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                                                  Environmental Protection
                                                  Agency
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                                                                         oEPA
                                                  Stressor  Identification
                                                  Guidance Document
 EPA/822/B-00/025


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STRESSOR IDENTIFICATION
   GUIDANCE DOCUMENT
     U.S. Environmental Protection Agency

             Office of Water
          Washington, DC 20460

      Office of Research and Development
          Washington, DC 20460
            EPA-822-B-00-025
             December 2000

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                                           Disclaimer

This Stressor Identification Guidance Document provides guidance to assist EPA Regions, States, and
Tribes in their efforts to protect the biological integrity of the Nation's waters, one of the primary
objectives of the Clean Water Act (CWA).  It also provides guidance to the public and the regulated
community on identifying stressors that cause biological impairment. While this document constitutes
the U.S. Environmental Protection Agency's (EPA's) scientific recommendations regarding stressor
identification, this document does not substitute for the CWA or EPA's regulations, nor is it a regulation
itself.  Thus, it cannot impose legally binding requirements on EPA, States, Tribes, or the regulated
community, and may not apply to a particular situation based upon the circumstances. When appropriate,
State and Tribal decisionmakers retain the discretion to adopt approaches on a case-by-case basis that
differ from this guidance. EPA may change this  guidance in the future.	

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                           Stressor Identification Guidance Document
                             Acknowledgments

Primary Authors:

   EPA, Office of Research and Development:
       Susan Cormier, Ph.D.
       Susan Braen Norton, Ph.D.
       Glenn Suter II, Ph.D.

   EPA, Office of Science and Technology:
       Donna Reed-Judkins, Ph.D.

Contributing Authors:

   EPA, Office of Science and Technology:
       Jennifer Mitchell
       William Swietlik
       Marjorie Coombs Wellman

   EPA, Office of Wetlands, Oceans and Watersheds:
       Thomas Danielson
       Chris Faulkner
       Laura Gabanski, Ph.D.
       Molly Whitworth, Ph.D.

   EPA, Office of Research and Development:
       Edith Lin, Ph. D.
       Bhagya Subramanian

   EPA, Office of Enforcement and Compliance Assurance
       Brad Mahanes

   Other Affiliations:
       David Altfater, Ohio Environmental Protection Agency
       William Clements, Ph.D., Colorado State University, Fort Collins, Colorado
       Susan P.  Davies, Ph.D., Maine Department of Environmental Protection, Augusta, Maine
       Jeroen Gerritsen, Ph.D., Tetra Tech, Owings Mills, Maryland
       Martina Keefe, Tetra Tech, Owings Mills, Maryland
       Sandy Page, Tetra Tech, Owings Mills, Maryland
       Jeffrey Stinson, Ph.D., U.S. Air Force

Technical Editors:

   EPA, Office of Research and Development, National Risk Management and Restoration Lab:
       Jean Dye, Ph.D.
       Scott Minamyer
                                                                                      in

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                            Stressor Identification Guidance Document
    Tetra Tech:
       Abby Markowitz
       Sandra Page
       Colin Hill
       Brenda Fowler

Stressor Identification and Evaluation Workgroup Members:

    Co-leads:
       Office of Water: Donna Reed-Judkins, Ph.D., Office of Science and Technology
       Office of Research and Development: Susan Cormier, Ph.D., National Exposure Research Lab

    Members:
       Office of Water:
           Office of Science and Technology:
           Tom Gardner, Susan Jackson, Jennifer Mitchell, Keith Sappington, Treda Smith,
           William Swietlik, Brian Thompson, Marjorie Wellman

           Office of Wetlands, Oceans, and Watersheds:
           Thomas Danielson, Laura Gabanski, Chris Faulkner, Molly Whitworth, Ph.D.

       Office of Research and Development:
           National Center for Environmental Assessment:
           Susan Norton, Ph.D., Glenn Suter II, Ph.D.

           National Health and Environmental Effects Laboratory:
           Naomi Detenbeck, Ph.D., Wayne Munns, Ph.D.

           National Risk Management and Restoration Laboratory:
           Alan Everson, Scott Minamyer

       Office of Enforcement and Compliance Assurance
           Brad Mahanes

       EPA Regions
           Toney Ott, Region 8

       Other Federal Agencies:
           Jeffrey Stinson, Ph.D., U.S. Air Force

       States:
           Susan Davies, Maine Department of Environmental Protection, Augusta, Maine
           Chris O. Yoder, Ohio EPA, Columbus, Ohio

       Other Supporting EPA Members:
           Don Brady, Alan Hais, Margarete Heber, Mary Sullivan

       Contract Support, Tetra Tech, Owings Mills, Maryland:
           Michael Barbour, Ph.D., Jeroen Gerritsen, Ph.D., Martina Keefe, Sandy Page
IV

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                              Stressor Identification Guidance Document
Peer Reviewers:
       A. Fred Holland, Ph.D., Director, Marine Resources Research Institute of South Carolina.
       Kent Thornton, Ph.D., FTN Associates
       Wayne Landis, Ph.D., Director, Institute of Environment Toxicology and Chemistry, Western
       Washington University
The authors wish to gratefully acknowledge all others, not named above, who helped to prepare this
document.  The sum of these efforts contributed to the success of this guidance. Special thanks also Jo all
the EPA and State scientists who participated in the video conference in October, 1999; the Region III
Mid-Atlantic Water Pollution Biology Workshop at Cacapon, West Virginia, in March 2000; and the
Biological Advisory Committee meeting in Cincinnati, in May, 2000. Comments were also provided by
a number of EPA scientists and regulators and by other stakeholders, including the Kansas Department
of Health and Environment, Arizona Department of Environmental Quality, Denver Metro Wastewater
Reclamation District, Pennsylvania Department of Environmental Protection, Proctor and Gamble, The
Nature Conservancy, and the U.S. Geological Survey. Comments from the workshops and other
commenters helped shape the guidance.

The cover illustration was provided by a fifth grade student at Ursula Villa Elementary School, Mount
Lookout, OH.  According to the illustrator, the front cover is the river when you first pick up this book,
and the back cover is the river after you've followed the instructions.	

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                      Stressor Identification Guidance Document
                        Table  of Contents

Acknowledgments  	iii

Acronym List 	xiii

Executive Summary
       ES. 1  The Clean Water Act, Biological Integrity, and Stressor
             Identification	 ES-1
       ES.2  Intended Audience	 ES-2
       ES.3  Applications of the SI Process  	 ES-2
       ES.4  Document Overview	 ES-3
Chapter 1: Introduction to the Stressor Identification (SI) Process
        1.1   Introduction	
       1.2   Scope of this Guidance . . .
       1.3   Data Quality Issues	
       1.4   Overview of the SI Process
             1.4.1 The SI Process 	
             1.4.2 SI Process Iterations	
             1.4.3 Using the Results of Stressor Identification
       1.5   Use of the SI Process in Water Quality Management Programs
-1
-2
-2
-3
-3
-5
-5
-6
Chapter 2: Listing Candidate Causes
       2.1   Introduction	2-1
       2.2   Describe the Impairment	2-1
       2.3   Define the Scope of the Investigation	2-3
       2.4   Make the List  	2-4
       2.5   Develop Conceptual Models	2-5

Chapter 3: Analyzing the Evidence
       3.1   Introduction	3-1
       3.2   Associations Between Measurements of Candidate Causes and
             Effects	3-2
       3.3   Using Effects Data from Elsewhere 	3-6
       3.4   Measurements Associated with the Causal Mechanism	3-9
       3.5   Associations of Effects with Mitigation or Manipulation of Causes  . . 3-10

Chapter 4: Characterizing Causes
       4.1 Introduction	4-1
       4.2 Methods for Causal Characterization	4-1
           4.2.1 Eliminating Alternatives	4-3
           4.2.2 Diagnostic Protocols or Keys	4-7
           4.2.3 Strength of Evidence Analysis 	4-8
                  4.2.3.1  Causal Considerations for Strength of Evidence
                         Analysis 	4-9
                  4.2.3.2 Matching Evidence with Causal Considerations 	4-14
                  4.2.3.3  Weighing Causal Considerations	4-14
       4.3 Identify Probable Cause and Evaluate Confidence  	4-17
                                                                                    vn

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                            Stressor Identification Guidance Document
                    Table of Contents  (continued)
       Chapter 5: Iteration Options
              5.1 Reconsider the Impairment  	5-1
              5.2 Collect More Information on Previous and Additional Scenarios	5-2

       Chapter 6: Presumpscot River, Maine
              6.1   Executive Summary  	6-1
              6.2   Background	6-3
              6.3   List Candidate Causes	6-5
              6.4   Analyze Evidence and Characterize Causes: Eliminate 	6-8
              6.5   Analyze Evidence and Characterize Causes: Strength of Evidence  ..6-11
              6.6   Characterize Causes: Identify Probable Cause  	6-17
              6.7   Significance and Use of Results	6-18
              6.8   References	6-18

       Chapter 7: Little Scioto River, Ohio
              7.1   Executive Summary  	7-1
              7.2   Introduction	7-4
              7.3   Evidence of Impairment 	7-5
              7.4   List Candidate Causes	7-10
              7.5   Analyze Evidence to Eliminate Alternatives  	7-13
                   7.5.1 DataAnalyzed 	7-13
                   7.5.2 Associations between Candidate Causes and Effects  	7-14
                   7.5.3 Measurements Associated with the Causal Mechanism:
                        Exposure Pathways  	7-24
                   7.5.4 Summary of Analyses for Elimination	7-26
              7.6   Characterize Causes: Eliminate	7-26
              7.7   Analyze Evidence for Diagnosis	7-28
              7.8   Analyze Evidence to Compare Strength of Evidence	7-28
              7.9   Characterize Causes: Strength of Evidence	7-31
              7.10  Characterize Causes: Identify Probable Cause  	7-47
              7.11  Discussion	7-48
              7.12  References	7-50
              7.13  Additional Tables  	7-54

       APPENDICES

           A Overview of Water Management Programs Supported by the SI
           B Worksheet Model
           C Glossary of Terms
           D Literature Cited

       INDEX
vin

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                      Stressor Identification Guidance Document
                           List of Figures
Figure                                                                  Page

  1-1   The management context of the SI process	1-4

  2-1   A conceptual model for ecological risk assessment illustrating the effect of
       logging in salmon production in a forest stream	2-7

  3-1   The flow of information from data acquisition to the analysis phase of the
       SI process  	3-3

  3-2   Plot of toxicity data from a 7-day subchronic test of ambient waters and a
       community metric obtained on a common stream gradient  	3-4

  4-1   A logic for characterizing the causes of ecological injuries at specific sites . . 4-2

  6-1   Map of the Presumpscot River showing biomonitoring stations, potential
       sources of impairment, and their location relative to the Androscogginn
       River	6-4

  6-2   Species richness and number of EPT taxa in the Presumpscot River upstream
       and downstream of a pulp and paper mill effluent discharge	6-6

  6-3   Conceptual model showing the potential impact of stressors on the benthic
       community of the Presumpscot River	6-7

  6-4   Bottom dissolved oxygen concentration in the Presumpscot River	6-10

  7-1   Map of the Little Scioto River, Ohio, showing sites where fish were
       sampled	7-6

  7-2   Spatial changes in fish IBI (A) and benthic macroinvertebrate ICI (B)
       values in the Little Scioto River in 1987 (OEPA  1988) and 1992
       (OEPA 1994)  	7-7

  7-3   Changes in IBI and ICI  scores over distance in the Little Scioto River,
       1992  	7-9

  7-4   A conceptual model of the six candidate causes for the Little Scioto
       stressor identification 	7-12

  7-5   Selected QHEI metrics for  1987 and 1992	7-13

  7-6   Mean PAH concentrations from the sediment (mg/kg) in the Little Scioto
       River 1987-1998	7-15

  7-7   Mean metal concentrations from the sediment(mg/kg) in the Little Scioto
       River 1987-1998	7-17
                                                                                     IX

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                    Stressor Identification Guidance Document
               List of Figures (continued)
Figure                                                          Page

  7-8  Mean water chemistry values from the Little Scioto River from 1987-1998 . 7-18

  7-9  Bile metabolites ((ig/mg protein) measured in white suckers from the
      Little Scioto River in 1992	7-25

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                      Stressor Identification Guidance Document
                            List of Tables
Table                                                                     Page

 ES-1  Summary of the use of Stressor Identification (SI) in water quality
       management programs  	 ES-3

 1-1   The role of SI in various water management programs  	1-6

 3-1   Types of associations between measurements of causes and effects among
       site data and the evidence that may be derived from each	3-4

 3-2   Example associations between site-derived measures of exposure and
       measures of effects from controlled studies for different types of stressors .  . 3-8

 3-3   Example associations between site data and the processes by which
       stressors induce effects	3-9

 3-4   Types of field experiments and the evidence that may be derived from
       each	3-10

 4-1   Application of common types of evidence in eliminating alternatives  	4-5

 4-2   Types of evidence (columns) that contribute to each causal
       consideration (rows)	4-15

 4-3   Format for a table used to  summarize results of an inference concerning
       causation in case-specific ecoepidemiology	4-16

 6-1   Evidence of biological impairment in the Presumpscot River upstream and
       downstream of a pulp and paper mill effluent discharge  	6-5

 6-2   Physical and chemical parameters measured in the Presumpscot River
       upstream and downstream of a pulp and paper mill effluent discharge	6-9

 6-3   Considerations for eliminating candidate causes  	6-12

 6-4   Comparison of TSS loadings in the Presumpscot and Androscoggin
       Rivers  	6-12

 6-5   1996 - 1999 metal concentrations in the pulp and paper mill effluent	6-13

 6-6   Strength of evidence of non-attainment in the Presumpscot River  	6-14

 7-1   Summary of the three impairments that were considered in the Little
       Scioto River  	7-10

 7-2   Spearman rank correlations with selected metrics and the IBI and ICI
       from 1992 and selected PAHs  	7-19
                                                                                    XI

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                             Stressor Identification Guidance Document
                         List of Tables  (continued)
       Table                                                                     Page

        7-3   Spearman rank correlations with selected metrics and the IBI and ICI
              from 1992 and selected metals	7-19

        7-4   Spearman rank correlations with selected metrics and the IBI and ICI
              from 1992 and selected water quality and habitat quality measurements . .  . 7-20

        7-5   Evidence for eliminating candidates causes at Impairments A, B, and C ... 7-21

        7-6   Candidate causes remaining after elimination 	7-28

        7-7   Cumulative toxic units for PAHs and metals based on the PEL values	7-30

        7-8   Comparison of the reported concentration of water quality parameters
              (mg/L) with exceedances  	7-31

        7-9   Strength of evidence analysis for the three candidate causes of
              Impairment A, RM 7.9  	7-32

        7-10  Strength of evidence analysis for the five candidate causes of
              Impairment B, RM 6.5  	7-36

        7-11  Strength of evidence analysis for the three candidate causes of
              Impairment C, RM 5.7  	7-43

        7-12  Causal characterization	7-48

        7-13  Fish metrics for the Little Scioto River 1987 and 1992	7-54

        7-14  Macroinvertebrate metrics for the Little Scioto River 1987 and 1992	7-55

        7-15  QHEI metrics for the Little Scioto River 1987 and 1992	7-56

        7-16  Average concentrations of selected sediment organic compounds (mg/kg)
              in the Little Scioto River, Ohio, by river mile in 1987, 1991, 1992 and
              1998  	7-57

        7-17  Average concentrations (mg/kg) of selected metals in sediment from the
              Little Scioto River, Ohio, by river mile in 1987, 1991, 1992 and 1998	7-61

        7-18  Average concentration of selected water chemistry parameters (mg/L) in
              the Little Scioto River, Ohio, by river mile in 1987, 1992 and 1998	7-63

        7-19  PAH concentrations at nearest upstream location and locations of
              impairments (mg/kg)	7-64

        7-20  Metals concentrations at nearest upstream location and locations of
              impairments (mg/kg)	7-65
XII

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                      Stressor Identification Guidance Document
                           Acronym  List
303(d)        The section of the Clean Water Act that requires a listing by states,
              territories, and authorized tribes of impaired waters, which do not meet
              the water quality standards that states, territories, and authorized tribes
              have set for them, even after point sources of pollution have installed the
              minimum required levels of pollution control technology.

305(b)        The section of the Clean Water Act that requires EPA to assemble and
              submit a report to Congress on the condition of all water bodies across
              the Country as determined by a biennial collection of data and other
              information by States and Tribes.

7Q10         Lowest average 7 consecutive days flow with average recurrence
              frequency of once every 10 years

BAP          Benzo[a]pyrene

BOD         Biological Oxygen Demand

CERCLA     Comprehensive Environmental Response, Compensation, and Liability
              Act

COD         Chemical Oxygen Demand

CSOs         Combined Sewer Outfalls

CWA         Clean Water Act

DELTA       Deformities, Erosions, Lesions, Tumors, and Anomalies

DDT         Dichlorodiphenyltrichloroethane

DNR         Department of Natural Resources

DO           Dissolved Oxygen

DQA         Data Quality Assessment

DQO         Data Quality Objectives

ECBP        Eastern Cornbelt Plains

EMAP        Environmental Monitoring and Assessment Program

EPA          U.S. Environmental Protection Agency

EPT          Ephemeroptera-Plecoptera-Tricoptera

EROD        Ethoxy Resorufin[o]deethylase
                                                                                  xin

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                             Stressor Identification Guidance Document
       FACA        Federal Advisory Committee Act




       GIS          Geographic Information System




       IBI           Index of Biotic Integrity




       ICI           Invertebrate Community Index




       IFIM         Instream Flow and Incremental Methodology




       KBI          Kansas Biotic Index




       KDHE        Kansas Department of Environmental Protection




       MBI          Macroinvertebrate Biotic Index




       MIWB        Modified Index of Weil-Being




       MWH        Modified Warmwater Habitat




       NA           Not Applicable/Available




       NAPH        Naphthalene




       NE           No Evidence




       ND           Not Detected




       NEP          National Estuaries Program




       NIH          National Institute of Health




       NOX          Nitrites




       NPDES       National Pollution Discharge Elimination Act




       NFS          Non-point Source




       NRC          National Research Council




       OEPA        Ohio Environmental Protection Agency




       PAHs         Polycyclic Aromatic Hydrocarbons




       PEL          Probable Effect Level




       PO4          Ortho-phosphate




       POTWs       Publicly Owned Treatment Works




       QHEI         Qualitative Habitat Evaluation Index
xiv

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                      Stressor Identification Guidance Document
RM          River Mile




SECs         Sediment Effect Concentrations




SEP          Supplemental Environmental Protection




SI            Stressor Identification




TEL          Threshold Effect Level




TKN         Total Kjeldahl Nitrogen




TMDL        Total Maximum Daily Load




TP           Total Phosphorus




TIE          Toxicity Identification Evaluation




TRE          Toxicity Reduction Evaluation




TSS          Total Suspended Solids




USEPA       U.S. Environmental Protection Agency




WET         Whole Effluent Toxicity




WWH        Warm Water Habitat




WWTP       Waste Water Treatment Plant
                                                                                     xv

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                             Stressor Identification Guidance Document
 Executive Summary
                                            In this Summary:
                                            ES.1   The Clean Water Act, Biological
                                                   Integrity, and Stressor Identification
                                            ES.2   Intended Audience
                                            ES.3   Application of the SI Process
                                            ES.4   Document Overview
       ES.1  The Clean Water Act, Biological
              Integrity, and Stressor
              Identification
       Since the inception of the Clean Water Act (CWA) in 1972, the rivers, lakes, estuaries,
       and wetlands of the United States have indeed become cleaner.  The standard for
       measuring these improvements are both chemical and biological. Yet, we know that
       many waterbodies still fail to meet the goal of the Clean Water Act - to maintain the
       chemical, physical and biological integrity of the nation's waters.
                                                                   The ability to accurately
                                                                     identify stressors and
                                                                      defend the evidence
                                                                          supporting those
                                                                  findings is a critical step
                                                                  in developing strategies
                                                                      that will improve the
                                                                          quality of aquatic
                                                                                 resources.
Biological assessments have become increasingly important
tools for managing water quality to meet the goals of the
CWA. These methods, which use measurements of aquatic
biological communities, are particularly important for
evaluating the impacts of chemicals for which there are no
water quality standards, and for non-chemical stressors such
as flow alteration, siltation, and invasive species. However,
although biological assessments are critical tools for detecting
impairment, they do not identify the cause or causes of the
impairment.

The Office of Water and Office of Research and
Development of the US EPA have developed a process for
identifying any type of Stressor or combination of stressors
that cause biological impairment.  The Stressor Identification
(SI) Guidance is intended to lead water resource managers
through a formal  and rigorous process that
           *•  identifies stressors causing biological impairment in aquatic ecosystems, and

           +  provides a structure for organizing the scientific evidence supporting the
              conclusions.

       The ability to accurately identify stressors and defend the evidence supporting those
       findings is a critical step in developing strategies that will improve the quality of aquatic
       resources.

       The Stressor Identification process (SI) is prompted by biological assessment data
       indicating that a biological impairment has occurred.  The general SI process entails
       critically reviewing available information, forming possible Stressor scenarios that might
       explain the impairment, analyzing those scenarios, and producing conclusions about
       which stressor or stressors are causing the impairment. The SI process is iterative,
       usually beginning with a retrospective analysis of available data. The accuracy of the
       identification depends on the quality of data and other information used in the SI
       process.  In some cases, additional data collection may be necessary to accurately
       identify the stressor(s). The conclusions can be translated into management actions and
       the effectiveness of those management actions can be monitored.
Executive Summary
                                                                                  ES-1

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                              Stressor Identification Guidance Document
       ES.2   Intended Audience

       This guidance should prove useful to anyone involved in managing impaired aquatic
       ecosystems. The results of Stressor Identification investigations are valuable to many
                                types of environmental managers— including land-use
                                planners, industrial and municipal dischargers, reclamation
 Although the Stressor       companies, and any individuals or organizations involved in
 ,,,.,.,.            .      activities that directly or indirectly affect water quality or
 Identification process ,s     aquatic habitatg
 scientifically rigorous, it
 .                              The process of stressor identification draws upon abroad
 is flexible enough to         yariety of disciplines and is most effective when the SI
 support various water       investigator has input from professionals in a number of
                                environmental areas such as aquatic ecology, biology,
       "                        geology, geomorphology, statistics, chemistry, environmental
 requirements.                risk assessment, and toxicology. Sophisticated knowledge in
	   certain fields may increase the tools available to investigators
                                (e.g., physiological responses to certain stressors), but the SI
       process also can be used by investigators with very general tools (e.g., fish population
       estimates). Results of general measures, however, may not be as precise as when more
       specialized measures are used (e.g., stomach-lining histological evaluations).

       ES.3   Applications of the SI Process

       Although the Stressor Identification process is scientifically rigorous, it is flexible
       enough to support various water management requirements. Some potential applications
       of the SI process include the following:

           *•   Characterizing the Quality of the Nation's Waters:  Stressor Identification
               procedures can assist states in more accurately identifying the causes of
               biological impairment in 305(b) reporting.

           >   Identifying Waterbodies and Wetlands that Exceed Water Quality
               Standards: Accurate, reliable stressor identification procedures are necessary
               for EPA and the states/tribes to accurately identify the cause(s) of water quality
               standards violations for 303(d) listing and Total Maximum Daily Load (TMDL)
               calculations. The SI process can help achieve higher degrees of accuracy and
               reliability in identifying pollutants causing impacts.  The SI process is not
               designed, however, to allocate the amount of responsibility for an impact to  a
               particular source, especially when multiple sources of a stressor are present.

           *•   Regulatory and Non-Regulatory Pollution Management Programs: Stressor
               identification procedures can help identify different types of stressors within a
               watershed that are contributing to  biological impairment. Stressors can then be
               prioritized and controlled through a combination of voluntary and mandatory
               programs.

       Other types of programs in which the SI process is useful include: State/Local Watershed
       Management Programs, National Pollutant Discharge Elimination System (NPDES)
       Permitting Programs, Dredge and Fill Permitting, Compliance and Enforcement Actions,
       Risk Assessments, Preservation and Restoration Programs, and Control Effectiveness
       Assessments.


ES-2                                                            U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       If a legal challenge to the conclusions drawn is possible, or if costly remediation efforts
       are indicated as the means to control a stressor, it is essential to have a high level of
       confidence in the accuracy of the identification.  However, because requirements for
       confidence levels and stressor precision can vary with the intended use of the findings,
       managers also require flexibility in evaluation systems. Table ES.l summarizes various
       levels of rigor required in eight water quality management programs where the SI
       process can be applied.
        Table ES.L Summary of the use of Stressor Identification (SI) in water quality
        management programs.
Water Program
305(b) Water
Quality Reports
303(d) Impaired
Waterbody Lists
319 Non-point
Source Control
402 Point Source
Permitting
316(b) Cooling
Water Intake
Permitting
401 Water Quality
Certifications
404 Wetlands
Permitting
Water
Enforcement
Type of Program
Advisory
•

•





Regulatory

•

•
•
•
•

Enforcement



•
•

•
•
Level of Rigor Needed for SI
Low
•

•





Medium
•

•

•
•
•

High

•

•



•
ID Source
•
•
•
•
•

•
•
        ES.4   Document Overview

        The SI guidance document describes the organization and analysis of available evidence
        to determine the cause of biological impairment. The document does not directly
        address biological assessment, impairment detection, source allocation, management
        actions, or data collection, although these  activities interact with SI in significant ways.
        This document is intended to guide water  resource managers through the Stressor
        Identification process.

        Section One:   The Stressor Identification Process
        Introduces SI process and provides detailed guidance on implementing a stressor
        identification program. The guidance applies principles of ecoepidemiology to
        evaluating causes of biological impairment at specific locations.

           Chapter 1:  Introduction to the SI Process
           Provides the background and justification for the SI process.
Executive Summary
ES-3

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                              Stressor Identification Guidance Document
           Chapter 2:  Listing Candidate Causes
           Provides an overview of and guidance on the first step of the SI process, listing
           candidate causes for the impairment.

           Chapter 3:  Analyzing Evidence
           Provides an overview of and guidance on the second step of the SI process,
           analyzing new and previously existing data to generate evidence.

           Chapter 4:  Characterizing Causes
           Provides an overview of and guidance on the third step of the SI process, using the
           evidence from Step 2 to draw conclusions about the stressors that are most likely to
           have caused the impairment.

           Chapter 5:  Iteration Options
           Provides options for stressor identification if no clear cause is found in the first
           iteration.

       Section Two:   Case Studies
       Provides two case studies illustrating the SI process.

           Chapter 6:  Presumpscot River, Maine

           Chapter 7:  Little Scioto River, Ohio

       Appendix A:   Overview of Water Management Programs Supported by the SI
                      Process

       Appendix B:   Worksheet Model

       Appendix C:   Glossary of Terms

       Appendix D:   Literature Cited
ES-4                                                           U.S. Environmental Protection Agency

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                             Stressor Identification Guidance Document
 Chapter 1:
 Introduction to the Stressor
 Identification  (SI) Process
                                     In this Chapter:
                                     1.1     Introduction
                                     1.2     Scope of this Guidance
                                     1.3     Data Quality Issues
                                     1.4     Overview of the SI Process
                                     1.5     Use of the SI Process in Water
                                            Quality Management Programs
       1.1    Introduction

       The use of biological assessments and biocriteria in state and tribal water quality
       standards programs is atop priority of the U.S. Environmental Protection Agency (EPA).
       As such, one of the agency's objectives is to ensure that all States and Tribes develop
       water quality standards and programs that
                                                                         SI is an invaluable
                                                                         component of any
                                                                 bioassessment/biocriteria
                                                                   program concerned with
                                                                   protecting the biological
                                                                         integrity of aquatic
                                                                               ecosystems.
use bioassessment information to evaluate the
condition of aquatic life in all waterbodies,

establish biologically-based aquatic life use
designations,

protect aquatic life use standards with narrative or
numeric biocriteria (see box below),

regulate pollution sources,

assess the effectiveness of water quality
management efforts, and

communicate the condition of their waters.
       Although bioassessments are useful for identifying biological impairments, they do not
       identify the causes of impairments. Linking biological effects with their causes is
       particularly complex when multiple stressors impact a waterbody. Investigation
       procedures are needed that can successfully identify the stressor(s) and lead to
       appropriate corrective measures through habitat restoration, point and non-point source
       controls, or invasive species control. Water management programs have historically
       shown that aquatic life protection is best accomplished using integrated information from
       various sources. For example, the whole effluent toxicity program has utilized methods
       for more than a decade that help resource managers understand and control the toxicity
                          Defining Terms- Aquatic Life Use and Biocriteria

        Aquatic Life Use is a beneficial use designation, identified by a state, in which a waterbody
        provides suitable habitat for the survival and reproduction of desirable fish, shellfish, and other
        aquatic organisms.  Beneficial Use Designation is a management objective defining desirable
        uses that water quality should support. Examples include drinking water supply, primary
        contact recreation (swimming), and aquatic life use.

        Biocriteria are narrative expressions (qualitative) or numeric values (quantitative) describing
        the biological characteristics of aquatic communities based on appropriate reference
        conditions.
Chapter 1: Introduction to the Stressor Identification (SI) Process
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                              Stressor Identification Guidance Document
       of complex effluents.  Similarly, the Stressor Identification process will enable water
       resource managers to better understand and control stressors affecting aquatic biota.  SI
       is an invaluable component of any bioassessment/biocriteria program concerned with
       protecting the biological integrity of aquatic ecosystems.

       1.2     Scope of this Guidance

       The SI guidance covers the organization and analysis of available evidence to determine
       the cause of biological impairment. It does not directly address biological assessment,
	   reference condition, impairment detection, source allocation,
  ,.,   „.               .        management actions, data collection, or stakeholder
  The SI process may be           ,      .   ..,   '    ,      .. ...'  .  .    .   ... CT.
                                involvement- although these activities interact with SI in
  applied to any level of       significant ways. After stressors are identified, the
  ...   .  .       ...         appropriate management actions depend on the nature of
  biological organization       JT    +          A     ^   f  +    •   i A-
                                those stressors, and on other factors- including economics.
  (e.g., individuals,            Identifying appropriate management actions is beyond the
       .  ,.                      scope of this document, but examples of management actions
  populations,                   F  ,  ,  ,.   .,     '   ,.   ,    .,   ,.  «°  .    , „  f
                                are included in the case studies described in Chapters 6-7 or
  communities) and to any    this  document.
 type of waterbody (e.g.,      ,,      +u j    •+*•                  +            TJ
                                Many methods exist tor measuring impacts, exposure, land-
 freshwater streams,          use, habitat changes and other parameters that are important
    ,    .       ...           pieces of evidence in an SI investigation. Descriptions of
 estuaries, wetlands,          r!       .,,     ,     ,.,      &   -.,.    .,F     ~  CT
                                those methods are beyond  the scope or this guidance.  I he SI
 etc.).                          guidance, however, relies on the proper use of many tools to
	   collect evidence.  EPA recognizes the need for a tools
                                compendium as well as software to help organize evidence, to
       make use of available databases and technical publications and to prompt proper
       collection of additional data when needed. The SI process should be viewed as a "logic
       backbone" in determining the cause of impacts to aquatic biota.

