague. Although Phragraites austyalis nay dominate themajority of herbaceous wetlands in the floodplain, it isdifficult to comprehend that it is always the predominatingspecies. There is no reasoning provided as to why Phragraitesaustralis dominates most of the herbaceous floodplain, other than

Y"-" • it is an invasive, non-native species. It is quite\;. • characteristic of disturbed areas, and often colonizes all types

of landfills. I seem to recollect some wetlands in thefloodplain that were clearly dominated by sedges (Carex spp.), anobligate wetland species. Since sufficient population data onthe animal communities at Fields Brook are lacking, support forthe statement in Paragraph 1 that "no evidence of overt toxicantimpact to Fields Brook floodplain/wetland flora and fauna" islacking. This statement appears to be premature and should berephrased.

(5) Page 3-3, Subsection 3.1.3, Paragraph 1 - Wetlandvegetation in the floodplain corridor is characterized as "mediumquality habitat." This is inconsistent with the "high value"qualification of the wetland habitat indicated in Paragraph 1 ofSubsection 1.1.3 (Page 1-4). Also, it is a distinct possibilitythe method of crayfish collection used was just not successful in

X, obtaining samples in the Fields Brook floodplain. A method ofcapture suggested previously (baited minnow traps) may have beensuccessful in both background and Fields Brook floodplainlocations. I have personally used this method with success whensampling mud-bottom aquatic areas.

(6) Page 3-5, Subsection 3.1.3.1, Paragraph 4 - In the lastsentence, "Probably" should be deleted and "but" should bereplaced with "and." The two benthic communities at the FieldsBrook floodplain and background sites cannot be compared due tohabitat differences.

(7) Page 3-7, Section 3.2 - Potential exposure routes ofCOCs to the receptors are not discussed. Also, ecologicalassessment and measurement endpoints are poorly addressed in thetext.

i -3-

SUBJECT: Review of Ecological Risk Assessment For Fields BrookFloodplains'and Wetlands

(8) Page 4*10, Subsection 4.4*2, Paragraph 2 * Based on allbut possibly one of the references cited, it appears that thesecond sentence relates only to the bioavailability of heavymetals (i.e, Cadmium and Nickel). The preceding sentence on therelationship between sediment organic carbon and nonpolar organiccompounds suggests that the second sentence is in reference toorganic contaminants. Does this mean that the only bioavailablePCBs are those that are in soil moisture? More information (orreferences) in this paragraph is necessary to furthersubstantiate this statement.

(9) Pag* 4-54, Section 4.6 - A cursory review of theearthworm bioaccumulation and toxicity data would indicate thattoxicant effects should be a concern. The bioassay data should

£-V be reviewed further in this regard.*,' • •"* -.'3. Questions or comments regarding this technical review shouldbe referred to the undersigned, who may be reached at extension4404.

c

SCOTT W. PICKARDBiologistOperations Branch

CF:CENCB-CO-0CENCB-PE-SR (Conboy) I

fbarrpt.rev