       1.3     Data Quality  Issues

       The SI process is a procedure for analyzing available  evidence and determining if the
       available evidence is adequate to draw a conclusion about the causes of impairment.
       Since evidence may be  collected from a variety of sources using a variety of tools, proper
       documentation of the data is critical. Each technique  for collecting data has associated
       quality control measures. The higher the quality of data analyzed, the better the chances
       will be of correctly identifying  stressors.  Guidance on assessing data quality and making
       use of various types of data may be found in the Comprehensive  State Water Quality
       Assessment (305b) guidelines (USEPA 1997) and Ecological Risk Assessment
       guidelines (USEPA 1998a, also Chapter 3).  Data of unknown or poor quality can
       sometimes be used for very rough estimates if the  goals of the study allow, but, in
       general, the quality of all data should be acceptable and well documented.  If the
       available data are not adequate, the SI process can show where data are missing or
       deficient, but it does not address designing new data collection efforts. Chapter 2,
       however, does provide advice on quality control when new data are collected.

       After stressors are identified, the appropriate management actions depend on the nature
       of those stressors and on other factors, including economics.  Evaluating whether Stressor
       controls have allowed biological recovery is  critically important in verifying that the
       stressors were accurately identified.


1 -2                                                            U. S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
        1.4     Overview of the SI Process

        The SI process may be applied to any level of biological organization (e.g., individuals,
        populations, communities) and to any type of waterbody (e.g., freshwater streams,
        estuaries, wetlands, etc.).  Some of the criteria presented for evaluating evidence may be
        specific, however, to a waterbody type (e.g., references to upstream/downstream
        associations).  Similarly, the logic of the SI process may be applied in straightforward,
        single stressor situations or in complex situations with multiple stressors and cumulative
        impacts. Complex situations may require investigators to  refine the definition of the
        study area, gather new data, or do multiple iterations of SI to identify all the important
        stressors. The Little Scioto Case Study (Chapter 7) is given as an example of a complex
        stressor situation where  river segments were analyzed separately because impacts and
        stressors differed at each location.

        1.4.1   The SI Process

        Figure 1-1 provides an overview of the Stressor Identification  process within the context
        of water quality management and data collection. The SI process is initiated by the
        observation of a biological impairment (shown in the topmost  box).  Decision-maker and
        stakeholder involvement is shown along the left-hand side; their involvement is
        particularly important in defining the scope of the investigation and listing candidate
        causes. At any point in the process of identifying stressors, a need for additional data
        may be identified; the acquisition of this data is shown by the box on the right-hand side
        of the diagram. The accurate characterization of the probable  cause allows managers to
        identify appropriate management action to restore or protect biological condition.  Once
        stressors are identified and management actions are in place to control them, the
        effectiveness of the SI process (as demonstrated by improved conditions) can be
        monitored using appropriate monitoring tools and designs.

        The core of the SI process is shown  within the bold line of Figure 1-1 and consists of
        three main steps:

           1.  listing candidate causes of impairment (Chapter 2),

           2.  analyzing new and previously existing  data to generate evidence for each
               candidate cause (Chapter 3), and

           3.  producing a causal characterization using the evidence generated in Step 2 to
               draw conclusions  about the  stressors that are most likely to have caused the
               impairment (Chapter 4).

        The first step in the SI process is to  develop a list of candidate causes, or stressors, that
        will be evaluated. This is  accomplished by carefully describing the effect that is
        prompting the analysis (e.g., unexplained absence of brook trout) and gathering available
        information on the situation and potential causes. Evidence  may come from the case at
        hand, other similar situations, or knowledge of biological processes or mechanisms. The
        outputs of this initial step  are a list of candidate causes and a conceptual model that
        shows cause and effect relationships.
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                              Stressor Identification Guidance Document
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                              Stressor Identification Guidance Document
       The second step, analyzing evidence, involves analyzing the information related to each
       of the potential causes. Virtually everything that is known about an impaired aquatic
       ecosystem is potentially useful in this step.  For example, useful data may come from
       chemical analysis of effluents, organisms, ambient waters, and sediments; toxicity tests
       of effluents, waters, and sediments; necropsies; biotic surveys; habitat analyses;
       hydrologic records; and biomarker analyses. These data do not in themselves, however,
       constitute evidence of causation. The investigator performing the analysis must organize
       the data in terms of associations that could support or refute proposed  causal scenarios.
       Chapter 3 discusses several levels of associations between:

            >  measurements of the candidate causes and responses,

            >  measures of exposure at the site and measures of effects from  laboratory studies

            >  site measurements and intermediate steps in a chain of causal processes, and

            >  cause and effect in deliberate manipulations of field situations or media.

       These associations comprise the body of evidence used to characterize the cause.

       In the third step, characterize causes, the investigator uses the evidence to eliminate, to
       diagnose, and to compare the strength of evidence in order to identify  a probable cause.
       The input information includes a description of the effects to be explained, the  set of
       potential causes, and the evidence relevant to the characterization.  Evidence is brought
       in and analyzed as needed until sufficient confidence in the causal characterization is
       reached.  In straightforward cases, the process may be completed in linear fashion.  In
       more complex cases, the causal characterization may require additional data or analyses,
       and the investigator may iterate the process.

        1.4.2   SI Process Iterations

       The SI process may be iterative, beginning with retrospective
       analysis of available data.  If the stressor is not adequately         Although the SI process
       identified in the first attempt, the SI process continues using              cannot accurately
       better data or testing other suspected stressors.  The process
       repeats until the stressor is successfully identified. The                    identify stressors
       certainty of the identification depends on the quality of              without adequate data,
       information used in the SI process. In some cases, additional
       data collection may be necessary to confidently identify the                completing tne o/
       stressor(s). Although the SI process cannot accurately identify      process is helpful even
       stressors without adequate data, completing the SI process is
       helpful even without adequate  data because the exercise can          witnout adequate aata
       help target future data collection efforts.                             because the exercise
        1.4.3   Using the Results of Stressor Identification              can helP tar9et future
                                                                       data collection efforts.
        Stressor Identification is only one of several activities required   	
        to improve and protect biological condition (Figure 1-1). In
        some cases, the most effective management action will be obvious after the probable
        cause has been identified.  In many cases, however, the investigation must identify
        sources and apportion responsibility among them.  This can be even more difficult than
        identifying the stress in the first place (e.g., quantifying the sources of sediment in a


Chapter 1: Introduction to the Stressor Identification (SI) Process                                        1-5

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                                Stressor Identification Guidance Document
        large watershed), and may require environmental process models.  The identification and
        implementation of management alternatives can also be a complex process that requires
        additional analyses (e.g., economic comparisons, engineering feasibility) and stakeholder
        involvement. Once a management alternative is selected and implemented, monitoring
        its effectiveness can ensure that biological goals are attained, and provides valuable
        feedback to the SI process. All of these important activities are outside the scope of the
        current document. However, accurate and defensible identification of the cause through
        the SI process is the key component that directs management efforts towards solutions
        that have the best chance of improving biological condition.

        1.5     Use of the SI Process in Water Quality Management Programs


        Identifying the cause of biological impairments is an essential element of many water
        quality management programs.  Table  1-1 summarizes the stressor identification needs of
        several water management programs.  An extended discussion of some major regulatory
        programs and their requirements is presented in Appendix A.
         Table 1 -1.  The role of SI in various water management programs.
            Program
          Type/Name
             Purpose
            Role of SI
         305(b)

         Characterizing
         the Quality of
         the Nation's
         Waters
Under section 305(b) of the Clean
Water Act (CWA), states and tribes
are required to assess the general
status of their waterbodies and
identify, in general terms, known or
suspected causes of water quality
impairments, including biological
impairments.
Stressor identification procedures will
assist states and tribes to accurately
identify the causes of biological
impairment. This is a non-regulatory,
information  reporting effort. A high
degree of certainty in identifying the
causes of impairment is not always
needed for 305(b) reports.
         303(d) Listings
         and TMDLs

         Identifying
         Waterbodies
         and Wetlands
         that Exceed
         Water Quality
         Standards
Under section 303(d) of the CWA,
states and tribes are required to
prepare and submit to EPA lists of
specific waterbodies that currently
violate, or have the potential to violate
water quality standards, including
designated uses and numeric or
narrative criteria such as biocriteria.
Wetlands assessment programs are
also being developed and wetlands
may be listed on 303(d) lists.
Accurate, reliable stressor
identification procedures are
necessary for EPA and the
states/tribes to accurately identify the
cause(s) of water quality standards
violations. A high degree of accuracy
and reliability in the stressor
identification process is necessary
and sources will need to be identified.
         State/Local
         Watershed
         Management
         Programs
Managing water resources on a
watershed basis involves examining
the quality of a waterbody relative to
all the stressors within its watershed.
Stressors,  once identified, are
prioritized and controlled through a
combination of voluntary and
mandatory programs, possibly
employing the CWA 402, 319, 404,
401, and other programs.
Stressor identification procedures will
help to identify the different types of
stressors within a watershed that may
be contributing to biological
impairment. A high degree of
certainty in identifying the causes of
impairment is needed.
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                                           U.S. Environmental Protection Agency

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                                  Stressor Identification Guidance Document
          Table 1-1 (continued).  The role of SI in various water management programs.
            Program
           Type/Name
             Purpose
             Role of SI
          319 Non-point
          Source Control
          Program
The 319 Program is a voluntary,
advisory program under which the
states develop plans for controlling
the impacts of non-point source runoff
using guidance and information about
different types of non-point source
pollution.
Stressor identification procedures will
help to identify the different types of
non-point sources within a watershed
that may be contributing to biological
impairment. A high degree of
certainty in identifying the causes of
impairment is not always needed.
          NPDES Permit
          Program
Under Section 402 of the CWA, it is
illegal to discharge pollutants to
waters of the United States from any
"point source" (a discrete
conveyance) unless authorized by a
National Pollutant Discharge
Elimination System permit  issued by
either the states or EPA. NPDES
permits are required whenever a
discharge is found to be causing a
violation of water quality, including
biological impairment.
Accurate stressor identification can
be very critical in NPDES permitting
cases, both for fairness and success
in stressor control. The SI process
can help to determine if the discharge
is the cause of biological impairment.
This is especially important when site-
specific modifications of state
standards or national criteria are
used. A high degree of accuracy and
reliability  in the stressor identification
process is necessary and sources will
need to be identified. The SI process
is not designed to allocate the amount
of responsibility for an impact when
multiple sources for a stressor are
present.
          316(b) Cooling
          Water Intake
          Program
Under Section 316(b) of the CWA,
any NPDES permitted discharger
which also intakes cooling water must
not cause an adverse environmental
impact to the waterbody.
To determine if a cooling water intake
structure is causing adverse
environmental impacts to the
waterbody, the overall health of the
waterbody should be known.  Where
biological impairments are found,
stressor identification procedures
should be used to identify the different
stressors causing the waterbody to be
impaired, including the intake
structure.  A high degree of certainty
is needed.
          401 Water
          Quality
          Certifications
Under Section 401 of the CWA,
different types of federal permitting
activities (such as wetlands dredge
and fill permitting) require a
certification that there will be no
adverse impact on water quality as a
result of the activity. This certification
process is the 401  Water Quality
Certification.
Stressor identification procedures will
help to identify the different types of
stress an activity may place on water
quality that can then be addressed
through conditions in the 401
Certification.
Chapter 1: Introduction to the Stressor Identification (SI) Process
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                                 Stressor Identification Guidance Document
         Table 1-1 (continued). The role of SI in various water management programs.
            Program
           Type/Name
             Purpose
             Role of SI
         Wetlands
         Permitting
Under Section 404 of the CWA, the
discharge of dredge and fill materials
into a wetland is illegal unless
authorized by a 404 Permit.  The 404
Permit must receive a 401 Water
Quality Certification.
Stressor identification procedures
may help to identify unanticipated
stress from a dredge and fill activity
on water quality or the biological
community after the activity is
underway. Stressor identification
procedures will also help in pre-
permitting evaluations of the potential
impacts of 404 permitting by
assessing different potential stressors
on the wetland in advance.
         Compliance
         and
         Enforcement
Whenever an enforcement action is
taken by a regulatory authority, the
type of pollution, the source, and
other stressors that play a role in
causing the violation need to be
clearly identified and related to the
violating source.
Stressor identification procedures
must be able to clearly identify the
different types of pollution causing the
violation with a high degree of
confidence.  Legal defensibility is
required. Identifying the source with a
high degree of confidence is also
needed, though the current SI
process does not provide that
guidance.
         Risk
         Assessments
Results of bioassessment studies can
be used in watershed ecological risk
assessments to predict risk from
specific stressors and anticipate the
success of management actions.
Accurate stressor identification is an
integral part of this process and can
help ensure that management actions
are properly targeted and efficient in
producing the desired results.
         Wetlands
         Assessments
States are beginning to develop
wetlands assessment procedures.  In
the future, wetlands protection is
expected to be increasingly
incorporated into state water quality
standards.
Stressor identification procedures, as
well as future tools specific to wetland
investigations, are very much needed
by wetlands managers. The biological
assessment methods will allow
resource managers to evaluate the
condition of wetlands and may
provide some indication of the type of
stressor damaging a wetland.  Once
bioassessment methods are
completed and incorporated into
monitoring programs, wetlands may
be listed on 305(b) lists as impaired
due to biological impairment. The SI
process should help identify stressors
causing biological impairment so
resource managers can better
remedy the problems.
1-8
                                              U.S. Environmental Protection Agency

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                                 Stressor Identification Guidance Document
         Table 1-1 (continued).  The role of SI in various water management programs.
            Program
           Type/Name
             Purpose
            Role of SI
          Preservation
          Programs
The National Estuary Program (NEP)
was established in 1987 by
amendments to the Clean Water Act
to identify, restore, and protect
nationally significant estuaries of the
United States.  The program focuses
on improving water quality in an
estuary, and on maintaining the
integrity of the whole system -its
chemical, physical,  and biological
properties-as well as its economic,
recreational, and aesthetic values.
Stressor identification procedures
should be useful to the NEP, and
other preservation programs, by
helping stakeholders identify causes
of impairments. This information
would feed into the development of a
management plan.
          Restoration
          Programs
The Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA), commonly
known as Superfund, was enacted in
1980 (and amended in 1986) for
hazardous waste cleanup.
As in enforcement and compliance
programs, stressor identification
procedures must be able to clearly
identify the different types of pollution
causing the impairment with a high
degree of confidence.  Legal
defensibility is required. Identifying
the source with a high degree of
confidence is also needed, though the
current SI process does not provide
that guidance.
          Pollution
          Control
          Effectiveness
A key component of any pollution
control program or watershed
management effort is the ability to
ascertain (or predict) the likely
effectiveness of pollution control
measures or management strategies.
Stressor identification procedures will
help to identify the different types of
pollution a control measure needs to
reduce and the different types of
stressors a management strategy
needs to address.
Chapter 1: Introduction to the Stressor Identification (SI) Process
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                              Stressor Identification Guidance Document
 Chapter 2
 Listing Candidate  Causes
       2.1     Introduction

       The first step in the stressor identification
       process is to develop the list of candidate
       causes, or stressors. This is accomplished by
       carefully describing the effect that is
       prompting the analysis, and gathering
       available information on the situation and
       potential causes (see the box below for
       definitions of some key terms).  Potential
       causes are evaluated and those that are
       sufficiently credible are retained as candidate
       causes used in the analysis stage. The outputs
       of this initial  step are a list of candidate causes
       and a conceptual model that shows the
       relationship between the causes and the effect.
In this Chapter:
2.1  Introduction
2.2 Describe the Impairment
2.3 Define the Scope of the Investigation
2.4 Make the List
2.5 Develop Conceptual Models
s
tressor IdentificatiofK /
LIST CANDIDATE CAUSES
4 L
ANALYZE EVIDENCE
3 C
CHARACTERIZE CAUSES
Eliminate Diagnose Strength of Evidence
1 1 1
Identify Probable Cause

                        Defining Terms - Exposures, Effects, Causes, Sources

        An effect is a biological change traceable to a cause.

        Exposure is the co-occurrence or contact of a stressor with the biological resource.

        A cause is defined as a stressor that occurs at an intensity, duration, and frequency of exposure
        that results in a change in the ecological condition.

        A source is the origin of a stressor.  It is an entity or action that releases or imposes a stressor
        into the waterbody.

        note: the processes of detecting impairment and identifying sources are beyond the scope of
        this document
       2.2     Describe the Impairment

       The first important piece of information to be documented is a careful description of the
       effect that prompted the evaluation.  Whenever possible, the impairment should be
       described in terms of its nature, magnitude, and spatial and temporal extent (see
       worksheet in Appendix B, Unit I, page B-4). Making inferences about causes is easier
       when the impairment is defined in terms of a specific effect, or response. The response
       should be quantified as a count (abundance of darter species) or continuous variable
       (mean length of darters). If multiple effects with different causes are described as a
       single impairment, it may be mistakenly assumed that there is only a single cause.

       The importance of biological entities as resources and as sentinels of the overall integrity
       of ecosystems  is recognized in the Clean Water Act as well as in subsequent legislation
       and regulations (See Chapter 1).  Observations made in streams and rivers can alert
Chapter 2: Listing Candidate Causes
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                              Stressor Identification Guidance Document
       environmental managers or the public to a potential problem. If the biological or
       ecological impairment is of sufficient magnitude, it may necessitate identifying the cause
       and the potential management controls needed to prevent further damage or to restore the
       ecosystem.  Observations that might prompt the initiation of a stressor identification
       investigation include:

           >   kills offish, invertebrates, plants, domestic animals, or wildlife,

           >   anomalies in any life form, such as tumors, lesions, parasites, disease,

           >   altered community structure such as the absence, reduction, or dominance of a
               particular taxon-this can include increased algal blooms, loss of mussels,
               increase of tolerant species, etc.,

           >   loss of species or shifts in abundance,

           >   response of indicators designed to monitor or detect biological, community, or
               ecological condition, such as the Index of Biotic Integrity (IBI) or the
               Invertebrate Community Index (ICI),

           >   changes in the reproductive cycle, population structure, or genetic similarity,

           >   alteration of ecosystem function, such as nutrient cycles, respiration, and
               photosynthetic rates, and

           >   alteration of the aerial extent and pattern of different ecosystems: for example,
               shrinking wetlands, change in the mosaic of open water, wet meadows, sandbars
               and riparian shrubs and trees.

       It can be important to describe how the observed condition makes the waterbody unfit for
       its intended use. This makes the purpose and relative importance of the assessment
       clear.  For instance, if the fish are covered with lesions, no one wants to fish for them.

       In addition to describing the impairment, it is useful to prepare a background statement
       articulating the steps taken that  revealed the biological impairment.  For example, it
       might be appropriate to refer to  a numerical or narrative biocriterion, or a reference
       condition that has been created  for this type of waterbody, including the documentation
       for its derivation.

       If conditions are below expectations, it is important to discuss how the quality or
       condition of the stream compares to other streams, or to the same stream in other places
       or times.  Photographs of the water body provide visual evidence of a lost resource and
       can later be used in describing potential pathways that may have lead to the impairment.
       Equally important are photographs of what the resource could be like (e.g., taken from
       other locations), what it used to be like, or what valued attributes are still retained.

       Maps or other geographical representations that show the location and severity of
       impairments are essential for orienting the investigators, examining spatial relationships,
       and eliciting information from stakeholders (see worksheet in Appendix B, Unit I, page
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                             Stressor Identification Guidance Document
  The scope of the
  investigation determines
  the extent of the data
  sets that will be
  analyzed. It defines the
  geographic area and
  time frame under
  consideration and the
  types of data that will be
  examined.
B-5).  Maps can range from simple hand-drawn to computer-
generated versions. Useful geographic information includes
location of the impairment and known point sources, cities,
roads, dams, tributaries, and land use. Examples of maps are
included in the case studies presented in Section  2 of this
document (Chapters 6 and 7). The depiction of this
geographic information is also used to determine the scope of
the evaluation; that is, the overall spatial and temporal extent
of the study.

2.3    Define the Scope of the Investigation

The scope of the investigation influences the selection of
candidate causes, and has ramifications for the final outcome
and the practical use of the entire stressor identification
effort. In a sense, the scope reflects perceptions about the
ecosystem and beliefs about the level of restoration, or
change, that is possible.
       The scope of the investigation determines the extent of the
       data sets that will be analyzed (see worksheet in Appendix
       B, Unit I, page B-4). It defines the geographic area and time
       frame under consideration as well as the types of data that
       will be examined.  The scope of the investigation may be
       limited or broad. An example of a limited scope is an
       evaluation of whether a particular stressor is responsible for
       an impairment.  A broader objective would be to evaluate
       which, among several candidate causes, could be
       responsible for the observed effect. This broader approach
       might be appropriate for waters that are not attaining their
       designated use, and for which TMDLs (Total Maximum
       Daily Loads; see glossary) must be developed.
                                     Early communication
                                     with the stakeholders
                                      will help ensure that
                                  relevant information has
                                   been identified and that
                                      potential causes are
                                              considered.
       Several factors influence the overall scope of the investigation, including:
                  the regulatory context,
                  the purpose of the investigation,
                  the relative importance of stressors emanating from outside the watershed,
                  stakeholder expectations and interests,
                  logistical constraints,
                  cost,
                  personnel, and
                  available data.
       Other factors to consider are the geographic extent of the impairment, and the extent of
       knowledge about the impairment. Early communication with the stakeholders will help
       ensure that relevant information has been identified, and that potential causes are
       considered.  After these factors are carefully reviewed, a definition of the geographical
       area should be clearly stated. The regulatory context sometimes limits the scope of the
       study. For acid rain regulation, the geographical area is very large, whereas an NPDES
       violation may involve less than a kilometer of stream reach. The investigators should
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                              Stressor Identification Guidance Document
       document any regulatory authorities involved and discuss the regulatory requirement for
       making a causal determination of the impairment.

       The depth of the study may be limited by a paucity of data. In this case, it may still be
       appropriate to attempt a causal determination with the available data, and then indicate
       what additional information is needed to more confidently ascribe the cause.

       2.4    Make the List

       In developing a list of candidate causes, investigators should consider available evidence
       from the case at hand, other similar situations, and knowledge of biological processes or
       mechanisms (see text box entitled "Using Existing Programs to List Candidate Causes"
       and worksheet in Appendix B, Unit I, page B-6).  The causes of ecological condition
       usually involve multiple spatial and temporal scales; both of which must be considered in
       defining the scope of the study and in listing candidate causes.  Recent environmental
       events are overlaid on historical events, even those spanning geological time. Global and
       regional influences form the backdrop for local factors.
                                                                 In some cases, two or more
                                                                 stressors must be present
                                                                 for the effect to occur.
Where multiple stressors contribute to cause an effect, the
stressor that makes the largest contribution is the
principal cause.  Usually a principal cause is so dominant
that removing other causes has no effect on the condition
of the resource.  For example, if benthic habitat is both
physically altered and chemically contaminated, restoring
the  physical habitat may have no effect until the chemical
contamination is removed. In this situation the chemical contamination is the principal
cause.  The habitat alteration is still a cause of impairment, but it is ancillary and masked
by the toxic chemical impact. Nevertheless, pervasive ancillary causes like habitat
alteration, nutrient enrichment, and sediment loading can lower the potential
improvement to the waterbody even after the controlling or principal cause is removed.
                            Finding and Using Existing Lists of Stressors

         Monitoring programs conducted by government agencies and non-governmental organizations
         may identify types and levels of stressors. For example, EPA's Environmental Monitoring and
         Assessment Program (EMAP) has monitored common stressors found in estuarine systems.1
         Among those listed are elevated nutrient concentrations, prolonged phytoplankton blooms, low
         dissolved oxygen, and sediment contamination.

         State agencies and volunteer monitoring programs may also be good sources of information
         on stressors.  Maryland's Department of Natural Resources (DNR), for example, maintains a
         website on which are links to maps indicating long term trends in total  nitrogen, total
         phosphorus, and total suspended  solids for 3rd order and larger streams in the state of
         Maryland.2


         1 See EPA "Condition of the Mid-Atlantic Estuaries." Office of Research and Development,
         Washington, D.C. #600-R-98-147. November, 1998.

         2See Maryland DNR website, http://www.dnr.state.md.us/streams/status trend/index.html
2-4
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       In some cases, two or more stressors must be present for the effect to occur. For
       example, a moderate level of nutrients poses no toxicological threat, but if sparse
       riparian cover permits sufficient sunlight to allow algal growth, then eutrophication can
       occur, with a subsequent cascade of effects. Another example is when a combination of
       reduced stream flow and lack of shading cause an elevation of temperature beyond the
       limit that native species can tolerate. Stressors acting together to cause an effect should
       be listed as a single scenario.

       There are some ways to simplify the process of identifying and listing candidate causes.
       In the beginning, it helps to make a relatively long list and then pare the list down to the
       most  likely causes.  For the initial long list, it is a good idea to include all  stressors
       known to occur in a waterbody.  Even if these stressors have not previously been shown
       to cause this type of impairment, someone is likely to want proof that they were not
       causal agents. Include stressors that stakeholders have good reason to believe may be
       important.  Consult other ecologists for potential causes of the impairment.

       Knowledge about pollution sources near the waterbody can also suggest potential
       stressors. Point sources, such as drainage pipes, outfalls, and ditches are easily identified
       as sources.  Constituents of the effluent can be listed as candidate causes.  Other sources
       may be located some distance from the resource, such as motor vehicles and smoke
       stacks that generate candidate causes such as acid rain or nitrogen enrichment.  Particular
       land uses often generate a consistent suite of stressors.  For example, siltation and
       pesticides are commonly associated with agriculture. Locations of sources and stressors
       should be added to the impairment maps developed in Section 2.2.

       Once an exhaustive list of candidate causes is developed, the next step is to pare the list
       down. Including very unlikely causes can make the identification process unwieldy and
       will distract stakeholders  and managers from the more likely candidates. Unlikely
       stressors are those that are believed to be mechanistically implausible or absent from the
       watershed.  Although they need not be  evaluated, we recommend that you document the
       rationale for not including the less likely causes.

       2.5     Develop Conceptual Models

       The final part of this initial step is to develop conceptual models for the candidate
       causes, linking the  cause with the effect (see worksheet in Appendix B, Unit I, page B-6).
       This part of the process documents a likely explanation of how the stressor could have
       caused the impairment. Conceptual models provide a good way to communicate
       hypotheses and assumptions about how and why effects are occurring.  Models can also
       show where different causes may interact and where additional data collection may
       provide useful information.
 	   Conceptual models will vary in complexity, depending on the
  The conceptual model       mechanisms and ecological processes involved.  A
      .....     ,.   ,       generalized conceptual model might show land uses in the
  can help the investigator    &               F            5         .
                                watershed that generate m-stream stressors impacting valued
  see the pathway             resources. For instance, if fish communities are  impacted by
  ,  ,      ,.        ...  ,        moderate levels  of nutrients in a sunlit stream, it is important
  between the candidate                                                '       ,
                                to show that the effect could have occurred via several
  cause and the eventual      possible pathways, or a combination of pathways, such as:
  impact.
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                              Stressor Identification Guidance Document
           >   decaying algal blooms that result in low dissolved oxygen,

           >   the dominance of prey, causing a change in abundance of species,

           >   conditions favorable for opportunistic pathogens,

           >   diatom-rich water that is so turbid that sight-feeding fish cannot find prey and
               starve, and

           >   embedded substrates smothered with decaying and overgrown algal mats that
               reduce habitat for foraging, refugia, and reproduction.

       The primary causes in this example are nutrients and incident sunlight. The secondary
       cause in the pathway could be any of the stressors that are formed from the initial cause.
       It is usually a good idea to consult with ecologists experienced with similar streams
       when developing conceptual models, especially when complex pathways and ecological
       process are involved.

       Using a pictorial, poster-style conceptual model is useful to introduce the ecological
       relationships. Then a box and arrow diagram can be used to show details of the
       relationships among stressors, receptors, and intermediate processes.  Some  models get
       too complicated to be helpful. The diagram should show only the pathways and causes
       considered in the study.  Separate diagrams for each stressor or pathway can keep the
       focus on the analysis steps that will follow. Figure 2-1 is an example of a box and arrow
       conceptual model illustrating the impacts of logging on salmon production in a forest
       stream. Additional examples and advice on conceptual model development can be found
       in Jorgensen (1994), Suter (1999), Cormier et al. (2000c), USEPA (1998a) (especially
       Appendix C), and in the case studies shown in Chapters 6 and 7.

       In addition to helping the investigators to elucidate the relationships among multiple
       cause and multiple effects, conceptual models are also powerful tools for communicating
       among the investigative team and obtaining additional insights from stakeholders and
       managers.
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                              Stressor Identification Guidance Document

Adult Salmon
I
^ Spawning ^
1
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, + V
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VDisturbancey \DisturbanceJ
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       Figure 2-1. A conceptual model for ecological risk assessment illustrating the effect of
       logging in salmon production in a forest stream. (The assessment includes a series of
       exposures and responses. In the diagram, the circles are stressors, the rectangles are
       states of receptors, and the hexagons are processes of receptors.  The rectangle with
       rounded corners is an intervention, establishment of buffer zones, that is being
       considered (Suteretal. 1994).)
Chapter 2: Listing Candidate Causes
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                              Stressor Identification Guidance Document
 Chapter 3
 Analyzing the Evidence
                                              In this Chapter:
                                              3.1 Introduction
                                              3.2 Associations Between Measurements of
                                                 Candidate Causes and Effects
                                              3.3 Using Effects Data from Elsewhere
                                              3.4 Measurements Associated with the
                                                 Causal Mechanism
                                              3.5 Associations of Effects with Mitigation or
                                                 Manipulation of Causes
                                                   L
                                                   Stressoi\ldentification
                                                              LIST CANDIDATE CAUSES/
                                                                ANALYZE  EVIDENCE
       3.1    Introduction

       The second step in the SI process is to analyze
       the information that is related to each of the
       candidate causes identified in Chapter 2.
       Virtually everything that is known about an
       impaired aquatic ecosystem and about the
       candidate causes of the impairment may be
       useful for inferring causality. Potentially
       useful data that may come from studies of the
       site include chemical analysis of effluents,
       organisms, ambient waters, and sediments;
       toxicity tests of effluents, waters, and
       sediments; necropsies; biotic surveys; habitat
       analyses; hydrologic records; and biomarker
       analyses. A similar array of data may be
       obtained  from other sites and from laboratory
       studies (performed ad hoc or reported in the
       literature). However, these data do not in themselves constitute evidence of causation.
                               The  investigators performing the causal analysis must
	   organize and analyze the data in terms of associations that
 Existing data  are  often      might support or refute proposed causal scenarios.
                                                              CHARACTERIZE CAUSES
                                                                              Strength of Evidence
                                                                  Identify Probable Cause
 sufficient to determine
 the cause of impairment.
                         The SI process does not require a minimum data set, and
                         existing data are often sufficient to determine the cause of
	   impairment.  However, the investigator has the responsibility
                         of evaluating whether the data used are sufficient to support
 the SI process. If the investigator decides to generate additional data, its  quality must be
 assured (see text box entitled "Data Quality Objectives").

 The primary inputs to the analysis step are the list of candidate causes and the associated
 conceptual models that link the causes with the observed effects (developed in Chapter
 2). Other inputs include data and information that come from the case at hand, other
 similar cases,  the laboratory, and the literature that synthesizes biological and ecological
 knowledge (Figure 3-1).  In the analysis step, this information is converted into causal
 evidence that  falls into four general categories of relationships:

        1.   associations between measurements of the candidate causes and effects
            (Section 3.2),

        2.   associations between measures of exposure at the site and measures of
            effects from laboratory studies (Section 3.3),

        3.   associations of site measurements with intermediate steps in a chain of
            causal processes (Section 3.4), and
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                               Stressor Identification Guidance Document
               4.   associations of cause and effect in deliberate manipulations of field
                    situations or media (Section 3.5).

        The evidence produced in the analysis step is used to characterize the cause or causes of
        the observed effect (see Chapter 4).  The analysis and characterization of causes is
        usually done iteratively and interactively, as illustrated by the two-way arrows between
        the analysis and characterization boxes in Figures 1-1 and 3-1.  Evidence is brought in
        and analyzed as needed until there is sufficient confidence in the causal characterization.
        In straightforward cases, the process may be completed in linear fashion.  In more
        complex cases, the causal characterization may require additional data or analyses,  and
        the investigator may repeat the process.
                                       Data Quality Objectives

         If new data will be generated for an SI investigation, consider following U.S. EPA's Data Quality
         Objectives (DQO) process.  The DQO process combines a problem formulation exercise with
         conventional sampling statistics to determine the type, quantity, and quality of data needed to
         make an environmental decision with a  desired probability of error (Quality Management Staff
         1994). The  DQO process is not directly applicable to SI since it is designed to determine the
         probability of exceeding a threshold.  However, using a formal process to define the problem,
         examine information needs, and determine study boundaries is important in planning any
         sampling and analysis program. The criteria for defining an optimum design for an SI study will
         vary depending on the circumstances.  Following sampling and analysis, a Data Quality
         Assessment (DQA) should be performed to determine whether the goals of the DQO process
         have been achieved (Quality Assurance Division 1998).  The EPA's Quality System, including
         requirements for non-EPA organizations, can be found at www.epa.qov/quality/index.html.

         Quality Assurance Division. 1998. Guidance for Data Quality Assessment. EPA QA/G-9, QA97
         Version, or EPA/600/R-96/084. U.S. EPA, Washington, D.C.

         Quality Management Staff. 1994. Guidance for the Data Quality Objectives Process. EPA
         QA/G-4, or EPA/600/R-96/055. U.S. EPA, Washington D.C.
        3.2    Associations Between Measurements of Candidate Causes and
               Effects

        The first type of evidence of causation is associations among measurements of candidate
        causes and effects (Table 3-1). The objective of this analysis is to provide evidence that:

             >    the candidate cause and the effect are observed at the same time or place,

             >    when the candidate cause is not observed, the effect is also not observed, or

             >    the intensity of the causal factor is related to the magnitude of the effect.

        Causal evaluations often begin by examining associations from the case at hand.  For
        example, effects are observed downstream, but not upstream of a candidate cause. These
        associations provide the core of information used for characterizing causes (see
        worksheet in Appendix B, Unit II, page B-7).  Associations may be revealed by plotting
        data on common axes, as shown in Figure 3-2. In this figure, the spatial pattern of a
        toxicity bioassay results are clearly associated with the spatial pattern of a community
        metric.  Causal inference is easier when the stressors and effects are located together (co-
3-2
U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       located) in time and space. Inference becomes more difficult
       as stressors are dispersed over larger scales, occur
       intermittently, or cannot be measured. Inference is also more
       difficult when there is a time lag between exposures. For
       example, if a stressor, such as a diversion of water flow
       prevents salmon from reaching the sea on their out-migration,
       the effect (i.e., destruction of the salmon run) may not be       	
       observed until three years later. In some cases, models may
       be useful for extrapolating inferences from available measurements.
Causal evaluations often
     begin by examining
             associations
  from the case at hand.











































List Candidate Causes

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Associate measurements of candidate causes wit
observed effects

Associate effects with mitigation or manipulation o
causes

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effects data from elsewhere

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mechanism

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Characterize Causes







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       Figure 3-1. The flow of information from data acquisition to the analysis phase of the SI
       process.
Chapter 3: Analyzing the Evidence
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                     Stressor Identification Guidance Document
 Table 3-1. Types of associations between measurements of causes and effects
 among site data and the evidence that may be derived from each.
Type of Association
Spatial co-location
Spatial gradient
Temporal relationship
Temporal gradient
Example Evidence
Effects are occurring at same place as exposure
Effects do not occur where there is no exposure
For candidates with discrete sources on streams and
rivers:
Effects occur downstream of a source
Effects do not occur upstream of a source
For candidates with dispersed sources:
Effects occur where there is exposure, but not at
carefully matched reference sites where exposure
does not occur
Effects decline as exposure declines over space
Exposure precedes effects in time
Effects are occurring simultaneously with exposure
(allowing for response and recovery rates)
Intermittent sources are associated with intermittent
exposure and effects
Effects increase or decline as exposure increases or
declines overtime
      100 i—
       80
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                 •  TOXICITYDATA

                 O  COMMUNITY DATA
       40
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                                3456

                              STREAM STATIONS
8
9
Figure 3-2. Plot of toxicity data from a 7-day subchronic test of ambient waters and a
community metric obtained on a common stream gradient (Norberg-King and Mount
1986).
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                              Stressor Identification Guidance Document
       The evaluation of associations must consider whether potentially affected organisms may
       have moved since exposure. It is helpful to consider the mobility of organisms relative
       to the extent of the observed exposed and unexposed reaches or areas. Clearly, fish are
       capable of swimming long distances and invertebrates may drift downstream or fly
       upstream. However, extensive experience with bioassessment offish and invertebrate
       communities has  demonstrated that the movements of these organisms are usually not so
       great as to prevent the observation of spatial associations.  The movement of a few
       individual organisms from contaminated reaches to upstream reaches will diminish, but
       generally not eliminate, the contrast or gradient among reaches. However, salmon and
       other species that regularly move long distances require special consideration when
       analyzing spatial  associations. In such cases, consider the logic of the situation and
       possibly use a GIS as a platform for modeling spatial relationships.

       Obtaining measurements of the  stressor that can be associated with the effect can be
       challenging. In the most straightforward cases, the
       measurements of the stressor itself are available; for example,
       nutrient concentrations, degree of siltation, dissolved oxygen           In some cases, the
       concentrations, or chemical concentrations. In some cases, the                         .
       candidate cause is the lack of a required resource, such as          canaiaate cause is tne
       nesting habitat. In these cases, measurements can establish that           lack of a required
       the resource is indeed missing at the place and time it would be
       required by an organism. When measurements of the stressor            resource, sucn as
       are not available, surrogates can be used, although the                      nesting habitat
       uncertainty in the analysis will increase. Information on the      	
       location and attributes of sources can be useful surrogates.
       This information can be particularly important for stressors that are intermittent in nature
       (e.g., high flow events), or degrade quickly (e.g., some pesticides). In these cases, source
       information may be used as a surrogate for the stressors. As sources become larger in
       scale and  more diffuse, information on the sources  becomes more difficult to use in site-
       specific causal evaluation.

       Similarly, measuring the immediate or direct response to a stressor increases the
       confidence in a causal evaluation. For example, a fish kill may be associated with
       nutrient enrichment, acting through algal growth, decomposition, and oxygen depletion.
       Measurements of the initial algal growth and oxygen depletion would increase an
       investigator's confidence that nutrient enrichment was the cause of the fish kill.
       Conceptual models are very useful  for illustrating linkages between complex pathways
       of cause and effects, and for illustrating where measurements are (and are not) available.

       Whenever possible, associations should be quantified.  For categorical data, calculate the
       frequencies of associations. For count or continuous data use,  linear or nonlinear
       models. For example, the abundance of Ephemeroptera at a site may be regressed
       against concentration of total sediment PAHs. Similarly, the community data plotted in
       Figure 3-2 might be regressed against the toxicity data.  If effects data are categorical or
       heterogeneous and exposure data are continuous, categorical regression may be used
       (Dourson et al. 1997).  Select the analysis technique that best illuminates the association,
       based on the amounts and types of data available. Some statistical descriptions of the
       associations include correlation coefficients, confidence intervals, and p-values.
       However, avoid statistical hypothesis testing of the  associations (see text box entitled
       "Using Statistics and Statistical Hypothesis Testing for Analyzing Observational Data in
       Stressor Identification"). Because groups are not randomly assigned in a way that
       minimizes the influence of confounding variables, a significant outcome in a hypothesis
       test may be falsely attributed to a candidate cause, when in fact it is due to another
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       factor.  On the other hand, the small sample sizes that are usually seen in these studies
       decrease the ability to statistically discriminate groups, and may lead to mistakenly
       eliminating a true cause.

       Often associations between candidate causes and effects can be improved by identifying
       and isolating confounding factors in either the receptors or the environment. For
       example, the frequency of hepatic neoplasms in fish is associated both with the age
       structure of the fish population and the concentration of PAHs in sediment (Baumann et
       al.1996).  Correction for age offish would increase the consistency and, potentially, the
       biological gradient in the relationship between hepatic neoplasm frequency and industrial
       contaminants. Similarly, a decline in fish species richness is a common measure of
       impairment, but the number of species present generally increases with increasing stream
       size (e.g., OEPA 1988a). Therefore, including a correction for stream size could
       strengthen the association between the degradation and species loss.

       Associations observed from other studies can provide useful supporting information,
       particularly when the specific type  or constellation of effects is consistently observed in
       association with a candidate stressor. Keep in mind that, as evidence, associations
       observed from other sites is not as strong as those observed from the study site.
       Therefore, if associations of effects and potential causes are analyzed at other sites, they
       should be evaluated separately from those at the site of concern.

       3.3    Using Effects Data from  Elsewhere

       Measures of exposure from the case at hand can also be matched with measures of effect
       from other situations. The objective  of this analysis is to provide evidence showing that
       the stressor is present at the study site in sufficient quantity or frequency that the
       investigator would expect to see a particular effect based on effect information from
       laboratory tests, field tests, or exposure-response relationships developed at other sites
       (see worksheet in Appendix B, Unit II, page B-12).  This type of evidence is familiar to
       ecotoxicologists who combine measures of exposure from the study site with measures
       of effect from laboratory tests. For example, concentrations of chemicals measured in
       water may be compared to concentrations that are thresholds for effects in toxicity tests,
       or they may be used in concentration-response models to estimate the frequency or
       magnitude of effects.  When doing these comparisons, the investigator should keep in
       mind that laboratory conditions or organisms may not accurately represent field
       conditions or organisms.

       Equivalent measures of exposure and effects are available for non-chemical stressors
       (Table 3-2). As in toxicological assessments, it is important to choose the most
       applicable high-quality effect measurements. It is also important to ensure that the
       measures of exposure and effects are consistent. For example, long-term field exposures
       are most appropriately compared with chronic test data.  In some cases, exposure-
       response information will not be available for a candidate cause, but will be available for
       an analogous agent, such as an effluent with a structurally similar chemical or an
       introduced species with similar feeding behavior.
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                            Using Statistics and Statistical Hypothesis Testing
                         for Analyzing Observational Data in Stressor Identification

  Statistical techniques are essential tools for summarizing and analyzing environmental measurements for SI.
  Good SI uses a variety of techniques, including descriptive statistics (e.g., means, ranges, variances),
  exploratory statistics (e.g., multivariate correlations), statistical modeling (e.g, exposure-response relationships),
  quality assurance statistics (e.g., accuracy and precision of analyses of duplicates and standard reference
  materials) and comparison of alternative models of candidate causes (e.g., goodness-of-fit or maximum
  likelihood).  However, the use of statistical hypothesis tests is problematic. Statistical hypothesis testing was
  designed for analyzing data from experiments, where treatments are replicated and randomly assigned to
  experimental units that are isolated from one another.  The application  of these tests to data from observational
  studies can result in erroneous conclusions.  In observational studies, treatments are very seldom replicated and
  are never randomly assigned to experimental units.

  If experimental units are  replicated at all, they are  replicated within the  same water body and hence are likely to
  influence one another. As a result,  samples are replicated rather than treatments.  This is known as
  pseudoreplication (Hurlbert  1984).  Finally, the location of a candidate cause is a given, rather than  being
  randomly placed, so it is  likely that candidate causes will co-vary with each other and with important natural
  attributes of the system (e.g., salinity, depth). The following table summarizes several common analytical
  techniques and discusses their use in SI.
            Activity
 Application
      to
observational
  data in SI
                      Comments
   Using summary statistics
   (e.g., mean water
   concentrations, 7Q10 flow
   rates) to summarize
   measurements
Encouraged
Pay attention to the biological or physical relevance of the
summary statistic used.  For example, the mean of chemical
concentrations overtime is often the most relevant (USEPA
1998a). As another example, the bankfull flow event is
considered to be an important determinant of stream
morphology (Rosgen 1996).
   Using statistics to determine
   the probability that two sets
   or samples are drawn from
   the same distribution, or
   that they differ by a
   prescribed amount
Use Caution
Note that this use is not hypothesis testing in that it does not
test a null hypothesis about a treatment (cause).  It simply
tells you the likelihood that differences are due to sampling
variance.  Also, the conventional criteria for statistically
significant differences are not relevant; the differences must
be shown to be biologically significant and the probabilities
must be shown to affect the overall strength of evidence.
Because the sample sizes are often small relative to
variance, the power to detect real differences may be small.
   Using the results of
   statistical hypothesis tests
   to conclude that a candidate
   is (or is not) the cause
Wrong
The assumptions of statistical hypothesis testing are
violated.  In observational studies, replicate treatments
cannot be randomly assigned in a way that minimizes the
influence of confounding variables.  For this reason, a
significant outcome in a hypothesis test may be falsely
attributed to  a candidate cause when in fact it is due to
another factor.
   Using correlations or
   regression techniques to
   quantify relationships
   between variables.
Encouraged
The type of data (continuous, ordinal, or categorical) and the
type of relationship (e.g., linear, non linear) will determine
the best technique to use.
   Using statistics to determine
   the probability that a
   relationship is nonrandom,
   or that the slope of a
   regression differs from zero.
Use Caution
Note that this analysis indicates only the probability that an
apparent relationship is due to sampling variance.  It does
not test the hypothesis that the relationship is causal. Also,
the number of samples is likely to be low, so even
correlations or models that are not statistically significant
can be biologically significant and contribute to the strength
of evidence.
   Concluding that statistically
   significantly correlated
   variables have a causal
   relationship
Wrong
Correlation does not indicate causation, and a highly
improbable regression model does not indicate that the
independent variable caused the relationship.  Because
stressors often covary with each other and with natural
environmental attributes, a strong relationship between a
candidate cause and a biological variable may be due to a
factor other than the candidate cause.
Chapter 3: Analyzing the Evidence
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         Table 3-2.  Example associations between site-derived measures of exposure and
         measures of effects from controlled studies for different types of stressors.
Stressor
Chemical
Effluent
Contaminated
Ambient
Media
Habitat
Water
withdrawal/
drought
Thermal
energy
Siltation
(suspended)
Dissolved
oxygen and
oxygen-
demanding
contaminants
(e.g. BOD,
COD)
Siltation
(bed load)
Excess
mineral
nutrients
Pathogen
Non-
indigenous
invasive
species
Characterization of
Exposure:
Intensity, Time, and Space
External concentration in
medium
Internal concentration in
organism
Biomarker
Dilution of effluent
Location and time of
collection
Analysis of medium
Structural attributes
Hydrograph and associated
summary statistics (e.g.,
7Q10)
Temperature
Suspended concentration
(e.g., TSS)
Dissolved Oxygen
Degree of embeddedness,
texture
Dissolved concentration
Presence or abundance of
pathogen
Presence or abundance of
the species
Characterization of
Exposure-Response
Concentration-response or time-
response relationships from
laboratory or other field studies
Effluent dilution - response in the
laboratory (WET)
Lab or in situ tests using the
medium:
Medium dilution - response
Medium gradient - response
Empirical models (e.g., Habitat
suitability models)
In-stream flow models (e.g., IFIM)
Thermal tolerances
Concentration-Response
relationships from laboratory or other
field studies
Oxygen concentration-response
relationships from laboratory or other
field studies.
Empirical siltation-response
relationships from laboratory or other
field studies.
Empirical concentration-response
relationships from laboratory or other
field studies.
Eutrophication models
Disease, Symptoms
Ecological models (food web,
energetics, predator-prey, etc.)
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                             Stressor Identification Guidance Document
 In developing
 mechanistic conceptual
 models depicting the
 induction of effects, it is
 often apparent that there
 are intermediate steps in
 the causal process that
 may be observed or
 measured.
Laboratory toxicity tests and other controlled studies provide
the bases for models depicting the induction of effects by
particular causes. For example, an acute lethality test of a
chemical provides a concentration-response model which may
be used to determine whether fish kills might be attributable
to observed or estimated ambient concentrations. More
complex causal mechanisms, particularly those involving
indirect causation, require more complex mechanistic models.
As models of causal processes become more complex, it
becomes more difficult to judge whether an individual model
provides an acceptable representation of the  causes of
ecological degradation at a site. In such cases, the best
strategy is to generate mechanistic models of each proposed
causal scenario and determine which model best explains the
site data (Hilborn and Mangel 1997).
       3.4    Measurements Associated with the Causal Mechanism

       In developing mechanistic conceptual models depicting the induction of effects, it is
       often apparent that there are intermediate steps in the causal process that may be
       observed or measured. Documenting those intermediate steps increases confidence in
       the proposed causal mechanism (see worksheet in Appendix B, Unit II, page B-8). This
       type of evidence is particularly useful when the ultimate effects of multiple candidate
       causes are similar, but act through different mechanistic pathways.  Types and examples
       of intermediate steps are presented in Table 3-3.  In some cases it is sufficient to
       document the occurrence of the intermediate step, but in many cases, the level of the
       metric must be shown to be adequate. For example, if competition for prey by an
       introduced species is the proposed mechanism by which an endpoint species has been
       lost, then the investigator should show that the  number of prey are reduced sufficiently.

       Table 3-3. Example associations between site data and the processes by which
       stressors induce effects.
Type of Measurement
Symptoms (i.e., responses
specific to, or characteristic
of, a type of stressor and
causing the overt
impairment)
Biomarkers
Intermediate product of an
ecological process
Changes in abundance of
predators, prey, or
competitors
Example Mechanistic Association
Fish have lesions characteristic of a bacterium
Metalothionine induction is an intermediate step in the
glomerular toxicity of cadmium
Algal abundance and DO are measures of intermediate
steps in the induction offish kill by nutrient additions
Abundance of prey decreases upon introduction of a
new predator
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                             Stressor Identification Guidance Document
        Table 3-3 (continued). Example associations between site data and processes by
        which stressors induce effects.
Type of Measurement
Effects on other receptors
Distributions of stressors
and receptors coincide
Example Mechanistic Association
If impairment is defined in terms of effects on fish, then
the responses of invertebrates or plants may suggest
what causes are operating
For a stressor to cause an effect, it must contact or co-
occur with the receptor organisms. For causes that act
through the deprivation of a resource, the deprivation
must actually occur
       3.5    Associations of Effects with Mitigation or Manipulation of Causes

       Strong causal evidence can be provided by deliberately eliminating or reducing a
       candidate cause and noting whether the effects disappear or remain (see worksheet in
       Appendix B, Unit II, page B-10).  Causes can be eliminated as a part of a field
       experiment or by bringing site media into the laboratory  (Table 3-4). Field experiments
       may also be performed by manipulating the source (see text box entitled "Associating
       Effects with Mitigation or Manipulation of a Cause"). For example, cattle may be
       fenced away from some locations where they usually have access to a stream channel, or
       an effluent may be eliminated for a time due to plant shut-down. These experiments may
       be conducted at the site being assessed, or may be conducted at other sites where the
       same type of source operates. Occasionally, a regulatory or remedial action may be
       treated as an experimental manipulation. Alternatively, experiments may be conducted
       that control the exposure of organisms or communities to potential causes. Examples
       include caging previously unexposed organisms at contaminated locations, placing
       containers of uncontaminated sediments in locations with contaminated water.  These
       field experiments typically cannot be replicated,  so their results are potentially subject to
       confounding (see text box "Using Statistics and Statistical Hypothesis Testing for
       Analyzing Observational Data in Stressor Identification").  Finally, site media can be
       brought into the laboratory and manipulated to eliminate different candidate causes.
       Then the results of the manipulation can be tested using laboratory organisms.  These
       methods have been most extensively developed for the purpose of attributing causality
       among different chemicals in effluents.

       Table 3-4.  Types of field experiments  and the evidence that may be derived from each.
Example Experiment
Manipulation of a source
in the field
Manipulation of exposure
in the field
Laboratory manipulation
and testing of media from
the case
Example Evidence Derived from the Experiment
Elimination of a source reduces or eliminates the effect.
Introduction of previously unexposed organisms results in
effects.
Isolation of organisms from one cause reveals the effects
of others.
Extracting site media into fractions containing different
chemical classes results in toxicity being associated with
only one fraction.
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                      Associating Effects with Mitigation or Manipulation of a Cause

          Biological data collected by the Kansas Department of Health and Environment (KDHE) have
          played an increasingly important role in the state's efforts to document water quality
          impairments. KDHE historically has applied a modification of Davenport and Kelly's (1983)
          macroinvertebrate biotic index (MBI) to identify impairments resulting from nutrient loading and
          organic enrichment. Recently, a genus- and species-level indicator known as the Kansas
          Biotic Index (KBI) was developed to specifically respond to different stressor categories,
          including nutrients and oxygen demanding substances (KBIorg). Data collected by KDHE have
          shown that declines in the MBI and KBIorg have been consistently associated with increased
          organic enrichment, nutrient loading,  and ammonia contamination.

          The MBI and KBIorg were used to document the association between effects and the
          mitigation or manipulation of causes. After a nitrification process was installed at the city of
          Wichita's municipal wastewater treatment facility, median concentrations of total ammonia-
          nitrogen in the Arkansas River decreased from 1.1 mg/L (1982-91) to 0.06 mg/L (1992-99).
          Concomitant decreases in the upper quartile MBI and KBIorg values were sufficiently large to
          justify a formal change in the Arkansas River's  305(b) impairment status.  Moreover, city
          officials documented the recolonization of this river by several rare or previously extirpated fish
          species. Comparable improvements in MBI and KBIorg scores were documented in the Smoky
          Hill River below the city of Salina sewage treatment plant after ammonia levels were reduced
          by implementing wastewater nitrification and an industrial pretreatment initiative.

          Outcome
          In the 2000 KDHE 305(b) assessment, the Smoky Hill River was upgraded from non-supporting
          to fully supporting of aquatic life.

          References
          Davenport, E. and H. Kelly. (1983); Huggins, G. and F. Moffett.  (1988); KDHE. (1993, 1998,
          2000).
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                             Stressor Identification Guidance Document
 Chapter 4
 Characterizing Causes
       4.1    Introduction

       Characterizing causes involves using the
       evidence analyzed in Chapter 3 to reach a
       conclusion and to state the levels of confidence
       in that conclusion.  The input information in
       this process includes a description of the
       effects to be explained, the set of candidate
       causes developed in Chapter 2, and the causal
       evidence analyzed in Chapter 3.

       4.2    Methods for Causal
              Characterization
                                                  In this Chapter:
                                                  4.1  Introduction
                                                  4.2 Methods for Causal Characterization
                                                  4.3 Identify Probable Cause and Evaluate
                                                      Confidence
                                                 Stressor^dentification
T
                                                            LIST CANDIDATE CAUSES
                                                              ANALYZE EVIDENCE
                                                             \              /
                                                             CHARACTERIZE CAUSES
                                                         Eliminate    Diagnose    Strength of Evidence
                                                                Identify Probable Cause
       After available evidence has been compiled and analyzed, the cause(s) may be obvious.
       In other cases, a more systematic method for reaching a conclusion may be needed.  The
       use of clearly documented inferential logic increases the defensibility of causal
       attribution. This chapter describes three methods for using the evidence developed in
       Chapter 3 to characterize the cause: (1) eliminating alternatives, (2) using diagnostic
       protocols, and (3) weighing the strength of evidence supporting each candidate cause.
       Figure 4-1 depicts a procedure that combines these multiple methods to reach a
       conclusion of causality. Although this approach uses a combination of methods for
       characterizing causes, each method may also be used independently.

       This integrated approach does not include all possible methods of causal analysis,
       particularly the use of expert judgment. When evidence is ambiguous, the process of
       developing consensus among a panel of experts may be more acceptable to stakeholders
       than any systematic evaluation of evidence. Utilizing expert judgment is certainly a
       more flexible approach in that it does not require any particular data set or type of model.
       In addition, experts can reach conclusions on the basis of experience and pattern
                               recognition. For example, an experienced extension agent
      	  may visit a farm pond that is not producing bass and, without
                               taking any measurements, know that the pond is too small or
                               receives too much manure runoff from surrounding pastures
                               to support bass reproduction. However, when the issue of
                               causation is contentious, the attempt to develop consensus
                               may be complicated by experts who represent the interests of
                               the contending parties. Even when the experts are  neutral,
                               expert consensus may not be acceptable to some parties due
                               to subjectivity. Finally, the process of developing expert
                               consensus may not be practical. An NIH consensus
                               development conference or an NRC panel may be practical
                               for large-scale issues, such as the carcinogenicity of
       electromagnetic fields.  It may not be practical to convene an expert panel for each
       outfall causing ecological injuries.
Although this approach
uses a combination of
methods for
characterizing causes,
each method may also
be used independently.
Chapter 4: Characterizing Causes
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                Causal
               Evi
                                       List of Candidate Causes
                                       and Conceptual Models

7
1 *
l
Yes
r
Diagnostic
Analysis
        Figure 4-1. A logic for characterizing the causes of ecological injuries at specific sites.
        (Processes are  rectangles, and the three inferential methods have heavy borders.
        Decisions are diamonds, and inputs are parallelograms.)
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CHARACTERIZE CAUSES
E

liminate |


Diagnose




Strength of Ev


Identify Probable Cause



dence

       Inputs to the characterization process (the parallelogram at the top of Figure 4-1) include
       a description of the effects to be explained, the list of candidate causes, and the
       associated conceptual models (Chapter 2). The set of candidate causes should include
       stressors that consist of multiple factors that act together and are not individually
       sufficient to cause the effect (i.e., causal scenarios).  Other inputs to characterization
       include the causal evidence produced in the analysis step (the three parallelograms on the
       left side of Figure 4-1). As discussed above, analyses are usually conducted in
       combination, as needed, throughout the  characterization process. For example, the
       evidence necessary for eliminating candidate causes is analyzed first, then evidence  for
       diagnosis, and, finally if necessary, the strength of evidence for each candidate cause is
       analyzed.

       4.2.1  Eliminating Alternatives
       The causal characterization methods shown in
       Figure 4-1 are presented in order, from the
       most conclusive to the least conclusive. The
       first method, eliminating alternatives, is a
       powerful approach to evaluating information.
       The ability to eliminate all but one alternative
       is a strong standard of proof for causality, and
       it is easily understood and widely practiced.
       It is the basic technique of literature's most
       famous master of inference, Sherlock
       Holmes:
           "When you have eliminated the impossible, whatever remains, however
           improbable, must be the truth."
               — (Sir Arthur Conan Doyle, Sign of Four, 1890).

       Elimination is also an effective way of reducing the numbers of alternatives to be
       considered before using another method (e.g., strength of evidence, Section 4.1.3, and
       see worksheet in Appendix B, Unit III, page B-15).  Eliminating evidence is a
       particularly good option for SI when the set of alternatives is limited, and when disproof
       does not rely on statistics (see text box in Chapter 3 entitled "Using Statistics and
       Statistical Hypothesis Testing for Analyzing Observational Data in Stressor
       Identification"). Specifically, if the SI is conducted to support a permitting action,
       logical elimination of the permitted source as a potential cause of the observed injury is a
       sufficient causal analysis. Because of the complexity associated with ecological systems
       and multiple stressors, many SI investigations will not have the evidence necessary to
       confidently eliminate causes.  These evaluations will rely on a strength of evidence
       analysis (Section 4.1.3).

       Elimination as  a method for establishing causality has strong roots in the philosophy of
       science. Popper, Platt, and other conventional philosophers of science have argued that
       it is logically impossible to prove a hypothesized relationship, but it is possible to
       disprove hypotheses (Platt 1964, Popper 1968).  If a set of possible causes has been
       identified, once all but one alternative has been eliminated, the remaining hypothesis
       must be true. For example, if a body of water is  found to be acidic, it is possible to
       establish the cause as acid deposition by eliminating acid mine drainage, geologic
       sulphate, and biogenic acids as causes (Thornton et al. 1994).
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       The elimination of alternatives has three major limitations:

           >   Due to limited knowledge, it may not be possible to identify a complete set of
               candidate. Also, the array of possible causes is potentially infinite, as there is no
               clear boundary between plausible and absurd hypothetical causes (Susser 1986b,
               Susser 1988).

           >   The process of elimination is limited by the ability to perform reliable tests and
               obtain unambiguous results. Such tests are often difficult in ecology. One may
               fail to reject a hypothesis but be uncertain of that result due to sampling
               variance, biases, and temporal variance.  If all but one cause is rejected on
               uncertain grounds, it is difficult to accept the remaining candidate cause with
               confidence.

           >   Elimination of causes should be done with particular care when multiple
               sufficient causes may be operating.  The evidence for one cause may be so strong
               that it masks the effects of another sufficient cause and appears to be the sole
               cause.  In addition, beware that the temporal sequence of cause and effect may
               appear to be wrong when one sufficient cause precedes another. For example, an
               industrial effluent may impair a biological community. If the stream is
               subsequently channelized, the effects would be obscured by the industrial
               effluent.  The channelization would  have been sufficient to degrade biological
               communities within a pristine stream and therefore should be retained as a
               candidate cause. As shown in Table 4-1, similar issues are also relevant to
               spatial sequences such as those occurring in streams or rivers.

       Most often the objective of SI is to identify all sufficient causes (for example, when the
       goal is to remediate or restore a water body). In these cases, the elimination step should
       be performed iteratively. That is, each cause eliminated during the first round should be
       reevaluated to determine if its effects may have been masked by another cause.  If so, the
       candidate cause should be retained.  In extreme cases, the masked secondary causes will
       remain unidentified, because the primary causes  are so conspicuous. For example, if
       channelization has eliminated nearly all fish, it may not be apparent that episodic
       pesticide runoff would affect sensitive species. Such occult secondary causes will
       become apparent only after the primary causes have been remediated.

       Some types of evidence can be used to eliminate candidate causes, and when those
       causes might be retained because of masking.  Only associations derived from
       measurements taken from the case under evaluation are strong
       enough to eliminate an alternative. Associations derived from                         "   "
       similar cases cannot be used to eliminate alternatives, but are              Only associations
       useful in strength of evidence analyses which allow for                         derived from
       uncertain or indecisive evidence (Section 4.1.3).
                                                                        measurements taken
       A stressor can be confidently eliminated if case-specific               from the case under
       measurements clearly show that a necessary  step in the causal
       chain of events has not occurred. For example, if a chemical          evaluation are strong
       must be taken up by an organism in order to  cause an effect,          enough to eliminate an
       and it can be demonstrated that uptake has not occurred (e.g.,
       though biomarkers or body burdens), the chemical can be                        alternative.
       eliminated  as a cause. Similarly, if sedimentation causes        	
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       effects by silting-in riffles, and riffles can be demonstrated to be free of silt,
       sedimentation can be eliminated as a cause.

       Although another potential way to eliminate a candidate cause is through experimental
       manipulations, the results of field experiments are seldom sufficiently conclusive to
       eliminate a cause. Uncertainties exist in field experiments due to a lack of thorough
       knowledge of recovery and recolonization rates following exposure. As a result,
       reduction or elimination of exposure may not appear to eliminate the effects. Field
       experiment data can, however, be used in the strength of evidence analysis discussed in
       Section 4.1.3. In addition, removal of one sufficient cause may unmask the effects of
       another. The protocols associated with the Toxicity Identification and Evaluation (TIE)
       program can be applied here, but not all effects of concern occur in these tests (e.g.,
       tumors). Further, there may be questions concerning the sensitivity of the 7-day tests and
       test species relative to field durations and species (USEPA 1993a,b).  TIE, therefore, is
       considered as part of the  strength of evidence analysis.
         Table 4-1. Application of common types of evidence in eliminating alternatives.
Type of Evidence
(See Chapter 3)
Associations
between
measurements of
candidate causes
and effects: Did
the stressor
precede the effect
in time?
Associations
between
measurements of
candidate causes
and effects: Is
there an
upstream/
downstream
conjunction of
candidate cause
and effect?
Associations
between
measurements of
candidate causes
and effects: Is
there a reference
site/test site
conjunction of
candidate cause
and effect?
Reason for
Rejection
If the effects
preceded a
candidate cause in
time, it cannot be
the primary cause.

If the effect occurs
upstream of the
candidate cause's
source or does not
occur regularly
downstream (e.g., is
distributed spatially
independently of a
plume, sediment
deposition areas,
etc.), it cannot be
the primary cause.
If a candidate cause
occurs at reference
sites and occurs at
equal or greater
levels, it can be
eliminated.



Masking
Considerations
If the candidate cause
is preceded by both
the effect and another
sufficient cause, its
effects may be
masked, and it should
be retained.
If the candidate cause
is downstream of
another sufficient
cause, its effects may
be masked and it
should be retained.








Causal
Consideration 1
(See Section
4.1.3)
Temporality



Co-occurrence


Co-occurrence







Chapter 4: Characterizing Causes
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         Table 4-1 (continued). Application of common types of evidence in eliminating
         Alternatives.
Type of Evidence
(See Chapter 3)
Associations
between
measurements of
candidate causes
and effects: Is a
decrease in the
magnitude or
proportion of an
effect seen along
a decreasing
gradient of the
stressor?
Measurements
associated with
the causal
mechanism: Has
the stressor co-
occurred with,
contacted, or
entered the
receptor(s)
showing the
effect?








Association of
effects with
mitigation or
manipulation of
causes:
Did effects
continue when a
source or stressor
was removed?
Reason for
Rejection
A constant or
increasing level of
effect with
significantly
decreasing
exposure would
eliminate a cause.
If the candidate
cause never
contacted or co-
occurred with the
receptor organisms,
the cause may be
eliminated. For
appropriate
stressors, if tissue
burdens or other
measures of
exposure are found
not to occur in
affected organisms,
the cause may be
eliminated. For
stressors that act
through a known
chain of events, if a
link in the chain can
be shown to be
missing, the
candidate cause can
be eliminated.
If the effect
continues even after
the stressor is
removed, then the
candidate cause can
be eliminated. This
assumes that there
is no impediment to
recolonization.
Masking
Considerations
If a decreasing
gradient of one
sufficient cause
coincides with an
increasing gradient of
second, recovery from
the first cause may be
obscured.











The effect may also
continue if another
sufficient cause is
present.



Causal
Consideration 1
(See Section
4.1.3)
Biological
Gradient

Complete
Exposure
Pathway










Experiment,
Temporality



           Many of the same types of evidence can also be used in the strength of evidence analysis (see
           Section 4.1.3). This column denotes the corresponding causal consideration used there.
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       In some cases all causes but one will be eliminated, and the part of the process is to
       describe the level of confidence in the characterization. It is often desirable to perform a
       strength of evidence analysis of that cause to demonstrate that it is probable, given all
       available evidence.  If the true cause was not identified as a candidate, it may be possible
       to eliminate all candidate causes. In that case, one must repeat the process of identifying
       candidate causes (Chapter 2). In most cases, the elimination of causes will simply
       narrow the set of candidates, which is always helpful.  Then the process continues to the
       next step, which is the use of diagnostic protocols or keys.

       4.2.2   Diagnostic Protocols or Keys
CHARACTERIZE CAUSES
Eliminate | Diagnose |


Strength of Evi


Identify Probable Cause

dence

       If more than one cause remains after the
       elimination step, the next step is to consider
       whether any of the causes are subject to a
       diagnostic analysis. Whereas the elimination
       step relies on negative evidence (e.g., an
       exposure pathway is not present), diagnostic
       protocols rely on positive evidence (e.g., a
       particular symptom is present).  Diagnostic
       symptoms are also used in the strength of
       evidence analysis (under consistency of
       association and specificity; see Section 4.1.3). The diagnostic protocols referred to here
       have been used and tested sufficiently to be considered authoritative and some have been
       formalized into a set of rules or a key (e.g., Meyer and Barclay 1990).

       In medicine, diagnostic protocols identify a disease by examining its signs and
       symptoms. The diagnostic process requires an understanding of mechanism, so most of
       the evidence comes from measurements associated with the causal mechanism (see
      	   Section 3.4 and worksheet in Appendix B, Unit III, page B-
                                 19). As  in medical practice, diagnostic information in the SI
                                 process comes from the exposed organisms and includes
                                 symptomatology (i.e., signs of the action of the causal agent
                                 on the organisms), measures of internal exposure (e.g.,
                                 isolation of pathogens or analysis of chemicals in
                                 organisms), or measurements of intermediate processes (e.g.,
                                 a depressed pre-dawn dissolved oxygen level).
The diagnostic approach
is a good alternative for
SI when organisms are
available for
examination, when the
                                 The diagnostic approach is a good alternative for SI when
                                 organisms are available for examination, when the candidate
                                 causes are familiar enough that they have made it into the
                                 protocols, and when there is a high degree of specificity in
                                 the cause, the effect, or both.  As an example, protocols for
                                 the investigation offish kills are particularly well established
                                 (e.g., Meyer and Barclay 1990) and consist of collection of
                                 site data concerning candidate causes (e.g., oxygen, pH,
                                 temperature, contaminant levels, and presence of toxic
                                 algae), site data concerning effects (e.g., taxa killed, duration
                                 of event, behavior of live fish), and necropsy results (e.g.,
                                 lesions, pathogens, tissue contamination, or clinical signs
                                 such as blue stomach which indicates molybdenum toxicity).
       Meyer and Barclay (1990) even provide a dichotomous key for determining the causes of
       fish kills.  Since an SI investigation is more likely to examine current biological
candidate causes are
familiar enough that they
have made it into the
protocols, and when
there is a high degree of
specificity in the cause,
the effect, or both.
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                              Stressor Identification Guidance Document
       community compositions that might reflect past chronic exposures rather than the effects
       of acute lethality, the methods for fish kill investigations often are not directly
       applicable. However, a diagnostic approach can potentially be employed.

       Diagnostic tools are well developed for pathogens and to a slightly lesser extent for
       chemicals (e.g., certain bill deformities are diagnostic of exposure to dioxin-like
       compounds) (Gilbertson et al. 1991). Diagnostics are also well developed for a few
       other agents such as low dissolved oxygen (low blood oxygen, gasping at the surface,
       etc.). For many other stressors and for most non-vertebrate aquatic organisms,  reliable
       diagnostics are seldom available. Expert judgment has been used to assign tolerance
       values to taxonomic groups for nutrients and this concept has  been extended to other
       stressor types (Hilsenhoff 1987,  Huggins and Moffet 1988). The utility of using these
       tolerance values in multimetric indices along with some recent statistical analyses
       indicate that the structure offish and invertebrate communities may prove valuable for
       diagnosis (Yoder and Rankin 1995b, Norton et al. 2000).  Although the use of
       multimetric information for diagnosing cause and effect is not yet widely accepted or
       validated, this information can be brought into the strength of evidence analysis
       discussed in the next section.

       4.2.3  Strength of Evidence Analysis

       In many SI cases, the candidate causes  are not identified by elimination or diagnosis, and
       an analysis of the strength of evidence for each of the candidate causes is required (see
       worksheet in Appendix B, Unit III, page B-20).  This analysis organizes information so
       that the evidence that supports, or doesn't
       support, each candidate cause can be easily
       compared and communicated. When there are
       many candidate causes or when evidence is
       ambiguous, strength of evidence analysis is
       more useful than elimination of alternatives
       because it identifies the alternative that is best
       supported by the evidence. Even when a cause
       has been identified by a process  of elimination
       or diagnosis, it is often desirable to complete
       the strength of evidence analysis in order to
CHARACTERIZE CAUSES
Eliminal


e Diagnose




| Strength of Ev


Identify Probable Cause

dence

       organize all of the evidence for the decision makers and stakeholders.

       The strength of evidence analysis discussed in the remainder of this section defines a
       group of causal considerations used to organize the information concerning each
       alternative. Causal considerations are logical categories of evidence that are consistently
       applied to support or refute a hypothesized cause. They are defined in Section 4.2.3.1.
       Section 4.2.3.2 discusses how the types of evidence described in Chapter 3 provide
       information relevant to each consideration. Finally, Section 4.2.3.3 shows how to
       evaluate the strength of each piece of evidence in supporting or refuting a candidate
       cause.

       For the purposes of this approach, we treat Koch's postulates (see text box entitled
       "Koch's Postulates") as a special case of analysis of the strength of evidence. That is,
       for pathogens or chemical contaminants, if Koch's postulates are satisfied, the strength
       of evidence is particularly high.
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        4.2.3.1  Causal Considerations for Strength of Evidence Analysis

        This section describes various causal considerations used for strength of evidence
        analyses. These considerations draw on the work of epidemiologists and ecologists over
        the last 30 years (Fox 1991, Hill  1965, Susser 1986a).
                                           Koch's Postulates

          Koch's postulates combine different lines of evidence in a formal way to provide compelling
          evidence for causation. The approach was originally developed for pathogen-induced
          diseases. It has been adapted for demonstrating that particular toxicants cause human
          diseases (Yerushalmy and Palmer 1959, Hackney and Kinn 1979) or ecological effects
          (Adams 1963, Woodman and Cowling 1987, Suter 1990, Suter 1993), and has been
          recommended for ecological risk assessment (EPA 1998a). The following is an adaptation of
          Koch's postulates for causal inference in ecological epidemiology for effects of pathogens or
          chemicals.

              1.  The injury, dysfunction, or other potential effect of the pathogen or toxicant must be
                  regularly associated with exposure to the pathogen or toxicant in association with any
                 contributory causal factors.
              2.  The pathogen, toxicant, or a specific indicator of exposure must be found in the
                 affected organisms.

              3.  The effects must be seen when healthy organisms are  exposed to the pathogen or
                 toxicant under controlled conditions, and any contributory factors should contribute in
                 the same way during the controlled  exposures.
              4.  The pathogen, toxicant, or a specific indicator of exposure must be found in the
                 experimentally affected organisms.

          The power of Koch's  postulates arises from the way the four types of evidence are combined.
          The requirement of regular association in the field ensures that the association is relevant to
          the field, but, because field observations are uncontrolled, one cannot determine whether the
          association is, in fact, caused by an another  agent that happens to be correlated with the
          proposed cause.  In addition, associations in field data fail to demonstrate the temporal
          sequence between the candidate cause and effect. The requirement that the candidate causal
          agent induce the effect under controlled conditions eliminated the potential for confounding
          and demonstrates  that the cause precedes the effect.  However, the artificial conditions of
          toxicity tests and other experimental studies  means that the demonstrated causal association
          may not be relevant to the field. The second and fourth postulates provide the ties that bind
          the two lines of evidence together. That is, evidence of exposure must be obtained in the field
          and must correspond to the experimental exposure.  This correspondence of the exposure
          metrics makes it highly unlikely that the correspondence of effects in the field  and the
          experiment are coincidental.

          Koch's four postulates were derived for addressing the general issue of whether a stressor
          could be a cause at all (i.e., could DDT cause reproductive failure in birds).  SI investigations
          typically choose among causal scenarios that have already been established as having the
          ability to produce impairment.  For this reason, the emphasis is placed on postulate 2,
          identifying the pathogen, toxicant, or specific indicator of exposure in the affected organisms.
          This case-specific  information is then combined with previously established information
          discussed in postulates 1, 3, and 4.  This approach works best for simple causal agents that
          have a known indicator of exposure.  When causal scenarios have multiple insufficient causes,
          the requirements of regular association and experimental evidence can rarely be met for the
          specific mixture that is encountered in the field situation.  In cases where multiple sufficient
          causes can be assumed to be acting independently, the evidence for each cause can be
          evaluated separately.
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       The first four considerations, co-occurrence, temporality, biological gradient, and
       complete exposure pathway draw primarily on associations that are derived from the case
       itself.  These considerations form the strongest basis for causal inference. The next two
       considerations, consistency of association and experiment can be based either on data
       from the case at hand or may draw from similar situations.  The next four considerations,
       plausibility, specificity, analogy, and predictive performance, combine information from
       the case at hand with experiences from other cases or test situations, or from knowledge
       of biological, physical, and chemical mechanisms. These considerations provide
       corroborative information that can be used to supplement the basic observations of
       association of observed effects and potential causes from the case.  The last two
       considerations, consistency and coherency of evidence, evaluate the  relationships among
       all of the available lines of evidence.

       Each of these causal considerations is discussed below:

             Co-occurrence -  The spatial co-location of the candidate cause and effect.  In SI,
       this consideration is case-specific; for example, effects may be occurring downstream
       but not upstream of an identified source (see text box entitled "Arkansas River Case
       Study"). This consideration should be interpreted with caution when several sufficient
       causes may be present and when the objective of the analysis is to identify all potential
       and contributing causes.  In this situation, the causes occurring the furthest upstream may
       mask the effects of causes occurring later in the downstream sequence.

             Temporality - A cause must always precede its effects. For example, a baseline
       monitoring study showing a productive trout population before a dam was built provides
       some evidence that the dam caused the subsequent population decline. As with co-
       occurrence, this criterion should be applied with caution when several sufficient causes
       may be present and when the objective of the analysis is to  identify all potential and
       contributing causes. In this situation, the causes occurring early in the time sequence
       may mask the effects of causes occurring later.

            Biological Gradient - The effect should increase with increasing exposure. This
       is the classic toxicological requirements that effects must be shown to increase with
       dose. Biological gradient is also applicable to other types of causes  (see text box entitled
       "Arkansas River Case Study").  For example, if fine  substrate texture is believed to cause
       reduced diversity of benthic invertebrates, then diversity should decline along a gradient
       of texture.  In SI, evidence for biological gradient is case-specific. Examples include
       demonstrating recovery of a community downstream of an outfall, or evidence that an
       effect decreases with decreasing concentration of an effluent or with increasing mean
       flow. Investigators should be aware that some stressors elicit non-linear response. For
       example, community diversity can increase at low levels of nutrient enrichment, then
       decline again as enrichment increases. Regression and correlation analyses are common
       tools used to quantify biological gradient; both high slopes  and large correlation
       coefficients increase the strength of evidence.

             Complete Exposure Pathway - The physical course a stressor takes from the
       source to the receptors (e.g., organisms or community) of interest. If the exposure
       pathway is incomplete, the stressor does not reach the receptor, and cannot cause an
       effect. Evidence for a complete exposure pathway is case-specific and may include
       measurements such as body burdens of chemicals, presence of parasites or pathogens, or
       biomarkers of exposure (see text box entitled "Arkansas River Case Study").  For
       stressors that do not leave internal evidence (e.g., siltation), measurements that show the
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        stressor co-occurring in space and time with the receptor may be useful.  For causes that
        induce effects indirectly, observations or measurements of the intermediate products or
        conditions are evidence of a complete exposure pathway (see Chapter 7, Little Scioto
        case study).

              Consistency of Association -  Refers to the repeated observation of the effect and
        candidate cause in different places or times (see text box entitled "Lake Washington
        Case Study"). A consistent association of an effect with a candidate cause is likely to
        indicate true causation.  The case for causation is stronger if the number of instances of
        consistency is greater, if the systems in which consistency is observed are diverse, and if
        the methods of measurement are diverse.  Consistency can be demonstrated using
        evidence from the case at hand, or may draw on evidence from many cases. For
        example, if fish kills repeatedly occur below a particular outfall, there is a consistent
        association over time of those incidents with a candidate cause. Less commonly, a
        particular case may have multiple instances of exposure to an agent spread over space
        rather than time. Consistent association can also be demonstrated across multiple sites
        or cases.  For example, a decrease in benthic arthropod diversity may be consistently
        observed at many different sites having low dissolved oxygen levels.  Consistency of
        association across many sites is seldom demonstrated because the same causal agent
        seldom occurs at multiple sites that are sufficiently similar to demonstrate a consistent
        response.  However, when it is demonstrated,  consistency across  sites is stronger
        evidence for causation than the simple co-occurrence or temporal association of the
        agent with the response in a single case.
                                        Arkansas River Case Study:
                                    Using Strength of Evidence Analysis

         This example highlights strength of evidence evaluations used in the SI process. Specifically, the
         example presents several lines of evidence used to support the hypothesis that heavy metal exposure
         impairs benthic macroinvertebrate communities.

         Several sites in the Arkansas River (CO) were monitored over a 10-year span to examine the effects
         of cadmium (Cd), zinc (Zn), and copper (Cu) on benthic macroinvertebrates. More specifically, metal
         contamination was related to the abundance of heptageniid  mayflies. It was found that heptageniid
         mayflies were abundant upstream of known metal  inputs, and sparse downstream of these inputs,  an
         example of spatial co-occurrence.  In addition, a  complete exposure pathway was evident:
         concentrations of Cd, Cu and Zn were elevated in  benthic invertebrates collected at stations
         downstream of the source. Evidence of a biological gradient was observed using multiple regression
         analysis; the abundance of heptageniid mayflies decreased  with increasing zinc concentrations.

         Evidence from other studies was also available and demonstrated that effects from metals would be
         plausible based on stressor-response relationships observed in the laboratory.  Chronic toxicity
         tests of water collected from the Arkansas using Ceriodaphnia dubia and microcosm tests using
         mayflies established that effects would be expected at the concentrations of Zn, Cu, and Cd measured
         in the Arkansas.

         Evidence from other studies also supported the hypothesis that heavy metal exposures reduce
         abundance of mayflies. Regional Environmental Monitoring and Assessment Program (R-EMAP) data
         from other locations in the Rocky Mountains showed a consistent association between metal
         exposures and reduced abundance of heptageniid mayflies.

         Finally, efforts were undertaken by several agencies to reduce ambient metal concentrations, an
         example of a remedial experiment.  Increases in the abundance of heptageniid mayflies were
         observed at the sites with  greatest metal reduction. Further, little  biological improvement was
         observed where metal levels have remained elevated.

         References:  Clements and Kiffney 1994, Kiffney and Clements 1994a,  Kiffney and Clements 1994b,
         Clements 1994, Clements et al. 2000, Nelson and Roline 1996.
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             Experiment - Refers to the manipulation of a cause by eliminating a source or
       altering exposure (Hill 1965) (see text boxes entitled "Lake Washington Case Study" and
       "Arkansas River Case Study").  Experiments of greatest relevance to SI (see Section 3.3)
       include manipulating and testing site media in the laboratory (e.g., using TIE), and
       conducting field experiments by controlling a source (e.g., fencing cattle) (USEPA
       1991b,  1993a, 1993b). The strongest evidence is case-specific. If evidence from
       experiments conducted on a similar situation is used, the relevance to the case at hand
       should be described.

             Plausibility -  Refers to the degree to which a cause and effect relationship would
       be expected given known facts.  Two types of plausibility are discussed below:

             Mechanism: Given what  is known about the biology, physics, and chemistry of the
             candidate cause, the receiving environment, and the affected organisms, is it
             plausible that the effect resulted from the cause? It is important to distinguish a
             lack of information concerning a mechanism (e.g., the ability of chemical x to
             induce tumors is unknown) from evidence that a mechanism is implausible (e.g.,
             chemical x is not tumorogenic). It is also important to carefully consider whether
             some indirect mechanism may be responsible. For example, increased nutrient
             levels cause algal blooms that decompose and reduce epibenthic oxygen
             concentrations, which in turn decrease invertebrate diversity. If a mechanism is
             known and there is evidence that the mechanism is operating in a specific case, the
             positive evidence is particularly strong.

             Stressor-Response: Given a known relationship between the candidate cause and
             the effect, would effects be expected at the level of stressor seen in the
             environment?  The comparison of environmental concentrations to laboratory-
             derived concentration-response relationships is a common approach used in
             chemical risk assessments. It provides strong evidence of causality if
             concentrations are higher than a level that causes a relevant effect (see Table 3-2)
             (see text box entitled "Arkansas River Case Study").  Note that exceedence of
             water quality criteria or standards does not necessarily imply causation because
             regulatory values are intended to be set at safe levels. Whole effluent toxicity tests
             may be used with dilution models. Although used mostly for chemical stressors, a
             similar approach could also be used for other types of stressors, such as siltation.

             Analogy -  Examines whether the hypothesized relationship between cause and
       effect is similar to any well-established cases.  Hill  (1965) used the criterion of analogy
       to refer specifically to similar causes. For example, a new pesticide with a similar
       structure to another one may induce similar effects. The idea can be extended to other
       types of stressors. For example, an introduced species that has similar natural history
       characteristics to  one that had been previously introduced may have similar impacts on
       the ecological system.
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                                     Lake Washington Case Study1

         Lake Washington, located in Seattle and draining into Puget Sound, first began receiving street
         runoff and raw sewage input from Seattle at the turn of the 20th century. Although the sewer
         outlets were eventually replaced by wastewater treatment plant effluents, the growing human
         population in the surrounding area put increasing demands on the lake.  By 1953, 10
         wastewater treatment plants discharged into Lake Washington. Shortly thereafter, the first
         report describing nutrient loadings in the lake was issued by researchers at the University of
         Washington.

         While the problems associated with eutrophication were not widely recognized by the public at
         the time, a University of Washington professor, W.T. Edmondson, used the concept of
         consistency of association^ make an important observation: the recent discovery of a blue-
         green alga (Oscillatoria rubescens) in Lake Washington coincided with other documented
         cases where water quality had  declined  in  response to nutrient input. The lakes described in
         these reports ranged geographically from Wisconsin to western Europe, yet the highly specific
         occurrence of Oscillatoria was  identified in each case  as an early response to water
         enrichment.  Thus, Edmondson asserted that the water quality in  Lake Washington was
         declining in response to nutrient input, and would continue to decline in predictable ways.

         Edmondson developed a model based on  principles of mass balance and stoichiometry to
         define the quantitative relationships between nutrient levels and algal biomass. He used the
         model to forecast that water quality in Lake Washington would continue to decline in
         predictable ways.  This is an example of predictive performance, since continued monitoring
         confirmed his assertions.

         Outcome
         Edmondson's letters and popular science articles describing the problems of the lake
         successfully brought about public and political support for the  eventual clean-up of Lake
         Washington. Between 1963 and 1968, all 10 wastewater treatment plant discharges were
         diverted out of Lake Washington and sent to a  common collection system that ultimately
         discharged deep within Puget Sound.

         Until the diversions were constructed, water quality had continued to decline as predicted by
         Edmondson, with water transparency  at less than 1  m in 1962. However, in the years following
         the improvements, nutrient levels decreased substantially.   By the 1970s, visibility had reached
         12 m, and the presence of the blue-green  alga  O. rubescens was undetectable. The swift
         recovery of Lake Washington following the removal of nutrient inputs in this field experiment
         left little uncertainty about the true cause of its water quality decline.
         1 Summarized from J. T. Lehman (1986).
              Specificity of Cause - Applicable only if the proposed cause is plausible or if it
        has been consistently associated with the effect. Specific cause-effect relationships are
        more likely to be demonstrated to be causal (see text box "Lake Washington Case
        Study"). If an effect (e.g., hepatic tumors in fish) observed at the site has only one or a
        few known causes (e.g., PAHs), then the occurrence of one of those causes in association
        with the effect is strong evidence  of causation. In the extreme, causation is clear when
        both effects and causes are specific (x causes specific effect y, and y is caused only by x).
        One implication of this consideration is that both effects and causes should be defined as
        specifically as possible in order to increase the specificity of the association.  For
        example, a specific cause such as highly embedded substrate can be more clearly
        associated with identified effects than a general cause like overall poor habitat quality.

              Predictive Performance -  Refers to whether the candidate cause has any initially
        unobserved properties that were predicted to occur. Was that prediction confirmed at the
        site?  The ability to make and confirm predictions is one of the hallmarks of a good
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       scientific process.  For example, if the proposed cause of a fish kill is drift of an
       organophosphate insecticide into a stream, one could make the specific prediction that
       cholinesterase levels would be reduced, or the more general prediction that insects and
       crustaceans would also be killed.  If these predicted conditions are then observed at the
       site, it increases confidence in the causal relationship (see text box entitled "Lake
       Washington Case Study"). Multiple predictions in both the positive and negative
       direction would strengthen this criterion (e.g., plants and protozoa would not be harmed,
       but arthropods would be).

             Consistency of Evidence -  Refers to whether the hypothesized relationship
       between cause and effect is consistent with all available evidences. The  strength of this
       consideration increases with the number of lines of evidence (Yerushalmy and Palmer
       1959).

             Coherence of Evidence - Examines whether a conceptual or mathematical model
       can explain any apparent inconsistencies among the lines of evidence. For example
       metal concentrations at the site may be sufficient to impair reproduction  in fish, and yet
       both juvenile and adult fish occur at the site.  This evidence may be coherent if
       reproduction is not occurring at the site, but juvenile fish re-colonize the site from
       unexposed locations. Another explanation may be that the measured total metal
       concentration is not 100% bioavailable. The strength of these explanations depend on
       the expertise and judgment of the  assessors. It is a weak line of evidence, because of the
       possibility that post hoc explanations are wrong. However, the hypotheses may lead to
       experiments or predictions in future iterations of the causal assessment (e.g., testing the
       bioavailability of the metals), which could support stronger inferences.

       4.2.3.2  Matching Evidence with Causal Considerations

       Table 4-2 illustrates the different types of evidence discussed in Chapter 3 with the
       causal considerations they support. The relationship between types of evidence and
       causal considerations is not one-to-one. Each type of evidence may be relevant to
       several causal considerations, and a causal consideration may be evaluated using several
       different types of evidence.  In any specific application of SI,  evidence will probably
       exist for only some of the causal considerations, and the evidence will be uneven across
       the candidate causes. After the evidence relevant to each consideration is identified, it is
       evaluated as discussed  in the next section.

       4.2.3.3  Weighing Causal Considerations

       Epidemiologists and ecoepidemiologists have attempted to develop guidance for
       weighing the causal considerations described below (Fox 1991, Hill 1965, Susser
       1986a).  Table 4-3 presents the possible outcomes for each consideration and provides
       symbols to represent the influence of each outcome on the inference.

       Table 4-3 illustrates a format that  can be applied to specific SI cases. In  this table, the
       causal considerations are listed in the left-hand column. Each of the other columns
       presents results for a candidate cause.  The rows show the appropriate number of+, -, or
       0 symbols associated with the strength of evidence for each consideration evaluated for
       each candidate cause. Supporting narratives should describe how the scores were
       obtained from the evidence.  We do not recommend adding up the scores for each
       candidate cause. Adding the scores erroneously implies that each consideration is of
       equal importance and is equitable only if the same types of evidence are  available across
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        all candidates. In difficult cases, it may be valuable to compare the evidence for each
        individual consideration across the candidate causes. Particular attention should be paid
        to negative results, which are more likely to be decisive.
  Table 4-2. Types of evidence (columns) that contribute to each causal consideration (rows).




Causal
Considerations












Co-occurrence
Temporality
Biological
Gradient
Consistency of
Association
Complete
Exposure
Pathway
Specificity of
Cause
Plausibility:
Mechanism
Plausibility:
Stressor-
Response
Experiment
Analogy
Predictive
Performance
Types of Evidence

Associations of
Measurements
of Cause and
Effect







o
ro
0
o
o
O
ro
1o
Q.
CO
X



X












X










c
T3
CD
ro
1o
Q.
CO


X














X







o
(D
O
O
O
i
O
O
ro
o
Q.
E
H

X


X












X









c
 0
O 
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                                Stressor Identification Guidance Document
        Table 4-3. Format for a table used to summarize results of an inference concerning
        causation in case-specific ecoepidemiology. (Table adapted from Susser (1986a), Fox
        (1991), Suter (1998), Beyers (1998).)
Consideration
Results
Score1
Case-Specific Considerations
Co-occurrence
Temporality
Consistency of
Association
Biological Gradient
Complete Exposure
Pathway
Experiment
Compatible, Uncertain, Incompatible
Compatible, Uncertain, Incompatible
Invariant, In many places and times,
At background frequencies or many
exceptions to the association
Strong and monotonic, Weak or other
than monotonic, None, Clear
association but wrong sign
Evidence for all steps, Incomplete
evidence, Ambiguous, Some steps
missing or implausible
Experimental studies: Concordant,
Ambiguous, Inconcordant
+,0, 	
+,0, 	
++, +, -
+++, +, -, 	
++, +, o, —
+++, 0, 	
Considerations Based on Other Situations or Biological Knowledge
Plausibility
Mechanism
Stressor-Response2
Consistency of
Association
Specificity of cause3
Analogy
Positive
Negative
Experiment
Predictive Performance

Actual Evidence, Plausible, Not
known, Implausible
Quantitatively consistent, Concordant,
Ambiguous, Inconcordant
Invariant, In most places, In some
places, At background frequency or
many exceptions to the association
Only possible cause, One of a few,
One of many
Analogous cases: Many or few but
clear, Few or unclear
Experimental studies: Concordant,
Ambiguous, Inconcordant
Prediction: Confirmed specific or
multiple, Confirmed general,
Ambiguous, Failed

++, +, o, —
+++, +, 0, -
+++, ++, +1 —
+++, ++, 0
++, +
+++, 0, 	
+++, ++, 0, 	
Considerations Based on Multiple Lines of Evidence
Consistency of Evidence
Coherence of Evidence
Evidence: All consistent, Most
consistent, Multiple inconsistencies
Evidence: Inconsistency explained by
a credible mechanism, No known
explanation
+++, +, 	
+,o
           In addition to the scores noted, there ay be No Evidence (NE) available relevant to the
           consideration, or the consideration may be Not Applicable (NA) for the particular case (see
           especially stressor-response and specificity).
           Stressor-response is not applicable (NA) if the mechanism is clearly implausible.
           Specificity of cause is not applicable (NA) if either the mechanism is clearly implausible, or if
           there are many exceptions to the association.
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Other methods for combining different lines of evidence include expert systems based on
the logic of abduction and Bayesian statistical approaches (Josephson and Josephson
1996, Clemens  1986). As of this writing, these more quantitative approaches have not
yet been developed for combining evidence for SI.

4.3   Identify  Probable Cause and Evaluate Confidence
                                                     CHARACTERIZE CAUSES
                                                         Diagnose     Strength of Evidence
                                                       | Identify Probable Cause |
       Whichever method is used to infer causation,
       the results of the characterization must be
       summarized. That is, the cause must be
       described, the logical basis for its               Eliminate
       determination summarized, and the
       uncertainties concerning that determination
       presented. As discussed above, there may be
       multiple sufficient causes, all of which should
       be characterized.  In extreme cases, the
       effects of the primary causes are so severe
       that other potential causes will remain unidentified.

       The level of confidence in causal identification may be assessed in quantitative or
       qualitative terms. Confidence is determined in part by uncertainty concerning the data,
       the models, and the observations that contribute to the inference. The uncertainty
       associated with the data may be partially estimated by conventional statistical analysis
       (see text box in Chapter 3 entitled "Data Quality Objectives," and "Using Statistics and
       Statistical Hypothesis Testing"), but also includes uncertainty concerning the
       applicability of the data.  If data must be extrapolated between species or life stages, if
       old data are used to estimate current conditions, or if, for some other reason, data are not
       directly applicable, the associated uncertainty should be estimated.  The uncertainty in
       statistical models, such as regressions of biological properties against levels of potential
       causes, may be estimated using goodness-of-fit statistics or confidence bounds.  The
       uncertainty  due to the parameters in mathematical models, such as models of dissolved
       oxygen depression due to nutrient input, may be estimated analytically or by Monte
       Carlo simulation (USEPA 1996a, 1999). If a causal inference is logically clear and is
       based predominantly on the results of a statistical or mathematical model, the
       uncertainties concerning the results may serve to estimate the uncertainties concerning
       the inference.

        In most cases, unquantified uncertainties will dominate. These include  lack of data
       concerning the presence or levels of particular stressors, incomplete biological data,
       uncertainty  concerning the time when the impairment began, and many more. In
       addition, most causal inferences are based on the strength of evidence, so that no single
       source of uncertainty characterizes the uncertainty concerning the conclusion.
       Therefore, the uncertainty concerning most identifications of causes must be
       characterized qualitatively. That qualitative judgement should be accompanied by a list
       of major sources of uncertainty and their possible influence  on the results.

       In some cases, investigators will be able to clearly demonstrate that a particular cause is
       responsible  for the ecological injuries of concern.  However, in many if not most cases,
       there will be significant uncertainty concerning the relative contributions of alternative
       causal factors.  In such cases, it is necessary to determine whether the evidence is
       sufficient to justify a management action. Standards and criteria for establishing
       epidemiological causation are not generally agreed upon.  In particular, there is no


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       consistent standard for adequacy of proof. While conventional science sets a high
       standard to prove causation, the precautionary principle begins by assuming that an agent
       is harmful and requires disproof of causation (Botti et al. 1996). Such decisions are
       made by risk managers, rather than risk assessors, and may be based on considerations
       such as the cost of remediation and the nature and magnitude of the ecological injury.
       Ideally, that judgment would be made on the basis of a priori criteria. That is, each
       program that uses SI should specify a standard basis for deciding whether the
       characterization of the cause is sufficient for the management purpose.  For example, for
       the permitting of POTW effluents, a particular state might develop standards for proof
       that those effluents cause particular types of injuries. However, standards and criteria
       for establishing causation are not generally agreed upon, and many decisions are made
       ad hoc. That is, the evidence concerning causation may be presented to the risk manager
       as a best estimate of causation along with an accompanying analysis of uncertainties.
       The risk manager may use that result to help reach a decision.

       As  discussed in Chapter 1, the SI process may be conducted iteratively until sufficient
       confidence in the causal characterization is reached.  In the most uncertain and complex
       cases, the SI process may best serve to guide further data collection, modeling, or
       analysis efforts. Options for iterating the process are discussed further in Chapter 5,
       below.  If the cause is confidently identified, then the investigation may proceed to
       identifying sources, developing and implementing management options, and monitoring
       their effectiveness (Figure 1-1).
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 Chapter 5
 Iteration  Options
In this Chapter:
5.1  Reconsider the Impairment
5.2 Collect More Information
       This chapter describes iterations if no clear cause can be identified. If the SI process has
       yielded no clear cause for the biological impairment, it may be because (1) there is
       actually no effect (Section 5.1), or (2) there is insufficient information concerning the
       identified causes or the true cause was not among the list of candidate causes (Section
       5.2).  These alternatives, all leading to a reiteration of the investigation (Figure 4-1), are
       discussed in this section.

       5.1     Reconsider the Impairment

       When no cause was identified, it may be that there is actually no effect, or the actual
       effect may be different from the identified impairment (see worksheet in Appendix B,
       Unit V, page B-35). This situation is known as a false positive, or in statistical terms, a
       Type I error. It should be noted that both  false positive and false negative errors (failure
       to detect an effect that exists) are inherent to any detection system, whether it is medical
       diagnostics, aircraft radar, or environmental monitoring.

       A false positive might result from errors in a biological survey or in the analysis  of data.
       The samples may have been collected improperly; therefore, the biotic community
       appears to be less abundant or species rich than it truly is. The individuals performing
       the identifications may have misidentified organisms. There may have been errors in
       data recording or analysis. Any of these errors may artificially obscure the responses.
       A quality  assurance program can minimize, but not entirely eliminate these errors.  If the
       causal analysis reveals  weaknesses in the evidence for the occurrence of a real effect, a
       careful audit of the biological survey may be  appropriate.

       Other reasons for a false positive result include sampling error and the natural variability
       of the biological indicators. In any monitoring program, sampling is stratified among
       perceived natural classes and subdivisions of systems (e.g., habitat type, salinity,
       sediment, elevation, biogeographic region), and often by season (sampling index period
       in defined season). A sample may have been taken outside of an index period. A site
       may belong to a poorly characterized system type or may have been incorrectly classified
       (e.g., cold water system evaluated using warm water criteria). Any unrecognized
       misclassification can result in either a false positive or false negative. Intensive
       monitoring and characterization of natural systems, combined with quality assurance and
       peer review of results, can reduce both types of errors.

       In other cases, the impairment may have been defined too broadly or investigators may
       have made wrong assumptions about mechanisms when developing their conceptual
       model. For example, the first investigations into bird population declines  and DDT
       focused on mortality rather than egg-shell thinning, and failed to find a connection with
       DDT (see text box entitled "Revisiting the Impairment in the Case of DDT").  Careful
       reconsideration of the nature of the impairment can put the investigation back on the
       right track.

       Finally, natural variability of the indicators, not due to any measurement or analytical
       errors, can result in both false positives and false negatives.  Environmental criteria may


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                               Stressor Identification Guidance Document
        be defined by exceedence of a percentile or extreme value of some statistical
        distribution.  This means that natural, or unimpaired conditions, may also exceed the
        criteria at some frequency. Ideally, acceptable error rates should be specified for
        decisions resulting from the biological assessment system.  If confidence in a finding of
        biological impairment is low (that is, if the indicator just exceeds the threshold value),
        then increased sampling may reduce uncertainty and increase confidence (see next
        section).

        5.2     Collect More  Information on Previous and Additional Scenarios

        If a causal scenario has  not been established with sufficient confidence and the effect
        appears to be real, management should be consulted to discover if knowing the cause is
        still required for decision-making. If so, then more information must be collected (see
        worksheet in Appendix B, Unit VI, page B-36). Because the cost of field data collection
        and data analysis increases with each iteration, it is important to carefully plan what
        additional information is needed to determine the cause of impairment.  This information
        may include previously considered scenarios for which information was inadequate, or
        candidate causal scenarios that were not previously considered.
                             Revisiting the Impairment in the Case of DDT1

         The fact that DDT played a role in the decline of bald eagle and other bird-of-prey populations
         (e.g., osprey, brown pelicans) is now commonly appreciated among most biologists.  However,
         the link between DDT and the eggshell thinning that caused reproductive failure in these birds
         was not initially recognized.  Ultimately, the connection was made by re-examining the
         description of the impairment.

         The first link between DDT and  diminishing bald eagle and other bird-of-prey populations was
         the consistent observation of high body burdens of DDT metabolites. In other words, there was
         co-occurrence of the declining bird populations and the candidate cause,  DDT. There was
         also evidence of a complete exposure pathway to birds based on body burden of DDT.
         However, extensive toxicity testing of DDT on adult bird mortality revealed no relationship.  This
         suggested that the proposed mechanism, toxicity,  was implausible.  However, lethality was not
         the impairment; decline of birds-of prey was the impairment. A new conceptual model was
         required that considered other mechanisms that could result in declines in  bird  populations. In
         re-examination of the overall analysis,  it became apparent that the species chosen for testing
         had been relatively tolerant of DDT exposure compared to those that were affected in the wild,
         and that the endpoint observed in these tests (lethality) would not reflect reproductive success
         or failure resulting from DDT exposure.

         Field observations eventually revealed a  potential  plausible mechanism of reproductive failure
         due to eggshell thinning among bald eagles and other birds-of-prey.  Laboratory experiments
         showed that DDE could cause eggshell thinning.  Field studies showed that field exposures to
         DDE, a metabolite of DDT, were sufficient to cause effects in many species of birds based  on
         the stressor-response relationship. Together these findings  provided  lines of  evidence by
         which DDT might cause eggshell thinning and reduce reproductive success, a more specific
         impairment than declines in  bird population.

         Outcome
         In 1972, DDT was banned from most uses in the United States. In the years following the ban,
         bald eagle and other bird-of-prey populations slowly recovered. The  recovery of bird
         populations after banning the use of DDT, is an example of mitigation of the effect following
         manipulation of the cause, and  is very strong evidence that the use of DDT was, in fact, the true
         cause of bald eagle and other bird-of-prey population declines.

         References
         Grier, J.W.  1982; Blus, L.J., and C.J. Henny, 1997
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                              Stressor Identification Guidance Document
       Even when the characterization of causes has not determined the cause with sufficient
       confidence, the set of candidate causes should have been reduced, and the critical
       evidence should be apparent. In particular, it should be possible to design experiments
       or observations that will potentially eliminate certain causes (Chapter 4.1.1). However,
       such experiments are not always feasible.  Alternatively, one may identify critical pieces
       of positive evidence  that would strongly support one scenario and none of the others. In
       most cases, it will be appropriate and prudent to plan a sampling and testing program that
       will generate a set of potentially decisive positive and negative evidence.

       If all of the most common causes have been eliminated or have been determined to be
       unlikely, then additional causal scenarios need to be identified.  The process is similar to
       that described in Chapter 2. New data may have come to light during the first iteration
       of the SI process.  These data should be carefully reviewed to determine if there are any
       clues to suggest additional causal scenarios. Details of the available data should be
       considered, such as weather patterns, new construction, or land use information. If the
       descriptions of the effect or the scope were too broad, they may need to be refined or
       more clearly defined. Additional potential causal scenarios may include new stressors or
       combinations of stressors that occur simultaneously or in a specific sequence. After the
       additional candidate  causal scenarios are developed, key evidence should be identified
       that is likely to allow identification of the cause.

       The most important tools to bring to the SI process are experience in multiple disciplines
       (especially ecology), careful, deliberate critical thinking, and a strong desire to find the
       true cause of biological impairment.
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                            Stressor Identification Guidance Document
 Chapter 6
 Presumpscot River, Maine
       6.1    Executive Summary

       The Presumpscot River is located in southern Maine and forms the outlet of one of
       Maine's largest lakes, Sebago Lake. From 1984 to 1996, biological monitoring
       downstream of a pulp and paper mill discharge consistently revealed non-attainment of
       Maine's Class C aquatic life standards. The river is impounded above and below the
       discharge.  The discharge releases high concentrations of TSS and total phosphorus, and
       on occasion releases metals above the chronic criteria but below acute criteria. Upstream
       samples consistently indicated attainment of Class C or better standards.

       Description of the Impairment

       Biological  impairment was characterized by a shift in the benthic macroinvertebrate
       community from 90% insects upstream of a pulp and paper mill discharge to about 50%
       insects downstream. This shift included a 15-35% loss of taxonomic richness, and 40-
       60% loss of Ephemeroptera-Plecoptera-Trichoptera (EPT) taxa. Moreover, many insect
       taxa found upstream of the discharge were pollution-sensitive, while those found
       downstream were primarily pollution-tolerant species, such as snails and worms.

       List Candidate Causes

       Eight candidate causes for non-attainment were considered in the  Stressor Identification
       process:

           1.   Excess toxic chemicals from the discharge;

           2.   High TSS combined with floe causes high BOD and reduced DO;

           3.   High TSS combined with floe causes smothering;

           4.   Excess nutrients (from POTWs, nonpoint sources, and the mill) cause excess
              algal growth;

           5.   Impoundment increases sedimentation that smothers biota;

           6.   Impoundment decreases flow velocity and causes algal growth, leading to
              reduced DO;

           7.   Impoundment causes low DO; and

           8.   Impoundment causes loss of suitable habitat.

       Characterizing Causes:  Eliminate

       Four of the eight candidate causes were logically eliminated from examination of the
       evidence. Reduced DO sufficient to cause the impairment was not observed in the
       Presumpscot River, and bottom-water DO concentrations were stable throughout the


Chapter 6: Presumpscot River, Maine                                                           6-1

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                             Stressor Identification Guidance Document
       river, above and below the discharge. Therefore, causal scenarios #2, #6 and #7 could be
       eliminated. Although elevated concentrations of total phosphorus (TP) were observed
       below the discharge, the increase in chlorophyll a concentration was negligible. Water
       column chlorophyll a is a surrogate measure for algal biomass. Because excess algal
       growth was necessary for causal pathway #4, and there was none, it was also eliminated
       from further consideration.

       Characterizing Causes:  Diagnose

       No evidence strong enough to support diagnosis was available for any of the candidate
       causes.

       Characterizing Causes:  Strength of Evidence

       A strength of evidence approach was then used to examine the remaining four candidate
       causes. The four remaining causes were toxic chemicals, flocculent TSS causing
       smothering, impoundment increasing sedimentation, and impoundment causing loss of
       suitable habitat. There was no strong evidence for or against the toxic chemical
       hypothesis (#1).  Several lines of strong evidence favored the TSS hypothesis (#3):

           >  The exposure pathway from discharge to biological impairment was complete
              and plausible.

           >  Other rivers with  similar elevated flocculent TSS also had impaired biological
              assemblage.

           >  Removal of flocculent TSS from a nearby river resulted in recovery of the
              biological assemblage.

       Two lines of evidence disfavored the two impoundment hypotheses (#5 and #8):

           *•  Other impoundments with  similar potential sediment loadings (not from mill
              discharge)  and similar habitat support diverse invertebrate assemblages that meet
              aquatic life use criteria; and

           >  a site upstream of the mill effluent, and within the same impoundment, met
              aquatic life use criteria.

       Characterizing Causes:  Identify Probable Cause

       The evidence supporting scenario #3, that non-attainment was due to high loads of
       flocculent TSS from the discharge, was consistent throughout the lines of evidence.
       Strength  of association, spatial co-occurrence, and experimental lines of evidence
       strongly supported  this scenario. Evidence for the toxicity scenario (#1) was extremely
       weak. Evidence for the two impoundment scenarios (#5 and #8) was negative. The State
       of Maine concluded that high TSS  was sufficient for causing the biological impairment.
       Quality of the data  were adequate,  and confidence in the conclusion was high.
       Subsequently, the State took management action to reduce loadings  of TSS through a
       TMDL that was approved by EPA. This was the first time in New England that
       bioassessment findings had served  as the quantitative response variable for development
       of a TMDL and resulting pollutant discharge limits, including the pulp and paper mill.
6-2                                                            U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       Moreover, it provided a means for Maine to control a pollutant (TSS) for which it had no
       specific criterion in its water quality standards.

       6.2     Background

       This case study is presented as an example of how the stressor identification (SI) process
       could have been used to determine the cause of non-attainment of aquatic life use in a
       small river in Maine.  The case study begins with the presentation of background
       information on the regulations in the  State of Maine and the geographical location of the
       case study.  This is followed by a brief discussion of the evidence found at the site and in
       other situations.  Several causal scenarios are then presented and analyzed separately to
       illustrate how the SI process could be used to eliminate four of the eight candidate
       causes. A strength of evidence analysis is then used to identify the most likely cause.
       The case study concludes with a brief discussion of the management actions taken to
       remedy the situation.  One of the most significant results of this effort was that the State
       of Maine, Department of Environmental Protection, used bioassessment findings to
       control a stressor for which the State  has no standards.

       Impairment Trigger: Biological monitoring in the Presumpscot River in Westbrook,
       below a pulp and paper mill discharge, has consistently revealed non-attainment of Class
       C aquatic life standards (1984, 1994, 1995,  1996) using standard Maine Department of
       Environmental Protection methods (invertebrate) (Davies and Tsomides 1997).

       Regulatory Authority

       The Maine Department of Environmental Protection (MDEP) issues wastewater
       discharge licenses that set the allowable amounts of pollutants that industries may
       discharge to waters of the State.  These limits are scientifically determined in order to
       preserve water quality sufficient to maintain all designated uses and criteria established,
       by law, for the river. In recent years  USEPA has required that a Total Maximum Daily
       Load (TMDL) be established for impaired river systems, such as the Presumpscot, for
       which existing, required pollution controls are inadequate to attain applicable water
       quality standards.

       The State of Maine established minimum standards for three water quality
       classifications, Class A, Class B, and Class C. These classes specify designated aquatic
       life uses from Class C, the minimum  state standard, to the most protected waters with the
       Class A/AA designation. Class C requires that the structure and function of the
       biological community be maintained  and provides for the support of all indigenous fish
       species.

       Under this system, attainment of the aquatic life classification standards for a given
       water body is evaluated using numeric biological criteria.  The MDEP numeric aquatic
       life criteria are based on statewide data collections over a 14-year period with analysis of
       over 400 sampling events. Artificial  substrates (rock baskets) are incubated on the
       bottom at stream sites, retrieved, and benthic macroinvertebrates that have colonized the
       substrates are identified and enumerated (Davies and Tsomides 1997).  Aquatic life
       classification standards for a given water body are evaluated using numeric biological
       criteria that were statistically derived from the statewide database. The criteria are in the
       form of a statistical model (linear discriminant model) which yields the probability that a
       test sample belongs to one of the 3 water quality classes, or non-attainment of the lowest
Chapter 6: Presumpscot River, Maine                                                              6-3

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                             Stressor Identification Guidance Document
       class (Davies et al. 1995). The model uses a set of metrics derived from the species
       composition and abundance enumerated from the substrates.

       Geography

       The Presumpscot River is the outlet of Sebago Lake.  The river flows through the most
       densely-populated county in the State of Maine, crossing the towns of Gorham,
       Windham, Westbrook, Portland, and Falmouth. The Presumpscot then empties into
       Casco Bay at the Martins Point Bridge (Figure 6-1).
               Pulp Mill Outfall
           Westbrook
             POTW
                         295 attainment
                         Cumberland Dam
                        238
          Presumpscot River
            • Biomonitoring Stations f\/ Rivers
            A Sources            H_| Major water areas
           — Dams              I    I State
          POTW = Publicly Owned
                  Treatment Works     1      n      1
                                                        2 Miles
                 A
                  N
       Figure 6-1.  Map of the Presumpscot River showing biomonitoring stations, potential
       sources of impairment, and their location relative to the Androscoggin River (inset).
6-4
U.S. Environmental Protection Agency

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                             Stressor Identification Guidance Document
       Compared to industrial receiving waters in the State of Maine, the Presumpscot is a
       relatively small river, having a drainage area of only 647 square miles.  These
       circumstances contribute to a low dilution ratio in the lower Presumpscot River.

       The river has six impoundments and four industrial and municipal waste discharges.
       This study comprises an area immediately downstream of a pulp and paper mill effluent
       discharge. Approximately 3.2 km, downstream of the discharge is an impoundment;
       upstream is a municipal discharge and (further upstream) two impoundments.

       Evidence of Impairment

       Biological Evidence: Biological monitoring in the Presumpscot River in Westbrook,
       below a pulp and paper mill discharge, consistently revealed non-attainment of Class C
       aquatic life standards (1984, 1994, 1995, 1996) using the standard Maine Department of
       Environmental Protection methods (Davies et al. 1995, Davies and Tsomides 1997).

       Biological evidence indicating impairment on the lower Presumpscot River is
       summarized in Table 6-1 and Figure 6-2.  Upstream samples consistently indicated
       attainment of Class C or better aquatic life standards (Davies et al.  1999). Three
       kilometers downstream the Presumpscot within the impounded area did not attain Class
       C aquatic life standards.

       Table 6-1.  Evidence of biological impairment in the Presumpscot River upstream and
       downstream of a pulp and paper mill effluent discharge.
Evidence
Aquatic Life Standard
Benthic
Macroinvertebrate
Community
Taxonomic Richness
Sensitive Species
(EPT)
Snails and Worms
Upstream of
Effluent
Class C
90% insects
~
~
Low
Downstream of Effluent
Non-Attainment
50% insects
15%-35% decrease relative to upstream
46%-60% decrease relative to upstream
High
       The Presumpscot River biological monitoring samples reveal a shift in the benthic
       macroinvertebrate community from 90% insects above the mill to about 50% insects
       below the mill, with 15%-35% loss of taxonomic richness and 46%-60% loss of the
       sensitive Ephemeroptera-Plecoptera-Trichoptera (EPT) groups (Mitnik 1998). Pollution-
       sensitive insect taxa found in the upstream samples were replaced by a predominance of
       snails and worms, which are more tolerant of pollution, in the downstream samples.

       6.3     List Candidate Causes

       Eight candidate causes for the non-attainment of biological standards were considered.
       The candidate causes for the biological impairment of the Presumpscot River are shown
       in terms of a conceptual model (Figure 6-3), wherein the candidate causes are ordered
       from left to right. Each scenario is explained below:

       1. Excess Toxic Chemicals - Potentially toxic compounds may be discharged from the
       paper mill and these compounds adversely affect aquatic life.
Chapter 6: Presumpscot River, Maine
6-5

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                              Stressor Identification Guidance Document
                          Biological Indicators of Non-Attainment
                                                                    ] Species Richness
                                                                    I No. of EPTTaxa
                        upstream
                                   immediately
                                   dow nstream
approx. 1  mile
 dow nstream
        Figure 6-2. Species richness and number of EPT taxa in the Presumpscot River
        upstream and downstream of a pulp and paper mill effluent discharge.
                                                        Stressor Identification
                                                                  LIST CANDIDATE CAUSES
                                                                    ANALYZE EVIDENCE
                                                                   CHARACTERIZE CAUSES
Eliminate

Diagnose
| Strength of Evidence
                                                                      Identify Probable Cause
2. BOD (produced by high TSS with floe) reduces
DO - Excess total suspended solids (TSS with floe)
may be released by the paper mill effluent, and
these solids create biological oxygen demand
(BOD), reducing dissolved oxygen (DO) levels in
the river. Consequently, the river has insufficient
oxygen to support sensitive species of benthic
invertebrates.

3. TSS with floe - The increased levels of TSS
discharged to the river could impact the benthic
communities by accumulating as (non-
biodegradable) sediment, resulting in fewer
interstitial spaces  in which animals can live, and
possibly smothering benthic biota.
       4. Excess Nutrients - Excess nutrients, deriving from either upstream, non-point sources
       or from the paper mill effluent, may affect water quality by promoting algal blooms.  In
       this scenario, an overabundance of plant nutrients such as phosphorus is delivered to the
       stream, and over-stimulates algal growth (a process known as eutrophication). An
       increase of algae in the river may affect benthic macroinvertebrates in two ways. If the
       algal growth is severe, the resulting detritus becomes a source of BOD, reducing
       dissolved oxygen levels in the river. If the growth is modest, the algae may still affect
       the benthic macroinvertebrate community by providing an increased food supply for
       opportunistic invertebrates that use algae as a food source. Consequently, the
       community would shift in such a way that the opportunistic species would thrive and
       outcompete other, less opportunistic species.
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                                                         U.S. Environmental Protection Agency

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   Sources:
   Stressors:
   Interactions:
   Effect:
                                                              Altered
                                                             Hydrology
                                                           (Impoundment)
                   Toxic Chemicals
                                                Excess Nutrients
  Pool Conditions:
reduced flow velocity
  stream widening
  deepened water
                                                                        Increased
                                                                      Sedimentation
Increased TSS
                                  Shift in BenthicMacroinvertebrateCommunity
Figure 6-3.  Conceptual model showing the potential impact of stressors on the benthic community of the Presumpscot
River.  (Arrow with minus sign (-) indicates inhibition.)

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                              Stressor Identification Guidance Document
       The fifth through eighth candidate causes are based on impoundment of the river just
       downstream of the paper mill effluent.  Each cause begins with the idea that the
       impoundment is causing adverse changes in the physical nature of the Presumpscot.
       Impoundments generally widen and deepen a stream corridor, reducing flow velocity and
       creating pool-like conditions.  Such alterations can have several effects:

       5. Impoundment Increases Sedimentation - One effect of impoundment is increased
       sedimentation due to reduced flow velocity, which leads to fewer interstitial spaces in
       which animals can live, and potentially smothers benthic ones.

       6. Impoundment Promotes Algal Growth - The pool-like conditions created by the
       impoundment become a better habitat for algal growth, and algal blooms occur.
       Subsequently, benthic communities shift as a result of oxygen depletion or the
       dominance of algae-consuming invertebrates, as described previously.

       7. DO Reduction in Impoundment - An impounded river is deeper and slower, which
       results in less potential for mixing and more potential for stratification, particularly in
       warmer months. As a result, underlying water may not be sufficiently aerated, and
       benthic diversity decreases in response to low dissolved oxygen levels.

       8. Habitat Degradation caused by Impoundment - Changes in physical conditions of the
       river caused by impoundment reduce optimal habitat for benthic organisms. The effect is
       a direct one:  native benthic macroinvertebrates are unable to thrive under the altered
       conditions. Dissolved oxygen levels and other water quality parameters are not a factor.

       6.4   Analyze Evidence and Characterize Causes: Eliminate
       Physical and Chemical Evidence: Physical and
       chemical evidence indicating impairment on the
       lower Presumpscot River is summarized in Table 6-
       2. Upstream of the pulp and paper mill outfall, it
       was possible to see samplers on the river bottom at
       2.5 meters of depth, whereas in the effluent plume,
       just 600 m downstream, visibility was less than 0.5
       meter. Visibility at a sampling station 3.2 km
       downstream of the outfall remained significantly
       impaired.  This evidence was used to eliminate
       candidate causes.

       1. Toxic Chemicals - No in-stream or sediment
       chemistry data were available.  Therefore, toxic
       chemicals cannot be eliminated as a candidate
       cause.
Stressor Identification
          LIST CANDIDATE CAUSES
           ANALYZE EVIDENCE
          CHARACTERIZE CAUSES
       Eliminate    Dagnose   Strength of Evidence
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       U.S. Environmental Protection Agency

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                             Stressor Identification Guidance Document
       Table 6-2.  Physical and chemical parameters measured in the Presumpscot River
       upstream and downstream of a pulp and paper mill effluent discharge.
Observation
Visibility
Observations on
Sampling Equipment
(e.g., ropes, nets)
Mean TSS (ppm)1
Mean BOD (ppm)2
DO range (ppm) 3
Mean nitrate - nitrite
(ppm)2
Mean ammonia
(ppm)2
Mean Total
phosphorus (ppb)2
Mean Orthophosphate
(ppb)2
Mean Chlorophyll a
(ppb)2
Source
Mitnik1998
Mitnik1998
Courtemanch
etal. 1997
Mitnik1994
Mitnik1994
Mitnik1994
Mitnik1994
Mitnik1994
Mitnik1994
Mitnik1994
Upstream of
Mill
2.5m
Free of brown
floe
3 ppm
3.96
5.9-8.4
0.03
0.03
12.8
3.5
2.1
Downstream of Mill
<0.5 m (600 m below outfall)
and visibility remained
"significantly impaired" 3.2
km downstream
Coated with brown floe
5.9 ppm
6.19
5.8-8.0
0.05
0.12
61.2
44.3
2.3
       Notes
       1 Observations from 1995-96; number unknown
       2 4 sites above mill and 5 sites below on 3 consecutive days
       3 Bottom water; 9 sites above mill and 8 sites below on 6 non-consecutive days
       2. BOD (produced by high TSS with floe) reduces DO - Elevated BOD was associated
       with the biological impairment in the Presumpscot River. In this candidate scenario,
       reduced DO is the actual stressor that acts on the organisms to cause impairment.
       Monitoring in the Presumpscot River above and below the mill discharge indicated that
       DO concentrations did not decrease upstream to downstream (Table 6-2 and Figure 6-4).
       The reported DO measurements were taken at stations indicated on the map (Figure 1).
       Most of the sites shown in Figure 1 were impounded water; only 7.7, and 6.3 were free-
       flowing.  The results reported in Tables 6-2 and 6-3 were all sampled between 0640 and
       0850 hours, within 1m of the bottom, in  July and August, 1993 (Mitnik 1994).  This is
       the time, depth, and season at which minimum DO is found in lakes and impoundments,
       because of the diurnal cycle of photosynthesis and respiration, and because
       photosynthesis (but not respiration) is inhibited in deeper and darker waters. This
       analysis demonstrated that low DO does not occur in the Presumpscot River under any of
       the candidate causes involving reduced dissolved oxygen. Therefore, candidate causal
       scenarios # 2 (High TSS with floe causes high BOD and reduced DO) # 6
       (Impoundment promotes algal growth that in turn reduces dissolved oxygen), and # 7
       (Impoundment causes low DO through decreased water flow rate) could be eliminated
       without further analysis. The elimination of scenario #6 is reinforced by the evidence
       described in scenario #4, below.
Chapter 6: Presumpscot River, Maine
6-9

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                             Stressor Identification Guidance Document


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                              Stressor Identification Guidance Document
       8. Habitat Degradation caused by Impoundment - Again, the biological impairment
       found downstream of the paper mill discharge coincided with the presence of an
       impoundment (Table 6-3).  However, no measurements of habitat quality were available
       to determine if the biological impairment was the result of habitat loss caused by the
       impoundment. Therefore, scenario #8 could not be eliminated.

       Following the process of elimination, 4 candidate causes remained:

           1.  Excess toxic chemicals.

           3.  High TSS with floe causes smothering.

           5.  Impoundment increases sedimentation that smothers biota (with or without
              discharge of TSS and floe).

           8.  Impoundment causes loss of
              suitable habitat.

       6.5    Analyze Evidence and Characterize Causes: Strength of Evidence
                                                        Stressor Identification
                                                                  LIST CANDIDATE CAUSES
                                                                   ANALYZE EVIDENCE
                                                                  CHARACTERIZE CAUSES
Direct observations in the Presumpscot River
during macroinvertebrate and fish tissue sampling
revealed a heavy suspended and settled solids load.
Samplers and gill nets were coated with flocculent
fibers and water clarity was dramatically reduced.
In comparison to other paper mills in the State, the
pulp and paper mill effluent released to the
Presumpscot was considered high strength for
solids. However, the conditions faced on the
Presumpscot were similar to those found below the
discharge from another paper mill on the
Androscoggin River in Jay, Maine.  Because of this,
observations in the vicinity of the paper mill on the
Androscoggin River were used to support the
evidence found for this case study.
       A comparison of the two rivers and discharge loadings to each is given in Table 6-4.
       Paper mill discharges on both rivers were subject to impoundments with similar
       hydraulic properties (e.g., velocity and depth) and background TSS concentrations
       (about 3 ppm).  Two or more dams impounded both rivers upstream of the discharges.
                                                              Eliminate    Dagnose   Strength of Evidence
                                                                                  J
                                                                     Identify Probable Cause
Chapter 6: Presumpscot River, Maine
                                                                                    6-11

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                              Stressor Identification Guidance Document
       Table 6-3. Considerations for eliminating candidate causes.
Candidate
Cause
Toxic
Chemicals
BOD
(produced by
TSS) reduces
DO
TSS with floe
Nutrients and
algal growth
Impoundment
increases
sediment
Impoundment
promotes
algal growth
DO reduction
in
Impoundment
Habitat
degradation
caused by
impoundment
Impairments
occur same
place as
exposure?
NE
BOD Yes;
TSS Yes;
DO No
Yes
Nutrients
Yes;
Algal Yes
Yes
Algal Yes;
DO No
Imp. Yes;
DO No
Yes
Exposure
increased
over
closest
upstream
location?
NE
BOD Yes;
TSS Yes;
DO No
Yes
Nutrients
Yes;
Algal No
NE
Algal No;
DO No
Imp. Yes;
DO No
NE
Gradient of
recovery at
reduced
exposure?
NE
NE
NE
NE
NA
NA
NA
NA
Exposure
pathway
complete?
NE
No
Yes
No
NE
No
No
NE
Candidate
Causes
Remaining
X

X

X


X
       Table 6-4. Comparison of TSS loadings in the Presumpscot and
       (Sample points were located below a pulp and paper mill effluent
  Androscoggin Rivers.
  discharge.)

Mill & Year
Sampled
Aquatic Life Status
TSS treatment
Sampling Months
Flow, cubic
feet/second (cfs)
TSS Discharged,
pounds/day
TSS discharged/flow
Presumpscot
1995
Non-
Attainment
none
June-Aug
418
7454
3.31
1996
Non-
Attainment
none
Aug-Sept
463
8795
3.52
Androscoggin
1995
Non-
Attainment
none
June-Aug
2114
19804
1.74
1996
Attainment
TSS
removal
Aug-Sept
2982
5750
0.36
1997
Attainment
TSS
removal
June-Aug
4116
13495
0.61
6-12
U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       Moreover, the upstream impoundments on both rivers attained at least Class C aquatic
       life standards. However, both rivers were found to be in non-attainment of aquatic life
       standards downstream of the paper mill discharges in 1995. Calculated mean ambient
       concentrations of TSS in the Presumpscot downstream of the mill were 32% to 39%
       greater than ambient levels downstream of the mill on the Androscoggin River.  For the
       most part, the incremental TSS increase on the Androscoggin River, due to paper mill
       discharges, was within 1 ppm of background, while on the  Presumpscot, the mill
       discharge was about 3 ppm greater than background.

       In 1996, efforts were made by another paper mill on the Androscoggin River to reduce
       TSS discharge into the Androscoggin River. Following these efforts, the site's
       biological score improved and the river met Class C aquatic life standards. This
       recovery of biological conditions following TSS reduction  provided experimental
       evidence that TSS could also be the cause of ecological stress in the Presumpscot River.
       Table 6-6 summarizes the types of evidence weighed  in the analysis of potential stressors
       in the Presumpscot River.

       Other evidence used in the strength of evidence comparison is shown in Table 6-5.
       Some  metals exceeded chronic criteria when the maximum concentration in the effluent
       was evaluated with a low flow  scenario (Table 6-5). Although low DO was eliminated in
       the previous step of this case study.  Maine DEP performed an extensive modeling effort
       to investigate the potential for low DO below the mill outfall.  The modeling results
       supported the conclusion that the DO concentrations did not fall below minimum levels
       for Class C aquatic life uses (Mitnik 1998). Furthermore, during the same time period as
       the biological monitoring, there were not violations of criteria for DO.

       Table 6-5.1996 -1999 metal concentrations in the pulp and paper mill effluent.
Metals




Aluminum
Lead
Mercury
Silver
Range |jg/L
in Effluent Grab
Samples
1996-1999

108-1920
3-14
0.0001 - 0.9
10
Maximum
Receiving Water
Concentration
(|jg/L) at Low
Flow1 (7Q102)
207.9
1.52
0.097
1.083
Chronic
Criteria
(M9/L)


87
0.41
0.012
0.12
Acute
Criteria
(M9/L)


750
10.52
2.4
0.92
       Notes
       1 The receiving water concentration is calculated from the maximum effluent concentration divided
         by a dilution factor of 9.
       2 7Q10 + 7-day low flow over a ten year period.
Chapter 6: Presumpscot River, Maine
6-13

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Table 6-6: Strength of evidence of non-attainment in the Presumpscot River.
Case-Specific
Evidence:
Consideration
Spatial
Co-occurrence
Temporality
Consistency of
Association
Biological
Gradient
Complete
Exposure
Pathway
Experiment
TSS with Floe
Results
Compatible: Non-
attainment observed
in area of high TSS
and floe loading.
Attainment observed
in upstream areas
without TSS loading.
No observations prior
to paper mill
discharge.
No evidence
No evidence
Evidence for all steps:
High TSS and floe
discharge into river
well-documented.
No evidence
Score
+
NE
NE
NE
++
NE
Toxic Compound
Results
Evidence unavailable.
No observations prior
to paper mill
discharge.
No evidence
No evidence
No evidence
No evidence
Score
NE
NE
NE
NE
NE
NE
Impoundment increases
Sedimentation

Uncertain: Non-
attainment observed in
area of impoundment,
but no measurements
of sedimentation were
available.
No observations prior to
impounding
A site within the same
impoundment,
upstream of the mill
met aquatic life uses.
Not Applicable
No evidence
No evidence
Score
0
NE

NA
NE
NE
Impoundment causes Loss
of Habitat

Uncertain: Non-
attainment observed
in area of
impoundment, but no
observations of
habitat quality were
available.
No observations prior
to impounding
A site within the
same impoundment,
upstream of the mill
met aquatic life uses.
Not Applicable
No evidence
No evidence
Score
0
NE

NA
NE
NE

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Table 6-6 (continued): Strength of evidence for causes of non-attainment in the Presumpscot River.



Information
from Other
Situations or
Biological
Knowledge:

































Consideration

Plausibility -
Mechanism



Plausibility -
Stressor-
Response















Consistency of
Association



Specificity of
Cause

Analogy
Experiment




TSS with Floe

Results
Plausible: Snails and
worms are adapted to
utilization of settled
solids.

TSS response from
Androscoggin study
and modeling
sufficient to cause
impairment.













Invariant: Other sites
on other rivers with
TSS have impaired
biological
communities.
Low: Other causes
elicit similar
responses.
No evidence
Concordant: Removal
of TSS in the
Androscoggin river
improved invertebrate
assembleges.
Score
+




++

















+++




0


NE
+++




Toxic Compound

Results
Plausible: Toxic
compounds could
alter community
composition.

Ambiguous:
Assuming low flow
conditions and at the
highest
concentrations
reported for effluent
from the mill, chronic
aquatic life criteria
might be exceeded
for aluminum, lead,
mercury and silver.
However, if we
assume high flows at
the time of sampling
then neither acute nor
chronic aquatic life
criteria are likely to be
exceeded.
In some places:
Possibly could cause
effects if at maximum
values most of the
time, but unlikely
Low: Other causes
elicit similar
responses.
No evidence
No evidence




Score
+




0

















0




0


NE
NE




Impoundment increases
Sedimentation

Plausible: Sediment
could alter habitat and
community
composition.

Other impoundments
with similar potential
sediment loadings
support diverse
invertebrate
communities.












Other impoundments
on other rivers are not
impaired.


Low: Other causes
elicit similar responses.

No evidence
No evidence




Score
+



























0


NE
NE




Impoundment causes Loss
of Habitat

Plausible: Altered
habitat could change
community
composition.

Other impoundments
with similar habitat
support diverse
invertebrate
communities.













Other impoundments
on other rivers are
not impaired.


Low: Other causes
elicit similar
responses.
No evidence
No evidence




Score
+



























0


NE
NE





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Table 6-6 (continued): Strength of evidence for causes of non-attainment in the Presumpscot River.


Considerations
Based on
Multiple Lines
of Evidence:
Consideration
Predictive
Performance
Consistency of
Evidence
Coherence of
Evidence
TSS
Results
No evidence
All Consistent.

Score
NE
+++

Toxic Compound
Results
No evidence
Not consistent: data
collected during the
same time period as
the biological
monitoring indicated
that there were no
violations of criteria for
toxic materials (Mitnik
1998).
Could be due to
unmeasured chemical
or episodic exposure.
Score
NE
0
0
Impoundment increases
Sedimentation

No evidence
Not consistent: Other
sites with
impoundments
maintained diverse
communities.
No known explanation.
Score
NE
0
0
Impoundment causes Loss
of Habitat

No evidence
Not consistent:
Other sites with
impoundments
maintained diverse
communities.
No known
explanation.
Score
NE
0
0

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                              Stressor Identification Guidance Document
       6.6     Characterize Causes:  Identify Probable Cause
       Following the process of elimination, four
       causal scenarios remained to compare for
       strength of analysis (Table 6-6). These
       scenarios were: #1 (excess toxic
       chemicals), #3 (high TSS with floe causing
       smothering), #5 (impoundment increasing
       sedimentation that smothers biota, with or
       without discharge of TSS and floe), and #8
       (impoundment causing loss of suitable
       habitat).
CHARACTERIZE CAUSES
Eliminate Diagnose


Strength of Ev


| Identify Probable Cause

dence

       The evidence supporting scenario #3, that non-attainment was due to high TSS loads
       combined with floe, was consistent throughout the lines of evidence. Moreover, the
       strength of association, spatial co-occurrence, plausible stressor-response and experiment
       lines of evidence strongly supported this scenario. Therefore, high TSS with floe was
       sufficient for causing the biological impairment.  The quality of the data are adequate for
       this conclusion, and our confidence is high.

       In contrast, evidence for the toxicity scenario was weak, because the stressor-response
       association was unlikely based on levels of chemicals in the effluent and the likely
       dilution provided by the river at the time of discharge. If greater certainty was required,
       ambient receiving water toxicity tests could be used.

       Likewise, evidence for the candidate causes involving impoundments lacked field
       measurements of sedimentation and habitat quality. However, our confidence in
       rejecting these scenarios as the primary cause of impairment is strengthened by the fact
       that several upstream sites along the Presumpscot River were impounded with no
       associated biological impairment (Mitnik 1998, Davies et al. 1999), and within the same
       impoundment upstream from the mill, the Presumpscot met aquatic life uses.
       Furthermore, several other impounded rivers of the state  are able to meet Class B and C
       biological criteria (Davies et al. 1999).

       Nutrient levels were elevated; however, the algal concentration was not different from
       the nearest upstream sampling location. As a result, candidate cause # 4, excess
       nutrients, was eliminated; however, it is possible that the growth of algae was inhibited
       by other factors, such as shading from floe. If floe were removed, then effects due to
       eutrophication might become evident.

       Low dissolved oxygen was also eliminated based on spatial patterns of DO along the
       river. Other data is also available that increases the confidence that could have been
       presented in a strength of evidence analysis.  At the site, DO was not below 6 ppm.  The
       minimum DO level for Class C waters  is 5 ppm.  Maine DEP also performed an
       extensive modeling effort to investigate the potential for low DO below the mill outfall.
       The modeling results supported the conclusion that the DO concentrations did not fall
       below minimum levels for Class C aquatic life uses (Mitnik 1998).
Chapter 6: Presumpscot River, Maine
6-17

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                              Stressor Identification Guidance Document
       6.7     Significance and Use of Results

       In December 1998, the U.S. Environmental Protection Agency approved a Total
       Maximum Daily Load (TMDL) finding, prepared by Maine Department of
       Environmental Protection, for the Presumpscot River. This approval was significant for
       several reasons:

           1.   It was the first TMDL that addressed a listed 303(d) water to be approved in
               Region 1 USEPA (the New England States);

           2.   It was the first time in New England that bioassessment findings had served as
               the quantitative response variable from which a pollutant discharge limit was
               developed.

       The wastewater discharge license that has resulted from this effort requires an initial
       30% reduction in the TSS discharge from a pulp and paper mill in Westbrook.
       Provisions are included in the license for further reductions (up to 61%) if the initial
       levels still fail to provide for attainment of aquatic life standards.

       Main Factors Influencing Success

       The Department was able to apply this innovative approach to improving water quality
       and aquatic life conditions in the Presumpscot River because of the convergence of
       several factors:

           *•   The State has a sound legal basis for use  of biological monitoring findings to
               force action. Clearly defined aquatic life standards exist in the Water Quality
               Classification law and technically-defensible numeric criteria have been
               established by the Department;

           *•   Data essential to the modeling of the recommended total suspended solids load
               reductions on the Presumpscot River had been collected to assess aquatic life
               issues on the Androscoggin River (under State requirements for a 401 Water
               Quality certification for a hydropower license renewal);

           *•   Teamwork and collaboration between DEP, water quality modelers, and aquatic
               biologists resulted in an approach that integrated technical information and
               expertise from both disciplines. It also provided a means for the Department to
               control a stressor (TSS) for which the State has no  standards.

       6.8     References

       Courtemanch, D.L., P. Mitnik, and L. Tsomides.  1997.  Dec. 8, Memorandum to Greg
           Wood, Maine Department of Environmental Protection Licensing Section, Augusta,
           Maine.

       Davies, S.P., L. Tsomides, D.L. Courtemanch, and F. Drummond.  1995. Maine
           biological monitoring and biocriteria development program. Maine Department of
           Environmental Protection, Augusta, Maine.
6-18                                                           U.S. Environmental Protection Agency

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                             Stressor Identification Guidance Document
       Davies, S.P. and L. Tsomides.  1997. Methods for biological sampling and analysis of
          Maine's inland waters. DEP-LW/07-A97.  Maine Department of Environmental
          Protection, Augusta, Maine.

       Davies, S.P., L. Tsomides, J.L. DiFranco, and D.L. Courtemanch.  1999. Biomonitoring
          retrospective: Fifteen year summary for Maine rivers and streams. DEPLW1999-
          26. Maine Department of Environmental Protection, Augusta, Maine.

       Hilsenhoff, W.L.  1987. An improved biotic index of organic stream pollution. Great
          Lakes Entomol.  20:31-39.

       Mitnik, P. 1994. Presumpscot River waste load allocation.  Maine Department of
          Environmental Protection, Augusta, Maine.

       	. 1998. Presumpscot River supplemental report to waste load allocation. Maine
           Department of Environmental Protection, Augusta, Maine.
Chapter 6: Presumpscot River, Maine                                                            6-19

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                             Stressor Identification Guidance Document
 Chapter 7
 Little Scioto River,  Ohio
       7.1    Executive Summary

       This case study of the Little Scioto River represents an application of the SI process to a
       complicated system. Impairment of the Little Scioto River reflected several impacts
       caused by different stressors.  Originally, the data on the Little Scioto were collected and
       analyzed as part of the Ohio Environmental Protection Agency (OEPA) state monitoring
       program during 1987, 1991, 1992 and 1998 (OEPA 1988b, 1992, 1994, unpublished data
       from 1998) and as research for a USEPA methods development program.  The
       monitoring data were subsequently analyzed for this SI case study to demonstrate how
       data collected from monitoring programs could be used to identify probable causes of
       biological impairment.

       The SI investigation was initiated because criteria in the state of Ohio's water quality
       standards were violated in parts of the Little Scioto, a small river in north-central Ohio
       (Yoder and Rankin 1995b). The SI investigation involved a 9-mile stretch of the Little
       Scioto River near Marion, Ohio, where there was evidence of biological impairment.

       The State of Ohio has a "tiered" set of aquatic life use designations based on narrative
       definitions of specific aquatic uses that are protected by a set of numeric biocriteria,
       chemical criteria, and habitat criteria. Ohio EPA determines biological impairment of
       stream segments  by comparing study sites to the numeric biocriteria in their water
       quality standards. OEPA uses standard multimetric indices, including the Index of
       Biotic Integrity (IBI), the Invertebrate Community Index (ICI) (OEPA 1989a), and the
       Qualitative Habitat Evaluation Index (QHEI) (OEPA 1989c). Little Scioto River data
       collected in 1987 and 1992 showed a condition of "fair" to "severe impairment" in the
       stretch from river mile (RM) 9.2 to where the Little Scioto joins the Scioto River, just
       downstream of RM 0.4.

       Describe the Impairment

       Three distinctive impairments (A, B, and C) were identified for the causal evaluation (at
       RM 7.9, 6.5, and 5.7, respectively). Impairment A was characterized by a loss offish
       and benthic invertebrate species, a decrease in the number of individual fish, and an
       increase in the relative weight offish. Impairment B was characterized by a decrease in
       the relative weight offish and a large increase in deformities, fin erosion, lesions, tumors
       and anomalies  (DELTA).  Impairment C was characterized as having a further increase
       in DELTA and extirpation of a Tribe of midges, the Tanytarsini.

       List Candidate Causes

       Stressors impacting the upper portion of the river were identified as mostly non-point
       nutrient and sediment loadings associated with agriculture. Beginning at river mile 9.0
       and continuing to the mouth, the river is channelized. The Little Scioto River at and
       below Marion, Ohio, however, has been notably contaminated with elevated levels of
       polycyclic aromatic hydrocarbons (PAH). Creosote and metals in sediment samples and


Chapter 7: Little Scioto River, Ohio                                                             7-1

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                             Stressor Identification Guidance Document
       ammonia, phosphorous (P), total nitrogen (N) were detected in water samples (OEPA
       1994).

       Based on the knowledge about the site and effects, six candidate causes were
       hypothesized to account for the three major biological impairments observed in the Little
       Scioto study area:

           1.  Habitat alteration: embedded stream and deepened channel

           2.  Exposure to PAHs

           3.  Metal contamination

           4.  Ammonia Toxicity

           5.  Low Dissolved Oxygen/High Biological Oxygen Demand

           6.  Nutrient Enrichment

       Characterize Causes: Eliminate

       Candidate causes were eliminated because the level of exposure to the candidate cause
       did not increase compared to the nearest upstream location. Candidate causes that
       remained after the elimination step are listed below:

           >  Impairment A (RM 7.9) — habitat alteration, metal contamination, and nutrient
              enrichment remained as probable causes.

           *•  Impairment B (RM 6.5) — PAH contamination, metal contamination, ammonia
              toxicity, low dissolved oxygen/high biological oxygen demand, and nutrient
              enrichment remained as probable causes.

           *•  Impairment C (RM 5.7) — metal contamination, ammonia, and nutrient
              enrichment remained as probable causes.

       Characterize Causes: Diagnose

       No evidence strong enough to support diagnosis was available for any of the candidate
       stressors.

       Characterize Causes: Strength of Evidence

       A strength of evidence approach was used to examine the remaining causes with regard
       to each impairment. Evidence based on other situations and biological knowledge were
       especially important including consistency of association and plausibility of mechanism
       and stressor-response.

       Characterize Causes: Identify Probable Causes

       Impairment A
       At Impairment A, the increased relative weight is probably caused by the artificial
       deepening of the channel that allows larger fish to live there.  The mechanisms were


7-2                                                            U. S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       probable, and consistency of association and experiments from other sites in Ohio and
       elsewhere supported this finding for the specific impairments. The extirpation offish
       and benthic invertebrates seems to be most likely due to embedded substrates.  Although
       low DO could also be a cause, upstream locations had even lower DO levels and yet had
       a greater variety offish and invertebrate species.

       Although metals were present, the likelihood of response at these concentrations is low.
       Furthermore, the types of changes in the community, especially an increase in the
       relative weight offish, is very unlikely with the candidate cause of metals. Although P
       levels are slightly higher, effects are not associated with these phosphorous
       concentrations elsewhere, and they do not exceed Ohio proposed criteria values for
       effects. PAH and ammonia had already been eliminated because levels were the same or
       lower than upstream. Low DO /BOD was also eliminated as an overall pathway;
       however, low DO associated with channelization may still play a role, especially with
       respect to the slight increase in the percentage of DELTA.

       Impairment B
       A single  probable cause, toxic levels of PAH-contaminated sediments, is likely for the
       three manifestations of Impairment B:  decreased relative weight, increased DELTA, and
       decreased species. All of the evidence support PAH contamination as the cause. There
       is a complete exposure pathway at the location, and a clear mechanism of action for each
       of the effects.  The single most convincing piece of evidence is that the cumulative toxic
       units of PAH were more than 300 times the probable effects level.

       Metals are  at sufficient concentrations to cause effects; however, they are at levels close
       to upstream concentrations, and are less than 2% as toxic as the lowest cumulative toxic
       units of PAH.  Metal concentrations are high enough that they should be considered a
       potentially masked cause. Reduced DO resulting from increased BOD is unlikely
       because,  downstream, even greater levels of BOD did not cause reduction of dissolved
       oxygen.  Ammonia and nutrient enrichment are unlikely given that state criteria levels
       were met and given the much stronger evidence for PAH. Habitat  alteration continues to
       impair the site, but it is not the cause of the increased DELTA, decreased relative weight,
       or the additional decline in the number of species, because the level of embeddedness
       was similar to upstream.

       Impairment C
       At Impairment C, increased % DELTA and % Tanytarsini may have different causes.
       Increased DELTA in fish is probably caused by increased P and N. Nutrients, especially
       P, have been associated with increased fin erosion and lesions, but some uncertainty
       exists since P acts indirectly. Another candidate cause is also probable, namely,
       ammonia.  Ammonia is slightly higher at Impairment C than at Impairment B, and
       exceeded ammonia criterion values.  Biological gradients were absent for ammonia;
       however, this may have been a statistical artifact given the number of sites available  to
       perform the analysis, and the potential interference from other stressors downstream.

       Metals are  considered unlikely, because very specific surface lesions are only
       occasionally noted as effects from long-term exposure, and only some metal
       concentrations were slightly greater than at Impairment B.  Metal concentrations are high
       enough that they should be considered a potentially masked cause.

       The probable cause of extirpation of Tanytarsini at Impairment C is more uncertain
       because less is known about the natural history and stressor-response relationships of


Chapter 7: Little Scioto River, Ohio                                                               7-3

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                              Stressor Identification Guidance Document
       these benthic invertebrates. Nutrient enrichment still seems to be the most likely cause
       since all of the strength of evidence considerations were consistent.

       PAH contamination and habitat alteration continue to impair the site, but they are not the
       cause of the increased percent DELTA or extirpation of Tanytarsini.

       Identify Probable Cause

       The most probable causes were:

           >   Impairment A (RM 7.9) — Siltation and deepened channel are consistent with
               impairment A. The magnitude of the alteration and clear difference from
               upstream locations strongly support this cause.

           >   Impairment B (RM 6.5) — PAH-contaminated sediments are likely causes for
               the three manifestations of Impairment B.

           >   Impairment C (RM 5.7) — The causal characterization at Impairment C is less
               certain, but the strength of evidence favors increased nutrient enrichment as the
               cause.

       The Little Scioto case study is a good example of a complex system requiring a detailed
       analysis. Although it was possible to identify the dominant causes of specific
       impairments, other causes were present that had the potential to cause impairments if the
       dominant cause was removed.  For instance, habitat alteration associated with
       channelization would still impair the entire river below RM 9.0.

       7.2     Introduction

       The Little Scioto case study involves a nine-mile stretch of a river suffering from several
       impairments with different causes. Typical of similar stressor investigations, the data
       examined for this case study were  not collected or originally analyzed specifically for the
       Stressor Identification Technical Guidance Document. Rather, they were collected as a
       part of the Ohio EPA state monitoring program during 1987, 1991, 1992 and 1998
       (OEPA  1988b, 1992, 1994, unpublished data from 1998), and as research for a USEPA
       methods development program. These monitoring data were subsequently analyzed in
       this study to demonstrate how data collected from existing monitoring programs could be
       used to identify probable causes of biological impairment.

       Various types of data were used in this case study, including chemical analyses
       (sediment, water, and fish tissue) and biological assessment (biological community and
       physical habitat). Methods for the collection and analysis of chemical data are described
       in Ohio  EPA (1989c). In 1992, one grab sample was taken, whereas in 1987, multiple
       grab samples were taken.  Other Ohio EPA data sets included biological assessment data
       on fish and invertebrate assemblages and physical habitat measurements. In Ohio,
       impairment of stream aquatic life uses are defined by standard multimetric indices
       including the Index of Biotic Integrity (IBI) and the Invertebrate Community Index (ICI)
       (OEPA  1989a). These indices have been promulgated as numeric biocriteria in the
       State's water quality standards. The quality of the habitat is characterized using the
       Qualitative Habitat Evaluation Index (QHEI) (OEPA 1989c). These methods are
       described in detail by Ohio EPA (1989c).  Biochemical measurements of impairment
       included bile metabolites measured according to Lin et al. (1996) and ethoxy


7-4                                                            U. S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       resorufin[O]deethylase (EROD) activity measured according to Cormier et al. (2000b).
       Although the attempt was made to use biological and chemical data from the same
       locations, in some cases, chemical measurements were recorded at a location that did not
       exactly coincide with the location of biological assessment (e.g., RM 5.8 and RM 5.7,
       respectively).  However, the distance between the chemical and biological sample sites
       was negligible or overlapped, and the data were able to be used to analyze associations
       between candidate causes and the biological impairment.

       The Little Scioto River is a small river in north-central Ohio that empties into the Scioto
       River (Figure 7-1). It drains primarily farmland in the northeastern quadrant of the
       Eastern Corn Belt Plains ecoregion. The soils in this area are glacial till overlying
       limestone, dolomite, and shale bedrock. The water table has been lowered in much of
       the watershed by extensive use of tile drainage in crop fields. Near Marion, Ohio, the
       Little Scioto is biologically impaired.

       This causal investigation was initiated because the State of Ohio water quality standards
       related to biological criteria were violated (Yoder and Rankin 1995a).  The State of Ohio
       has a "tiered" set of aquatic life use designations based on narrative definitions of
       specific aquatic uses, which are protected by numeric criteria.

       The majority of Ohio rivers and streams are designated as Warmwater Habitat (WWH)
       (Yoder and Rankin 1995a). This designation is narratively defined as supporting a
       balanced, reproducing aquatic community. Quantitatively, the minimum criteria
       required to be in attainment of WWH standards are defined as the 25th percentile values
       of reference condition scores for a given index, site type,  and ecoregion.  The choice of
       the 25th percentile is considered to be conservative and will likely be influenced by the
       inclusion of marginal sites as well as reference quality sites.

       The Little Scioto River is considered Warmwater Habitat above RM 7.9 and a Modified
       Warmwater Habitat at and below RM 7.9 (see Figure 7-1). The Modified Warmwater
       Habitat (MWH) criteria are based on comparisons to a different reference condition than
       are used for the WWH criteria (Yoder and Rankin 1995a). The MWH  designation is a
       non-fishable aquatic life use, and is designed to protect streams that have been too
       impacted, or modified, to meet WWH standards. MWH streams are unlikely to  recover
       sufficiently to meet WWH designation.  Consequently, MWH criteria are typically lower
       than WWH criteria. In spite of poorer water quality conditions (such as low dissolved
       oxygen, high ammonia concentration, and increased nutrient input), MWH streams are
       nonetheless able to support permanent assemblages of tolerant species.

       7.3     Evidence of Impairment

       In 1987 and 1992, sampling and measurements for community and habitat indices (IBI,
       ICI, QHEI) were conducted by OEPA along the Little Scioto River. Standardized field,
       laboratory and data processing methods followed OEPA procedural guidelines (OEPA
       1988a, OEPA 1989a,b,c, Rankin 1989). Fish and macroinvertebrates were sampled at
       seven sites along the river, from river mile (RM) 9.5 to 0.4 (Figure 7-1). Index and
       metric scores for IBI, ICI, and QHEI used in this study were obtained from data sets that
       were generated and made available by OEPA as well as various OEPA reports (1988b,
       1992, and 1994).
Chapter 7: Little Scioto River, Ohio                                                                7-5

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                              Stressor Identification Guidance Document
                         SOURCES OF
            RIVER MILE   STRESSORS

                    9.2
         Impairment A 7.9
         Impairment B 6.5

         Impairment C 5.7
                        Defunct creosote plant
                        RaU Facility
                          1  Miles
       Figure 7-1. Map of the Little Scioto River, Ohio, showing sites where fish were
       sampled. (Approximate locations of significant physical features, tributaries and point
       source inputs are noted.  The small inset shows the location of the study area in the
       state of Ohio. Locations of Impairments A, B and C are also shown.)
       Of the seven sites sampled in 1987, the highest IBI score was 34 (out of a possible score
       of 60), which occurred at RM 9.2.  This score translates to a. fair ranking according to
       WWH standards. The remainder of sites were described as severely impaired, with IBI
       scores between 25 and 12 (the lowest possible IBI score) (OEPA 1994, Yoder and
       Rankin 1995a).  In 1992, the IBI score at RM 9.2 decreased by one point to 33.
       However, in 1992, the IBI score dropped 9 points to a score of 24 between RM 9.2 and
7-6
U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       RM 7.9. Another 5 point drop occurred at KM 6.5 and scores stayed between 19 and 20
       through RM 2.7. At RM 0.4, the IBI score climbed back to 25, greater than the adjacent
       upstream site's score, but still indicating impairment.  Figure 7-2A illustrates the
       fluctuation of the IBI at the seven sites during the two sampling years (1987 and 1992).

       Figure 7-2B traces a similar pattern of impairment for the invertebrate index during the
       1987 and 1992 sampling years.  The ICI met WWH aquatic life use standards in 1987
       and 1992 at RM 9.2, with scores of 40 and 38, respectively (Figure 7-2). In 1992, the ICI
       score declined 22 points at RM 7.9 with a score of 16, considered fair, but below MWH
       aquatic life use standards.  Scores further declined 12 or more points at RM 6.5, 5.7 and
       4.4, with scores ranging between 6 and 10. These scores are indicative  of highly
       impaired conditions (OEPA 1994, Yoder and Rankin 1995a).  ICI scores increased to a
       value of 18 downstream at RM 2.7 and RM 0.4.  In 1987, both IBI and ICI  scores were
       greater at RM 6.5 and then declined at RM 5.7, and remained very low to the mouth of
       the Little Scioto.

A









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       Figure 7-2. Spatial changes in fish IBI (A) and benthic macroinvertebrate ICI (B)
       values in the Little Scioto River in 1987 (OEPA 1988) and 1992 (OEPA 1994).
Chapter 7: Little Scioto River, Ohio
7-7

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                              Stressor Identification Guidance Document
       The impairments seen below RM 9.2 were more specifically described by examining the
       metrics that make up the IBI and the ICI. This information was combined with the
       changes seen in the overall IBI and ICI scores to determine whether distinctive patterns
       of impairment could be identified. Each distinctive impairment required a separate
       causal evaluation.

       A subset of the fish and macroinvertebrate metrics, selected to highlight differences in
       community patterns, is shown in Figures 7-3A (fish) and 7-3B (macroinvertebrates). The
       complete list of values for the metrics is shown in Tables 7-13 and Table 7-14 (Please
       note that Tables 7-13 through 7-20 are located in Section 7.13, "Additional Data
       Tables").  One of the metrics, relative weight offish, is not a component of the IBI but a
       component of another index, the Modified Index of Well-being (MIWB).
       Examination of the spatial distribution of the IBI, ICI, and metric patterns in 1992
       indicates that at least three distinct impairments occurred:

           *•   Impairment A was seen at RM 7.9 where a marked drop in both the IBI and ICI
              occurred relative to the upstream location at RM 9.2. Specific fish metrics that
              appeared to correspond to this drop included decreases in the number of
              individuals minus tolerant fish, decreased total number of species, and increased
              relative weight. In addition, the percentage of mayfly species decreased.

           >   Impairment B occurred at RM 6.5 and corresponded with an additional decrease
              in both the IBI and the ICI. Relative the upstream location at RM 7.9, fish
              relative weight decreased, the number of deformities, erosions, lesions, tumors
              and anomalies (DELTA) increased, and the percentages of mayflies and
              Tanytarsini midges  also decreased while the percentage of tolerant organisms
              increased.

           *•   Impairment C occurred at RM 5.7.  There was no change in the IBI relative to
              RM 6.5, although relative weight offish decreased and DELTA increased.  The
              invertebrates had variable changes depending on the sampling year. In 1987 and
               1992, the  % Tanytarsini midges decreased or disappeared entirely. Changes in
              the metrics at these  three locations are summarized in Table 7-1.

       The biological assessment data for the remaining locations showed a pattern similar to
       Impairment C, with the possibility of intensification at RM 4.4 and some improvement in
       metric scores occurring at RM 2.7 and 0.4.  A fourth impairment was not hypothesized
       for RM 4.4 because the pattern offish and invertebrate metrics were fairly similar to
       those  seen at RM 5.7.
7-8                                                            U. S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
A L2
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River Mile
           Figure 7-3. Changes in the IBI and ICI scores over distance in the Little Scioto
           River, 1992. ((A) Changes in the relative scores for the total number of individual
           fish minus tolerant fish (# fish minus tolerant), the number of species (# species),
           the relative weight of fish (relative weight) and the percentage of DELTA. (B)
           Changes in the relative abundances of percent Ephemeroptera, Tanytarsini,
           tolerant organisms, and Cricotopus, in the Little Scioto  River.  Normalized values
           were calculated by dividing the value  at the individual site by the highest value for
           all sites.)
Chapter 7: Little Scioto River, Ohio
7-9

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                              Stressor Identification Guidance Document
         Table 7-1. Summary of the three impairments that were considered in the Little
         Scioto River. (Each location is scored relative to the location immediately upstream,
         based on 1992 data.)
Response
Impairment A
RM7.9
Impairment B
RM6.5
Impairment C
RM5.7
Fish
# of individuals minus
tolerant individuals
# Species
Relative Weight
DELTA
-
-
7.9
0
+
-
-
0
-
0
-
5.7
Invertebrates
% Mayflies
% Tanytarsini midges
% Tolerant taxa
% Cricotopussp.
-
0
0
-
-
-
0
0
-
-
-
0
       (+) indicates an increase in the metric relative to the next upstream location
       (-) indicates a decrease
       (0) indicates no change.
                                                        Stressor Identification
                                                                  LIST CANDIDATE CAUSES
                                                                    ANALYZE EVIDENCE
7.4    List Candidate Causes

Evidence Used to Develop Candidate Causes

Many point and non-point sources of pollutants are
associated with the Little Scioto River. Stressors
impacting the upper portion of the river are mostly
non-point nutrient and sediment loadings associated
with agriculture. However, the Little Scioto River,
at and below Marion, Ohio, has been notably
contaminated with elevated levels of polycyclic
aromatic hydrocarbons (PAH). Creosote and metals
were found in sediment samples, and ammonia was
detected in water samples (OEPA 1994).  The
OEPA has, in fact, recently requested Superfund
support in the clean-up of an abandoned wood
creosote plant suspected of polluting the river since
the 1860's (Edwards and Riepenhoff 1998). An oily
sheen was noted on the river between river miles 6.5 and 5.8 during a site visit in 1992
(Cormier, pers. observ.). In-stream habitat quality was also degraded by channelization
that took place in the early 1900's (OEPA 1994).  Locations of the potential sources and
stressors, including a landfill and wastewater treatment plant (WWTP), are shown in
Figure 7-1.
                                                                   CHARACTERIZE CAUSES
Eliminate

Dagnose
7-10
                                                        U.S. Environmental Protection Agency

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                             Stressor Identification Guidance Document
       List of Candidate Causes and Scenarios

       As noted previously, three distinctive impairments were identified for the causal
       evaluation. Based on the knowledge of the sources and effects, six candidate causes
       were formulated to account for the impairment observed at each site. A conceptual
       model of these candidates is provided in Figure 7-4.

       1. Habitat Alteration - Habitat alteration, resulting from channelization, combines a
       complex interaction of several stressors.  These stressors are evident at RM 7.9 and
       continue to the mouth of the river. Channelization can alter biological communities by
       changing the physical structure of the stream and the flow characteristics of the water,
       ultimately lowering dissolved oxygen, increasing siltation, and reducing substrate
       complexity. This complex suite of stressors also includes: decreased woody debris,
       which reduces available substrate and changes the energy source; decreased sinuosity,
       which changes flow characteristics; erosional patterns and substrates; increased channel
       depth that favors larger species offish; loss of pools that act as refugia; and loss of riffles
       that oxygenate water and transport sediment (Tarplee et al. 1971, Karr and Schlosser
       1977, Yount and Niemi 1990, Allan 1995).

       2. PAH and 3. Metals - Biological impairment could also have been caused by toxic
       stress. Historically, the river has provided a means of waste  disposal for various
       industries, whose effluents have contained metals, PAH, and creosote. Waste materials
       may have also been buried in the landfill below RM 6.5 (OEPA 1994). All are
       potentially toxic to aquatic life, and some have the ability to  bioaccumulate through  the
       food web (Eisler 2000a,b). Thus, two candidate causes emerge: candidate cause #2 is
       that biological impairment has occurred due to PAH exposure (with PAH emanating
       from creosote deposits), and candidate cause #3 attributes  impairment to metal
       contamination.

       4. Ammonia Toxicity - Ammonia is directly discharged into streams by point sources
       (Russo 1985, Miltner and Rankin 1998).  Ammonia can also be formed as the result of
       nutrient enrichment. When dissolved oxygen levels are low, nitrates are  reduced to
       ammonium ion.  If pH is high, some of the ammonium ion is converted to un-ionized
       ammonia, which is toxic to aquatic organisms (Russo 1985). Moreover, pH may rise
       during periods of high photo synthetic rates from bicarbonate depletion.  High amounts of
       nutrients often lead to increased algal growth rates, and the conversion of ammonium to
       un-ionized ammonia is expedited  (Dodds and Welsh 2000).

       5. Low Dissolved Oxygen/ High Biological Oxygen Demand - Depletion of DO
       commonly occurs from organic enrichment (Smith et al. 1999).  Organic enrichment is
       the most common cause of increased biological oxygen demand (BOD) (Allan 1995).
       Potential sources of excess organic matter within the study area include a waste water
       treatment plant (WWTP) and several combined sewer outfalls (CSOs), as well as
       upstream, non-point sources. Organic matter is also produced by excess  algal growth
       from nutrient enrichment (Dodds  and Welsh 2000). Algal blooms themselves result in
       increased organic matter regardless of DO depletion. The  algal bloom may suffice to
       raise BOD so that DO is depleted. Because no chlorophyll a or algal biomass data were
       collected in this study, the cause of BOD to the river can only be estimated from BOD,
       measured at several points, and COD (chemical oxygen demand) measured at point
       sources such as the WWTP above RM 5.4 in 1998.
Chapter 7: Little Scioto River, Ohio                                                              7-11

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   Sources
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 Un-ionized
 Ammonia
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Figure 7-4. A conceptual model of the six candidate causes for the Little Scioto stressor identification. (Potential sources are
listed in top most rectangles. Potential stressors and interactions are located in ovals. Candidate causes are
numbered 1 through 6.  Note that some causes have more than one stressor or more than one step associated with it.
The impairments are located in the lower rectangle.)

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                              Stressor Identification Guidance Document
       6. Nutrient Enrichment - The sixth and final candidate cause is a less extreme form of
       nutrient enrichment. Primary production and organic matter loading to the sediments are
       increased, but not enough to reduce DO. This can cause changes in fish and benthic
       macroinvertebrate assemblages, including changes in dominant species, and greatly
       increased abundance and biomass (Carpenter et al. 1988, Rankin et al.1999, Smith et al.
       1999, Dodds and Welsh 2000, Edwards et al. 2000).  This form of nutrient enrichment is
       also associated with fin erosion (Rankin et al.  1999).

       7.5     Analyze Evidence to Eliminate Alternatives

       7.5.1   Data Analyzed
                                                                   LIST CANDIDATE CAUSES
                                                                     ANALYZE EVIDENCE
Habitat alteration-related data
Data on the spatial location of habitat alteration was
obtained by using the Qualitative Habitat Evaluation
Index (QHEI). The QHEI incorporates measures of
habitat condition and has been correlated with the
IBI.  This index uses eight interrelated metrics,
which assess substrate type  and quality; in-stream
cover type and amount; channel morphology;
riparian width and quality and bank erosion; pool /
riffle characteristics including depth, current, pool
morphology, substrate stability and riffle
embeddedness; and finally gradient (Rankin 1989).
Based on these metrics, a total score is assigned to a
stream reach out of a possible 100 points, with
greater scores indicating higher quality.  The channel morphology and substrate metrics
are particularly relevant for this case because of the channelization (Figure 7-5).  Values
for the QHEI and  its component metrics are given in Table 7-15 (see Section 7.13).
                                                         Stressor Identification
                                                                   CHARACTERIZE CAUSES
                    95      79       65       58
                    95      79       65       58
                                                             27       04
          Figure 7-5. Selected QHEI metrics for 1987 and 1992.  (Scores are qualitative
          ranks.)
Chapter 7: Little Scioto River, Ohio
                                                                                     7-13

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                              Stressor Identification Guidance Document
       Chemical Data
       Data on sediment and in-stream chemistry were used to evaluate the spatial location of
       the remaining candidate causes (#2-6). Nutrient concentrations measured in water
       included ammonia, nitrates and nitrites (NOX), phosphorus (P), and BOD. Ambient
       levels of potential toxic chemicals were determined for sediment and water.  Results of
       chemical analyses are presented in Tables 7-16, 7-17 and 7-18 (See Section 7.13), and
       Figures 7-6, 7-7, and 7-8.

       While PAHs were not detectable at the upstream sites (RM 9.5 and 7.9), many PAHs
       were detected between  RM 6.5 and 0.4 (Table 7-16) (Figure 7-6).  Spearman Rank
       Correlations between chemical and biological data from 1992 at RM 5.7 to 0.4 are
       shown in Table 7-2 through 7-5.

       Metals were found in sediments at relatively high concentrations at RM 6.5 and
       downstream (Table 7-17; see Section 7.13) (Figure 7-7). These included lead, cadmium,
       copper, chromium, zinc, and mercury.  Arsenic was relatively high at upstream reference
       and study sites. Spearman rank correlations between metals and biological data from
       1992 at RM 5.8 to 0.4 are shown in Table 7-3. Strong correlations having the sign that is
       consistent with the hypothesis were noted for copper and mercury.

       The water quality parameters ammonia, nitrates and nitrites (NOX), and BOD increased
       substantially at RM 5.8, and remained elevated. Dissolved oxygen declined at 7.9 and
       remained low to RM 0.4 (Table 7-18; see Section 7.13) (Figure 7-8). Spearman rank
       correlations of water chemistry and biological endpoints are presented in Table 7-4.
       Percent Tanytarsini are significantly correlated with DO, BOD, NOX and  P, and the
       negative direction of the slope was consistent with ecological theory. Percent DELTA
       was correlated with the same parameters (DO, BOD, NOX and P) but at the 0.8 level,
       whereas percent Cricotopus was associated with ammonia and the QHEI.

       7.5.2   Associations between Candidate Causes and Effects

       The associations between candidate causes and effects were analyzed by  combining data
       on the location of the three impairments with data on habitat  quality and chemical
       concentrations in water and sediments.  The analyses evaluated whether the candidate
       causes and each of the three impairments were spatially co-located, and whether a
       gradient in recovery corresponded with a decrease in the candidate cause. These
       associations are organized in table format (Table 7-5).

       The first objective of the analysis was to determine if there was evidence that the
       candidate cause occurred at the same place as the  impairment but not where that
       particular impairment was absent.  Plots of the channel quality and substrate metrics
       from the QHEI are shown in Figure 7-5.  The chemistry values relevant to each of the
       causal scenarios are shown in Figures 7-6, 7-7 and 7-8. Each graph shows the level or
       concentration of the parameter. The presence or absence of candidate causes at the
       locations of Impairments A, B, and C are summarized in Table 7-5.
7-14                                                            U.S. Environmental Protection Agency

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                               Stressor Identification Guidance Document
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         Figure 7-6. Mean PAH concentrations from the sediment (mg/kg) in the Little Scioto
         River 1987-1998.  ((o) indicates below detection limit. Absence of bar indicates no data
         available.)
Chapter 7: Little Scioto River, Ohio
7-15

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                              Stressor Identification Guidance Document


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       Little Scioto River 1987-1998. ((o) indicates below detection limit. Absence of bar
       indicates no data available.)
7-16
U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
16


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        Figure 7-7. Mean metal concentrations from the sediment (mg/kg) in the Little Scioto
        River from 1987-1998.  (Absence of bar indicates no data available.)
Chapter 7: Little Scioto River, Ohio
7-17

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                           Stressor Identification Guidance Document
            10
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            10
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1 1






I I

           25
             2
         n 1.5
        Z    1
           0.5
           500
           400
        g1 300
        «  200
           100
             3
           2.5
             2
        0.  1.5
             1
           0.5
            10
        O
        0   4
            25
            20
            1 =
            10
            5
            0
                 11.1    9.5    7.9     7.1     6.5    5.8    44     27     0.4









	





tm


                 11.1    95    7.9     7.1     6.5    58    44     27     04
                 11.1    9.5    7.9     7.1     6.5    5.8    4.4    2.7     0.4
MSB
                                              1
                 11.1    9.5    7.9    7.1
                                          6.5    5.8
                                                      4.4
                        i
                11.1    9.5    7.9     7.1     6.5    5.8    4.4     2.7     0.4
                   m
                 11.1    9.5    7.9     7.1     6.5    5.8    4.4    2.7     0.4
                 11.1    9.5    7.9     7.1     6.5    5.8    4.4     2.7     0.4
                 11.1    9.5    7.9     7.1     6.5    5.8    4.4    2.7     0.4
                                                             2.7     0.4
                                       1987
                                      D 1992
                                       1998
       Figure 7-8. Mean water chemistry values from the Little Scioto River from 1987-1998.
       (BOD, NOX, Ammonia, CaCO3, PO4, are all mg/L, Temperature (°C).  DO is also mg/L
       and is the minimum value obtained from grab samples for each year. Absence of a bar
       indicates no data for that year.)
7-18
                      U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       Table 7-2. Spearman rank correlations with selected metrics and the IBI and ICI from
       1992 and selected PAHs.  (Reflects only values from RM 5.8 to 0.4. Correlations N=4).
Parameter
Anthracene (#2)
Benzo[a]anthracene (#2)
Benzo[ghi]perylene(#2)
Benzo[a]pyrene (#2)
Chrysene (#2)
Dibenzo[a,h]anthracene
(#2)
Fluoranthene (#2)
Fluorene (#2)
Naphthalene (#2)
Phenanthrene (#2)
Pyrene (#2)
DELTA
0.60
0.00
0.00
0.00
0.80*
-0.21
0.00
0.74
0.26
0.60
0.00
% Tanytarsini
Midges
-0.74
-0.21
-0.21
-0.21
-0.95*
-0.06
-0.21
-0.89*
-0.54
-0.74
-0.21
% Cricotopus
-0.20
-0.40
-0.40
-0.40
0.40
-0.21
-0.40
0.11
0.26
-0.20
-0.40
          Correlations above 0.8
       Table 7-3. Spearman rank correlations with selected metrics and the IBI and ICI from
       1992 and selected metals.  (Reflects only values from RM 5.8 to 0.4. Correlations N=4).
Parameter (Candidate
Cause)
Arsenic (#3)
Cadmium (#3)
Chromium (#3)
Copper (#3)
Lead (#3)
Mercury (#3)
Zinc (#3)
DELTA
0.74
0.20
0.80*
1.00*
0.40
1.00*
0.40
% Tanytarsini
Midges
-0.89*
0.11
-0.63
-0.95*
-0.32
-0.95*
-0.32
% Cricotopus
0.11
-0.60
0.40
0.20
0.80*
0.20
0.80*
         * Correlations above 0.8
Chapter 7: Little Scioto River, Ohio
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                             Stressor Identification Guidance Document
       Table 7-4.  Spearman rank correlations with selected metrics and the IBI and ICI from
       1992 and selected water quality and habitat quality measurements.  (Reflects only
       values from RM 5.8 to 0.4. Correlations N=4).
Parameter (Candidate
Cause)
Channel Metric (#1)
QHEI (#1)
Ammonia, N (#4)
Dissolved oxygen maximum
(#5)
Dissolved oxygen minimum
(#5)
BOD (#5)
Nitrate-nitrite, N (#4,5,6)
Phosphorus, total P (#5,6)
DELTA
0.77
0.20
0.40
0.80*
0.60
0.80*
0.80*
0.80*
% Tanytarsini
Midges
-0.82*
-0.32
-0.32
-0.95*
-0.74
-0.95*
-0.95*
-0.95*
% Cricotopus
0.77
1.00*
0.80*
0.40
-0.20
0.40
0.40
0.40
          Correlations above 0.8
       The second objective was to determine if the cause increased compared to the nearest
       upstream location.  Statistical analyses were not used to determine an increase because
       the power would be very weak due to small sample sizes. Even a small increase was
       accepted since it might represent a threshold  for the effect (Table 7-5).

       The third objective of the analyses was to evaluate whether a gradient in the intensity of
       the potential cause  corresponded to a gradient of recovery in impairment.  The gradient
       analysis was conducted only for Impairment C, which was observed at four contiguous
       locations (i.e., RM  5.8 to 0.4). The recovery  of Impairment B could not be analyzed
       since it would be masked by Impairment C. Similarly, any recovery of Impairment A
       would be masked by both B and C. The gradients in environmental parameters and the
       IBI and ICI were examined visually by comparing Figures 7-2 and 7-3 with Figures 7-5
       through 7-8. The IBI and ICI metrics for 1987 and 1992 data are shown in Table 7-13
       and Table 7-14, respectively. In addition, Spearman's rank correlations were calculated
       using the 1992 data set to relate the biological metrics (shown in Figure 7-3) with each of
       the parameters related to the candidate causes.  The results of this analysis are shown in
       Tables 7-2 through 7-4.

       Two metrics are more severe at Impairment C:  % DELTA and % Tanytarsini midges
       decrease and % Cricotopus increases.  Percent DELTA were significantly correlated
       with copper and mercury, and moderately correlated with chrysene, chromium, BOD,
       nitrate, phosphorous, and maximum DO.  The change in tanytarsini midges was
       negatively and strongly correlated with chrysene, copper, mercury, BOD, nitrate,
       phosphorous, maximum dissolved oxygen, and moderately correlated with fluorene,
       arsenic, and the channel metric. The change  in % Cricotopus was strongly positively
       correlated with QHEI and moderately correlated with lead, zinc, and ammonia.
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U.S. Environmental Protection Agency

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                               Stressor Identification Guidance Document
         Table 7-5.  Evidence for eliminating candidates causes at Impairments A, B, and C.

Impairment A
Impairment B
Impairment C
Habitat Alteration (Candidate Cause 1)
Is there exposure at the
same location as the
impairment?
Is exposure increased
over the closest
upstream location?
Is there a gradient of
recovery as exposure
decreases?
Is the exposure pathway
complete?
Yes
Yes
NA*
(Gradient in
impairment is
masked by B
and C)
Yes
Yes
No
NA
(Gradient in
impairment is
masked by C)
Yes
Yes
No
No
(Correlation
coefficients have
the wrong signs,
with % DELTA and
% Tanytarsini)
Yes
PAH Contamination (Candidate Cause 2)
Is there exposure at the
same location as the
impairment?
Is exposure increased
over the closest
upstream location?
Is there a gradient of
recovery as exposure
decreases?
Is the exposure pathway
complete?
No
No
NA
(Gradient in
impairment is
masked by B
and C)
No
Yes
Yes
NA
(Gradient in
impairment is
masked by C)
Yes
Yes
No
(based on
metabolite values
in fish)
Inconclusive
(Mixed results)
Yes
Chapter 7: Little Scioto River, Ohio
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                              Stressor Identification Guidance Document
         Table 7-5 (continued). Evidence for eliminating candidates causes at Impairments
         A, B, and C.

Impairment A
Impairment B
Impairment C
Metal Contamination (Candidate Cause 3)
Is there exposure at the
same location as the
impairment?
Is exposure increased
over the closest
upstream location?
Is there a gradient of
recovery as exposure
decreases?
Is the exposure pathway
complete?
Yes
Yes
(all metals
greater in some
years)
NA
(Gradient in
impairment is
masked by B
and C)
Yes
Yes
Yes
(all metals
greater)
NA
(Gradient in
impairment is
masked by C)
Yes
Yes
Yes
(copper and zinc
increased)
Yes
(Tanytarsini
midges and %
DELTA are
strongly correlated
with copper and
mercury)
Yes
Ammonia (Candidate Cause 4)
Is there exposure at the
same location as the
impairment?
Is exposure increased
over the closest
upstream location?
Is there a gradient of
recovery as exposure
decreases?
Is the exposure pathway
complete?
Yes
No
NA
(Gradient in
impairment is
masked by B
and C)
No
Yes
Yes
NA
(Gradient in
impairment is
masked by C)
Yes
Yes
Yes
NA
(ammonia
increases below
RM 5.8)
Yes
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U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
         Table 7-5 (continued).  Evidence for eliminating candidates causes at Impairments
         A, B, and C.

Impairment A
Impairment B
Impairment C
Low Dissolved Oxygen/High BOD (Candidate Cause 5)
Is there exposure at the
same location as the
impairment?
Is exposure increased
over the closest
upstream location?
Is there a gradient of
recovery as exposure
decreases?
Is the exposure pathway
complete?
Yes
No
(DO is
depressed,
BOD
unchanged)
NA
(Gradient in
impairment is
masked by B
and C)
Yes
Yes
Yes
(BOD is two
times greater in
1992, DO slightly
less)
NA
(Gradient in
impairment is
masked by C)
Yes
Yes
No
(BOD is elevated,
but DO is greater
than either RM 7.9
orRM6.5)
NA
(ammonia
increases below
RM 5.8)
No
Nutrient Enrichment (Candidate Cause 6)
Is there exposure at the
same location as the
impairment?
Is exposure increased
over the closest
upstream location?
Is there a gradient of
recovery as exposure
decreases?
Is the exposure pathway
complete?
Yes
Yes
NA
(Gradient in
impairment is
masked by B
and C)
Yes
Yes
Yes
NA
(Gradient in
impairment is
masked by C)
Yes
Yes
Yes
Yes
(% Tanytarsini and
% DELTA are
strongly correlated
with NOX and Total
P)
Yes
       NA* = not applicable
Chapter 7: Little Scioto River, Ohio
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       7.5.3  Measurements Associated with the Causal Mechanism: Exposure Pathways

       The exposure pathways are shown in Figure 7-4.  Lines of evidence for each exposure
       pathway are discussed below and are summarized in Table 7-11. To refute an
       hypothesis, a step in the pathway must be absent.

       Habitat Alteration (#1) - Channelization results in a constellation of stressors, including
       loss of riffles with increased sediment deposition, and decreased DO. The QHEI metrics
       can yield insights into specific changes: for example, riffle scores are zero throughout
       the channelized portion of the stream (Table 7-15; see Section 7.13), substrate quality
       and embeddedness due to fine sediment drops at RM 7.9, and DO also drops at RM 7.9.
       The co-occurrence of macroinvertebrates with changes in physical structure may be
       somewhat lessened, because Hester-Dendy samplers create an artificial solid substrate
       for colonization. The ICI score does include a qualitative kick net sample that is
       independent of the artificial substrates. The exposure pathway for habitat alteration is
       complete for Impairments A,  B, and C.

       PAHs (#2) - Exposure to PAHs involves two steps:  direct contact with external tissues
       and uptake into the organism. Because the PAH information in this case is from the
       sediments, we  assume that fish and benthic invertebrates between river miles 6.5 and 0.4
       will contact this contamination.  Concentrations of PAH in the sediment were used only
       from samples collected in 1992, as it was the only year in which we were confident that
       the samples were collected from the top six inches.  It is unlikely that fish or
       invertebrates would be exposed to deeper sediments.

       The exposure pathway for PAHs could be interrupted if there was no sign of internal
       exposure. Aquatic contaminants such as PAHs have been monitored by measuring the
       metabolites of xenobiotics in fish bile (Roubal et al. 1977, Gmur and Varanasi 1982,
       Varanasi et al. 1983).  Samples from white suckers  (Catostomus commersoni) taken in
       1992 from the  Little Scioto River were analyzed for concentrations of benzo[a]pyrene
       (BAP) and naphthalene (NAPH)-type metabolites.  Results of the analysis of PAH bile
       metabolites in  white suckers from the Little Scioto River are shown in Figure 7-9.
       Biomarkers of NAPH and BAP are elevated from RM 6.5 to the mouth of the river,
       providing evidence that the exposure pathway is complete at these locations.  Exposure
       criteria, concentrations considered to be above background, were exceeded at RMs 6.5
       through 0.4. PAHs are also known to cause induction of detoxifying enzymes such as
       EROD. EROD activity was elevated at RM 6.5 - 0.4. Based on the absence or presence
       of bile metabolites, the exposure pathway for PAHs is incomplete at Impairment A, and
       complete at Impairments B and C.

       Metals (#3) - Metals must be  taken into organisms to cause adverse effects. Data from
       fish tissue sampled in 1992 confirm uptake of lead and zinc. For common carp
       (Cyprinus carpio) at RM 9.2, zinc concentrations were 79.6 mg/kg, at RM 6.5, zinc
       concentrations were 68.3 mg/kg.  For white suckers at RM 6.5, zinc concentrations were
       17.8 mg/kg,  and lead concentrations were 81.4 mg/kg.  At RM 2.7, fish tissues levels
       were 15.8 mg/kg for zinc and 0.34 mg/kg for lead. For the other metals, we have
       conservatively assumed that external exposure will  represent internal exposure for fish.
       Making this assumption, increased exposure to at least one of the metals  occurs at all
       sampling locations in the reach RM 7.9 to 0.4.  Concentrations of metals in sediment
       were from samples taken in 1992 from the top six inches of sediment.  For 1987 and
       1998 data, the  depth of samples is unknown.
7-24                                                           U. S. Environmental Protection Agency

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                             Stressor Identification Guidance Document
                        7.9
6.5
                   0.5yMg/mg BAP
                   and 80/ig/mg NAPH
5.7      4.4
 River Mile
                          I   I BAP
                          • NAPH
            Figure. 7-9.  Bile metabolites (|jg/mg protein) measured in white suckers
            from the Little Scioto River in 1992.  (Median levels of PAH metabolites
            below RM 7.9 were up as much as 4 times the Exposure Criteria, (dashed
            horizontal line) which are upper limits of background for the state of Ohio.
            The numbers above the bars equal number offish sampled. Vertical lines
            are standard errors.)
       Ammonia (#4) - There are several interweaving pathways by which ammonia can be
       produced in the river and cause effects. We have evidence for two of these steps: total
       ammonia, and nitrate and nitrite concentrations that are converted to ammonia when DO
       is low. Toxic unionized ammonia is formed at high pH. Hard water streams of the
       Eastern Corn Belt Plains typically have pH from 7.5-8; pH may rise even above 9.0 in
       the summer during maximum photosynthesis in nutrient-enriched waters. Data on pH
       are not available in 1992, however, in 1998 grab  samples, pH ranged between 7.4 to 8.0.
       The Little Scioto is highly enriched, and it is highly likely that there are periods when pH
       is greater than indicated by grab samples.  Thus,  we assume that the exposure pathway is
       complete in the Little Scioto when total ammonia is present. This occurs from RM 11.1
       to  0.4. Because ammonia concentrations are measured in the water column, both fish
       and macroinvertebrates are exposed.

       Low Dissolved Oxygen/High Biological Oxygen Demand (#5) - Dissolved oxygen can be
       depleted by high BOD due to the bacterial respiration associated with allochthonous
       organic matter or decaying algal mats. We have  measurements of several relevant
       parameters:  NOX, total P, BOD and DO concentrations. This exposure pathway is
       considered  complete under two scenarios: (1) BOD is elevated and DO is reduced
       compared with the most upstream location, or (2) if BOD data is unavailable, NOX and P
       are elevated and assumed to cause algal growth, and DO is reduced as compared with the
       most upstream location. At RM 7.9, DO is reduced, but BOD is unchanged, so that the
       exposure pathway is considered incomplete. RM 6.5 is more difficult to evaluate
       because data are scanty and are used from different years.  In 1987, DO data were low at
Chapter 7: Little Scioto River, Ohio
                                                          7-25

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                              Stressor Identification Guidance Document
       RM 6.5, and in 1992, the BOD was slightly elevated; thus, the pathway is complete. At
       RM 5.8 to 0.4, because BOD is elevated but DO is similar or greater than at 7.9, the
       exposure pathway is considered incomplete.

       Nutrient Enrichment (#6) -We have evidence for the presence of elevated levels of both
       NOX and total P concentrations. This exposure pathway appears to be complete at RM
       5.8 to 0.4, and at RM 7.9.

       7.5.4   Summary of Analyses for Elimination

       The results of the analysis of spatial associations are summarized in Table 7-5 (pages 7-
       21 to 7-23). The table addresses four questions for each combination of impairment and
       candidate cause. If any of the answers are no, then the candidate cause can be
       eliminated:

           *•   The first question is whether a candidate cause and impairment are spatially co-
               located. Regardless of concentration, the  answer is yes if the stressor is present.
               If the stressor is not present, the answer is no and the impairment could not have
               been caused by exposure to that stressor.

           *•   The second question asks whether the exposure is elevated compared to the
               closest upstream location where the impairment does not occur. The candidate
               cause could have been responsible for the impairment only if exposure increased.
               The candidate cause can be eliminated if the answer to the second question is no.

           *•   The third question asks whether there is a decrease in exposure that corresponds
               with recovery of the impairment. As discussed above, this question is relevant
               only to Impairment C.  If the answer is no with results clearly showing a
               lessening of impairment with consistent exposure, then the candidate cause can
               be eliminated.

           *•   The last question asks if the exposure pathway is  complete. If it is interrupted or
               clearly incomplete so that exposure could not have taken place, then it can be
               eliminated as a potential cause.

       7.6    Characterize Causes:  Eliminate
       Potential causes may be eliminated if the
       evidence indicates that they do not co-occur
       with effects, if effects decrease with increasing
       influence of the cause, or if the exposure
       pathway is incomplete. Each of the three
       Impairments (A, B, and C) are discussed below
       in relation to the elimination of specific causes.
       Conclusions about which candidate causes
       remain for each impairment are also listed.
CHARACTERIZE CAUSES
| Eliminate


| Diagnose
Strength of Ev



Identify Probable Cause

dence

           Impairment A: RM 7.9
           Habitat alteration and metal contamination are the only candidate causes known to
           co-occur at RM 7.9 and to increase compared to upstream locations. All metals were
           slightly greater at RM 7.9 compared to RM 9.2.  PAHs and ammonia were not
           elevated at RM 7.9 relative to the upstream reference, thus candidate causes #2 and
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                              Stressor Identification Guidance Document
           #4 are eliminated. DO concentrations were about 30% lower than upstream, but
           BOD concentrations were not different from the upstream reference location (RM
           9.2), thus candidate cause #5 is eliminated. NOX increased from 1.2 mg/L to 1.4
           mg/L. The shift is small, but precludes elimination of candidate cause #6.

           Conclusion: Habitat Alteration (#1), Metal Contamination (#3), and Nutrient
           Enrichment (#6) remain.
           Impairment B: RM 6.5.
           At this site, only candidate cause #1 can be eliminated because the degree of habitat
           alteration is not elevated compared with those at RM 7.9. The decline in QHEI score
           is associated with the obvious presence of organic chemical contamination rather
           than physical stream characteristics. Organic chemicals, including benzo[a]pyrene
           and naphthalene, were present and were elevated above concentrations at RM 7.9.
           Exposure to these organic chemicals was demonstrated by internal concentrations of
           metabolites.  The metals chromium, copper, lead, and mercury were elevated
           compared to upstream concentrations in all years for which there is data, including
           1988, 1991, 1992 and 1998.  Dissolved oxygen levels were among the lowest in the
           river in 1987, and BOD levels were slightly greater than upstream locations.
           Ammonia concentrations were also slightly greater, and total P concentrations were
           0.02 mg/L greater.

           Conclusion: PAH Contamination (#2)  Metal Contamination (#3), Ammonia
           Toxicity (#4), Low Dissolved Oxygen/High Biological Oxygen Demand (#5), and
           Nutrient Enrichment (#6) remain.

           Impairment C: RM 5.7.
           In this reach of the river, the degree of habitat alteration and PAH  levels were similar
           or lower than at RM 6.5, thus candidates #1 and #2 are eliminated. Candidate cause
           #5, low DO/high BOD, can be eliminated, even though BOD, P and NOX are elevated
           because the subsequent event in the pathway, decreased DO, did not occur. DO is
           unchanged from RM 7.9 in 1992, and RM 6.5 in 1987.  The metals (copper and zinc)
           increased slightly, and the copper gradient was significantly correlated with %
           Tanytarsini midges and % DELTA, thus candidate cause #3 remains.  NOX and P
           were elevated in the reach compared to upstream locations and were significantly
           correlated with % Tanytarsini midges. Candidate cause #6 remains. Candidate
           cause #4 could be eliminated since ammonia was not correlated with the specific
           impairments. However, the increase in ammonia was 10 times greater than
           upstream, and because the data available for correlations were very limited, a
           conservative decision could be made to retain this cause for further evaluation by the
           strength of evidence approach.

           Conclusion: Metal Contamination (#3), Ammonia (#4), and Nutrient
           Enrichment (#6) remain.

       A summary of the candidate causes that remain after the elimination process are listed in
       Table 7-6. Only those causes remaining need to be evaluated by diagnostic or strength of
       evidence analyses.
Chapter 7: Little Scioto River, Ohio                                                              7-27

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                             Stressor Identification Guidance Document
       Table 7-6.  Candidate causes remaining after elimination.

#1 Habitat alteration
#2 PAH Contamination
#3 Metal Contamination
#4 Ammonia
#5 Low DO/BOD
#6 Nutrient Enrichment
Impairment A
X

X


X
Impairment B

X
X
X
X
X
Impairment C


X
X

X
                                                        Stressor Identification
                                                                  LIST CANDIDATE CAUSES
                                                                   ANALYZE EVIDENCE
7.7    Analyze Evidence for Diagnosis

Diagnosis is the identification of causes based on
characteristic signs or symptoms (see 4.2.2).  No
evidence strong enough to support diagnosis was
available for any of the candidate stressors.
However, the pattern of community change is
considered to be suggestive, and is used in the
strength of evidence analysis below.

The deformities, fin erosion, rumors, physical
lesions and anomalies on fish that constitute the
DELTA are pathologies that are also potentially
subject to diagnosis. Some DELTA are strongly
associated with known toxic substances and others
with increased nutrients (Yoder and Rankin 1995b).
However, no pathologist has examined the fish in
question. DELTA cannot be used to distinguish among toxic substances unless specific
anomalies are identified, and even these may be too non-specific to diagnose without
additional information (e.g., histopathology).

7.8    Analyze Evidence to Compare Strength  of Evidence
CHARACTERIZE CAUSES

Eliminate
1

Dagnose




| Strength of Evidence |


| Identify Probable Cause
J

       All of the remaining candidate causes are subjected
       to a strength of evidence analysis to verify the
       elimination step and to identify the most likely
       cause from the multiple hypothesized causes that
       remained after the elimination process. The
       strength of evidence analysis examined case
       specific evidence as well as evidence from other
       situation and biological knowledge.

       Case Specific Evidence

       The evidence presented earlier for the elimination
       step is useful here as well.  In addition, some data
       on loadings are available from the Waste Water
       Treatment Plant (WWTP), which discharges at KM
                                                Stressor Identification
                                                          LIST CANDIDATE CAUSES
                                                            ANALYZE EVIDENCE
                                                          CHARACTERIZE CAUSES
Eliminate

Diagnose

Strength of Evidence
7-28
                                                        U.S. Environmental Protection Agency

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                             Stressor Identification Guidance Document
       6.2 and also has combined sewer overflows that discharge during wet weather periods.
       No clear trends were evident in the loadings of total non-filterable residue or biological
       oxygen demand between 1977 and 1992.  Ammonia values were generally low, with fifty
       percent of loading below 10 kg/day between 1977 and 1991. The highest ammonia
       loading occurred during 1992, with a median of 12.6 kg/day and a maximum of 130
       kg/day (OEPA 1994).

       Evidence from Other Situations or Biological Knowledge

       This section presents evidence that uses information from other studies that are related to
       either exposures or effects found in segments of the Little Scioto River. In particular,
       associations are made between the exposures known at the site and reports of effects
       caused by similar exposures. This section also uses levels of effects seen at the site and
       effects seen at other sites where the same candidate cause occurred.  It also considers
       special experimental evidence; that is, reports about places with similar stressors and
       effects that improved when the stressor was removed, and laboratory studies of candidate
       cause-effect relationships.

       Exposure-response data are available for PAHs and metals, although not for the
       community parameters of greatest interest for this study.  Sediment effect concentrations
       (SECs) developed for Hyalella azteca and Chironomus riparius were considered, but
       only Hyalella azteca was used since Chironomus riparius values were always less
       sensitive.  Sediment effect concentrations for Hyalella azteca are expressed as threshold
       effect level (TEL) and probable effect level (PEL) (Table 7-19; see Section 7.13)
       (USEPA 1996b).

       The TEL and PEL are sediment concentrations associated with toxicity in laboratory
       tests. The interpretation is that toxicity rarely occurs below the TEL and frequently
       occurs above the PEL (USEPA 1996b). Values were derived from a data set consisting
       of many similar studies, and they consider both effect and no-effect data for  field-
       contaminated sediments. The TEL and PEL values used  in this study are listed in Tables
       7-19 and 7-20 (see Section 7.13).  Since many metals and PAHs were present at sites,
       partial toxicity contributed by individual chemicals were  calculated and summed to
       estimate the overall toxicity of metals and PAH at each site.  TELs and PELs are used
       with caution because they are based on sediments with multiple contaminants.

       The TEL and PEL values were compared with the concentrations seen at the locations of
       impairment in Table 7-19. As shown in Table 7-19, the most striking result is that no
       PAH exceeded any criterion level at Impairment A for 1992. For metals only, the TEL
       for arsenic was exceeded at Impairment A in 1992. At Impairment B and C, the Hyalella
       azteca PEL and TEL were exceeded for all PAH that were measured and in every year
       except 1992, when there were  more samples below the detection limit. Hyalella  azteca
       TEL values were exceeded for most metals, but only a few PEL values were exceeded,
       including those for lead, copper, and  chromium.

       For PAHs, the cumulative toxic units were exceeded at Impairments B and C in every
       year (Table 7-7). Exceedances ranged from 339 to 18,820 times the  value that would
       probably kill Hyalella azteca.  For metals, the cumulative toxic units were also exceeded
       at Impairments B and C in every year. However, exceedances were never more than six
       times the cumulative probable effect level.
Chapter 7: Little Scioto River, Ohio                                                              7-29

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                             Stressor Identification Guidance Document
       Table 7-7.  Cumulative toxic units for PAHs and metals based on the PEL values.
       (Values greater than 1.0 exceed PEL*).
Chemical
PAH
Metals
Cumulative Toxic Units
Nearest
Upstream
Location
/0\
(0)
[1.2]*
/0.4\
(0.6)
[0.9]
Impairment A
/0\
(0)
[2.5]*
/0.7\
(1.1)*
[0.9]
Impairment B
/604.5V
(339.4)*
[18819.9]*
/4.3\*
(5.1)*
[1.6]*
Impairment C
79697. 8\*
(821)*
[1633.4]*
/1 .5\*
(2.8)*
[5.8]*
       * Exceeds PEL and TEL./\= 1987-1991, () = 1992, [] =1998.  Zero = below
        detection.
       Criteria are also available for ammonia (USEPA 1998b) (Table 7-8). The toxicity of
       total ammonia (which includes NH3 and NH4+) varies with pH.  Dehydration of
       ammonium ion (NH4+) to un-ionized ammonia is controlled by ambient pH, such that
       excess hydroxide ions (high pH) increase the concentration of the more toxic, un-ionized
       form. Hard water streams of the Eastern Corn Belt Plains (ECBP) typically have pH
       from 7.5-8; in the summer, during maximum photosynthesis in nutrient enriched waters,
       pH may rise above 9.0.  In 1998, pH values ranged between 7.4 and 8.4, and appeared to
       be independent of location. Total ammonia concentrations at RM 5.8 through 2.7 would
       have exceeded the ammonia criterion for water having a pH 8.0 to 8.5 in 1992 (Table 7-
       8). In 1998, the criterion would have been exceeded at pH 8.5.

       Ohio's criteria for dissolved oxygen (causal candidate #5) are 4.0 mg/1 for warm water,
       and 3.0 mg/1 for modified warm water. In 1992, no locations had  dissolved oxygen
       below the modified warm water criterion,  and only RM 2.7 had dissolved oxygen
       concentrations below the warm water criterion, based on a single measurement.
       However, in 1987, continuous data were collected by Datasonde (in-stream Hydrolab)
       and violations were detected at Impairments A and B (Table 7-8).

       Ohio's proposed state-wide criterion for modified warm-water habitat for nitrate and
       nitrite is 1.6 mg/L for wadeable streams in the ECBP having a drainage greater than 20
       mi2 and less than 200 mi2. For total phosphorus, the proposed state-wide criterion for
       modified warm-water habitat is 0.28 mg/L (Rankin et al. 1999). These are exceeded at
       RM 5.8 (Table 7-8).

       A state-wide study by Yoder and Rankin (1995b) indirectly examined the plausibility of
       specific community changes associated with nine types of sources, including waste water
       treatment plants, industrial point sources, conventional municipal sources, combined
       sewer overflows, channelization, and agricultural non-point sources. They found that
       deformities, erosions, lesions, tumors and  anomalies (DELTA) in fish were associated
       with industrial discharges (Yoder and Rankin 1995b) and nutrient enrichment (Rankin et
       al. 1999).  In the Little Scioto, the greatest % DELTA values are associated with the
       greatest nutrient concentrations. Among macroinvertebrates, the loss of Tanytarsini
       midges and the increase ofCricotopus sp.  are both associated with industrial discharges
       (Yoder and Rankin 1995b). In the Little Scioto, the disappearance of Tanytarsini midges
       and an increase in Cricotopus are associated with Impairment C.
7-30
U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
         Table 7-8. Comparison of the reported concentration of water quality parameters
         (mg/L) with exceedances.
Sediment
Parameter
Criteria mg/L
Ammonia3
0.57 mg/L at pH 8.5
1. 27 mg/L at pH 8.0
Dissolved Oxygenb
3.0 mg/L for MWH
Nitrate-nitrite0
1 .6 mg/L
Total phosphorusd
0.28 mg/L
RM7.9
[RM 7.1]
(<0.05)
[0.11,<0.05]
{4.6-2.8}*
(7.9, 5.7)
(1.4)
[0.73, <0.1]
(0.07)
[0.36*, 0.13]
RM6.5
(0.1)
{7.2-1 .9}*
(NA)
(0.8)
(0.09)
RM5.8
[RM 6.2]
(1.2)
[0.35, 0.69]
{8.3, 4.2}
(8.23,4.21)
(8.1)*
[0.33, 2.37]*
{1 .65}*
(2.17)*
[1.9, 1.21]*
         No Entry = No data for that year. {}=1987, ( )=1992, [] =1998.
         a USEPA (1998b) recommended ammonia criterion
         bOEPA (1994) dissolved oxygen criterion
         c Rankin et al. (1999) proposed nitrate-nitrite criterion
         d Rankin et al. (1999) proposed total phosphorus criterion
         * Exceedance of criterion
         Dissolved oxygen values are maximum and minimum.  Ammonia, nitrate-nitrite, total
         phosphorus measured in August and October, 1998.
       7.9     Characterize Causes:  Strength of Evidence
       Strength of evidence analysis uses all of
       the evidence generated in the analysis
       phase to examine the credibility of each
       remaining candidate cause.  The causal
       considerations for the strength of evidence
       analyses used three types of evidence:
       case-specific evidence, evidence from
       other situations or biological knowledge,
       and evidence based on multiple lines of
       evidence (Section 4.3.3). All the evidence
       was evaluated for consistency or
       coherence with the hypothesized causes.
       The results of the strength of evidence analysis are presented in Tables 7-9 to 7-11.
       Following the strength of evidence analysis, the candidate causes are characterized
       (Table 7-12). This involves describing the causal evidence and identifying the probable
       cause.
CHARACTERIZE CAUSES
Eliminat


e Diagnose


| Strength of Evidence |


Identify Probable Cause



Chapter 7: Little Scioto River, Ohio
7-31

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                               Stressor Identification Guidance Document
 Table 7-9. Strength of evidence analysis for the three candidate causes of Impairment A, RM 7.9.
Causal
Considera-
tion
Evidence
Score
Evidence
Score
Evidence
Score
Case-Specific Considerations

Co-
occurrence
Temporality
Consistency
of
Association
Biological
Gradient
Complete
Exposure
Pathway
Experiment
Habitat Alteration
Compatible: At and
below RM 7.9, the
habitat of the Little
Scioto is altered as a
result of channelization.
The degree of habitat
alteration remains about
the same to the mouth
of the river. The
upstream reference is
not channelized and
habitat is good.
No evidence
No evidence
Not applicable: Other
downstream candidate
causes interfere with
this consideration.
Evidence for all steps:
The fish and
invertebrates inhabit the
channelized reach
where the habitat is
altered.
Channel was deepened.
DO was depressed.
Substrate was
embedded.
No evidence.
+
NE
NE
NA
++
NE
Metals Contamination
Compatible: All
sediment metal
concentrations were
slightly higher at RM 7.9
compared to upstream.
No evidence
No evidence
Not applicable: Other
downstream candidate
causes interfere with
this consideration.
Incomplete evidence:
No internal
concentrations of
metals were measured.
Metals were present in
sediment and exposure
could occur from
ingestion or by
respiration of epibenthic
water or sediment
particles or through the
food chain.
No evidence.
+
NE
NE
NA
+
NE
Nutrient Enrichment
Compatible: N was
elevated by 0.2mg/L in
1992 compared to
upstream.
P is the same or
decreases compared to
upstream.
No evidence
No evidence
Not applicable: Other
downstream candidate
causes interfere with
this consideration.
Incomplete evidence:
Fish and invertebrates
inhabit stream where
nutrients are elevated.
Concentrations of algae
or chlorophyll a were not
measured.
No evidence.
+
NE
NE
NA
+
NE
 NE = no evidence; NA = not applicable/not available
7-32
U.S. Environmental Protection Agency

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                               Stressor Identification Guidance Document
 Table 7-9 (continued).  Strength of evidence analysis for the three candidate causes of Impairment
 A, RM7.9.
Causal
Considera-
tion
Evidence
Score
Evidence
Score
Evidence
Score
Considerations Based on Other Situations or Biological Knowledge

Plausibility:
Mechanism
Plausibility:
Stressor-
Response
Habitat Alteration
Increased Relative
Weight: Plausible:
Artificially deepened
channel allows larger
sized fish to survive.
Increased DELTA: Not
known: No obvious
mechanism other than
stress.
Loss of species:
Plausible: Embedded
sediments remove
forage, reproductive,
and cover habitats for
benthic fish including
darters and benthic
invertebrates including
mayflies. Low DO is not
tolerated by many
species (Karr and
Schlosser 1977, Yount
and Niemi 1990, Rankin
1995).
Increased Relative
Weight: No evidence.
Increased DELTA: No
evidence.
Loss of species: No
evidence.
No quantitative
evidence.
Habitat alteration
associated with
channelization is
generally believed to be
an all or none situation
affected by it's spatial
extent and severity.
+
0
+
NE
NE
NE
Metals Contamination
Increased Relative
Weight: Implausible: No
known mechanism for
metals. Metals usually
cause a decrease in the
relative weight offish
(Eisler 2000b).
Increased DELTA:
Implausible: Metals do
not cause fin erosion
and lesions (Eisler
2000b).
Loss of species:
Plausible: Metals are
known to cause lethal
and sub-lethal effects to
invertebrates and fish
that can extirpate
species from a site
(Eisler 2000b).
Metals usually cause a
decrease in the relative
weight offish (Eisler
2000b).
Increased Relative
Weight: Not applicable:
Implausible mechanism.
Increased DELTA: Not
applicable: implausible
mechanism.
Loss of species:
Inconcordant.
No metals exceeded
Hyalella azteca PEL
values in 1 987, 1 992 or
1998. The TEL value
for arsenic was
exceeded only in 1 992.
Metals cumulative toxic
units exceeded PEL in
1992, but only by 0.1
units (USEPA1996b).


+
NA
NA

Nutrient Enrichment
Increased Relative
Weight: Implausible: N
is a nutrient for algal
growth. Greater
production of algae
could provide additional
food, increasing fish
growth. However, the
mechanism is
implausible because N
is generally not limiting
(Allan 1995).
Increased DELTA:
Plausible: Nutrients are
believed to create
conditions that favor
opportunistic pathogens
and fungi that cause
lesions, fin erosion and
interfere with wound
healing.
Loss of species:
Plausible: Switching to
an autochthonous
energy source could
alter species survival
and community
composition offish and
invertebrates.
Increased Relative
Weight: Not applicable:
Implausible mechanism.
Increased DELTA:
Inconcordant:
magnitude of nutrient
change too small to
cause effect.
Loss of species:
Inconcordant.
The magnitude of
nutrient change was too
small to account for the
dramatic shifts in
invertebrate and fish
metrics. Proposed
nitrogen criterion for
Ohio was not exceeded
(Rankin et al. 1999).

+
+
NA


 NE = no evidence; NA = not applicable/not available
Chapter 7: Little Scioto River, Ohio
7-33

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                               Stressor Identification Guidance Document
 Table 7-9 (continued).  Strength of evidence analysis for the three candidate causes of Impairment
 A, RM7.9.
Causal
Considera-
tion


Evidence


Score


Evidence


Score


Evidence


Score
Considerations Based on Other Situations or Biological Knowledge (cont'd)

Consistency
of
Association






























Habitat Alteration
Increased Relative
Weight: In most places.

Increased DELTA: In
most places.





Loss of species: In most
places.

Moderate increase in
DELTA and loss of
species are commonly
associated with habitat
alteration associated
with channelization
(Yoder and Rankin
1995b). Increased
Relative Weight is also
commonly increased
with deepened channels
(Personal Observation).
Agricultural areas with
channelization having
similar stressors
showed decreases in
IBI and ICI component
metrics (Edwards et al.
1984, Sheildsetal.
1998).
++


++






++






















Metals Contamination
Increased Relative
Weight: Many
exceptions.
Increased DELTA:
Many exceptions.





Loss of species: Many
exceptions.

At other sites in Ohio
with similar metals
concentrations, Relative
Weight and DELTA
were not increased and
species were abundant.
Personal observation of
Ohio database.












-


.






-






















Nutrient Enrichment
Increased Relative
Weight: No evidence.

Increased DELTA:
Many exceptions. At
many sites in Ohio,
DELTA was not
increased by these
levels of N (Rankin et al.
1999).
Loss of species: Many
exceptions. At many
sites in Ohio, IBI and ICI
scores were high at
these levels of N
(Rankin et al. 1999).

High IBI and ICI cannot
be achieved when many
species are lost.













NE


-






-






















 NE = no evidence; NA = not applicable/not available
7-34
U.S. Environmental Protection Agency

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                               Stressor Identification Guidance Document
 Table 7-9 (continued).  Strength of evidence analysis for the three candidate causes of Impairment
 A, RM7.9.
Causal
Considera-
tion
Evidence
Score
Evidence
Score
Evidence
Score
Considerations Based on Other Situations or Biological Knowledge (cont'd)

Specificity of
Cause
Analogy
Experiment
Predictive
Performance
Habitat Alteration
Increased Relative
Weight: One of a few:
Deep channels or pools
required for larger fish.
Relative weight offish is
significantly correlated
with drainage area, a
surrogate for channel
depth (Norton 1999).
Increased DELTA: One
of many.
Loss of species: One of
many.
Not applicable
Increased Relative
Weight: No evidence
Increased DELTA: No
evidence
Loss of species:
Concordant: Artificial
riffle and pools
improved invertebrate
assemblage in the
channelized Olentangy
River (Edwards et al.
1984), and fish in
Mississippi River
(Sheildsetal. 1998).
No evidence
++
0
0
NA
NE
NE
+++
NE
Metals Contamination
Increased Relative
Weight: Not applicable:
Implausible mechanism.
Increased DELTA: Not
applicable: Implausible
mechanism.
Loss of species: One of
many.
Not applicable
Increased Relative
Weight: No evidence
Increased DELTA: No
evidence

No evidence
NA
NA
0
NA
NE
NE

NE
Nutrient Enrichment
Increased Relative
Weight: Not applicable:
Implausible mechanism.
Increased DELTA: One
of many.
Loss of species: One of
many.
Not applicable
Increased Relative
Weight: No evidence
Increased DELTA: No
evidence

No evidence
NA
0
0
NA
NE
NE

NE
Considerations from Multiple Lines of Evidence

Consistency
of Evidence
Coherence
of Evidence
Habitat Alteration
Increased Relative
Weight: All consistent.
Increased DELTA: All
consistent.
Loss of species: All
consistent.
Increased Relative
Weight, Increased
DELTA, Loss of
species: None.
+++
+++
+++
0
Metals Contamination
Increased Relative
Weight: Inconsistent:
Implausible mechanism.
Increased DELTA:
Inconsistent:
Implausible mechanism.
Loss of species:
Inconsistent - Although
metals are present, the
concentrations are
unlikely to cause
species extirpation.
Increased Relative
Weight, Increased
DELTA, Loss of
species: None.



0
Nutrient Enrichment
Increased Relative
Weight: Inconsistent:
Magnitude of change
inconsistent with
magnitude of effect.
Increased DELTA:
Inconsistent: Magnitude
of change inconsistent
with magnitude of effect.
Loss of species:
Inconsistent: Magnitude
of change inconsistent
with magnitude of effect.
Increased Relative
Weight, Increased
DELTA, Loss of
species: None.


—
0
 NE = no evidence; NA = not applicable/not available
Chapter 7: Little Scioto River, Ohio
7-35

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                               Stressor Identification Guidance Document
 Table 7-10.  Strength of evidence analysis for the five candidate causes of Impairment B, RM 6.5.
Causal
Consideration
Evidence
Score
Evidence
Score
Case-Specific Considerations

Co-occurrence
Temporality
Consistency of
Association
Biological Gradient
Complete Exposure
Pathway
Experiment
PAH contamination
Compatible: Sediment PAH
concentrations were several orders
of magnitude greater at RM 6.5 than
upstream (Table 13).
No evidence
No evidence: only one location.
Not Applicable: Other candidate
causes downstream interfere with
this consideration.
Actual evidence for all steps: PAHs
were present in the sediment, and
bottom-feeding fish and benthic
invertebrates are typically exposed
to sediment contaminants. Both BAP
and NAPH metabolites were found in
fish. EROD, a detoxifying enzyme
known to be induced by PAH, was
elevated.
No evidence
+
NE
NE
NA
+ +
NE
Metals Contamination
Compatible: Lead, chromium, copper
and mercury concentrations in
sediment were two to ten times
greater at RM 6.5 than upstream.
Cadmium and zinc were also greater,
but to a lesser degree.
No evidence
No evidence: only one location.
Not Applicable: Other candidate
causes downstream interfere with this
consideration.
Actual evidence for all steps: Metals
were present in sediment and
exposure could occur from ingestion
or by respiration of epibenthic water of
sediment particles or through the food
chain. Zinc and lead were detected
in fish tissues.
No evidence
+
NE
NE
NA
+ +
NE
 NE = no evidence; NA = not applicable/not available
7-36
U.S. Environmental Protection Agency

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                               Stressor Identification Guidance Document
 Table 7-10 (continued). Strength of evidence analysis for the five candidate causes of
 Impairment B, RM 6.5.
Causal
Consideration
Evidence
Score
Evidence
Score
Considerations Based on Other Situations or Biological Knowledge

Plausibility:
Mechanism
Plausibility:
Stressor-Response
Consistency of
Association
Specificity of Cause
PAH contamination
Decreased relative weight:
Plausible: PAHs are known to
reduce growth. Toxic compounds
can shorten life span resulting in
smaller fish (Eisler 2000a).
Increased DELTA: Plausible: PAHs
are known to cause eroded barbels,
fin erosion, lesions and internal and
external tumors (Eisler 2000a).
Decreased species: Plausible: PAHs
are known to be toxic and cause
reproductive impairments which
could extirpate species (Eisler
2000a).
Decreased relative weight:
Concordant: Toxic levels are
consistent with decreased fish
growth.
Increased DELTA: Quantitatively
consistent: PAHs are at levels that
cause tumors and other DELTA.
Decreased species: Quantitatively
consistent: The Hyalella azteca
PEL's were exceeded for all PAHs.
The cumulative PAH toxic units
ranged between 339 to 18,820 times
the PEL value (USEPA 1996b).
Decreased relative weight: In most
places: Decreased relative weight is
associated with complex toxic
exposures (Yoder and Rankin
1995b).
Increased DELTA: Invariant: Tumors
and other DELTA are associated
with fish exposed to high
concentrations of PAH in fresh and
marine waters (Albers 1995).
Decreased species: Invariant: At
more than 25 locations associated
with PAH contamination that
exceeded exposure criteria in Ohio,
IBI and ICI scores were below 30
(Cormier et al. 2000a). IBI and ICI
are known to be depressed even
when habitat quality is high (Cormier
et al. 2000b, OEPA 1992a). IBI and
ICI scores of less than 30 only occur
when some species are extirpated.
Decreased relative weight: One of
many.
Increased DELTA: One of many.
PAHs are known to cause external
lesions seen at Impairment B.
Decreased species: One of many.
+
+
+
+
+++
+++
++
+++
+++
0
0
0
Metals Contamination
Decreased relative weight: Plausible:
Metals are known to reduce growth.
Toxic compounds can shorten life
span resulting in smaller fish (Eisler
2000b).
Increased DELTA: Implausible:
Metals do not cause fin erosion and
lesions
Decreased species: Plausible: Metals
are known to cause lethal and sub-
lethal effects to invertebrates and fish
that can extirpate species from a site
(Eisler 2000b).
Decreased relative weight:
Ambiguous. Toxic levels are
consistent with decreased fish growth
(Eisler 2000b).
Increased DELTA: Not applicable:
mechanism is implausible.
Decreased species: Quantitatively
consistent. Lead exceeded Hyalella
azteca PEL values in 1 988-1 991 and
1992 and chromium in 1992. The
cumulative toxic units values for all
metals range from 1.6 to 5.1 (USEPA
1996b).
Decreased relative weight: In most
places: Decreased relative weight is
associated with complex toxic
exposures (Yoder and Rankin 1995).
Increased DELTA: Not applicable.
Decreased species: In most places:
Hickey and Clements (1998) reviewed
changes in invertebrate community
associated with metals in water
column.
Decreased relative weight: One of
many.
Increased DELTA: Not applicable.
Decreased species: One of many.
+

+
0
NA
+++
++
NA
++
0
NA
0
 NE = no evidence; NA = not applicable/not available
Chapter 7: Little Scioto River, Ohio
7-37

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                               Stressor Identification Guidance Document
 Table 7-10 (continued).  Strength of evidence analysis for the five candidate causes of
 Impairment B, RM 6.5.
Causal
Consideration
Evidence
Score
Evidence
Score
Considerations Based on Other Situations or Biological Knowledge (cont'd)

Analogy
Experiment
Predictive
Performance
PAH contamination
Not applicable
Decreased relative weight:
Concordant: Following dredging in
the Black River, Ohio, the age
structure of the brown bullheads
increased (Baumann and
Harshbarger 1995).
Increased DELTA: Concordant: In
the Black River Ohio, removal of
PAHs by dredging resulted in lower
levels of DELTA (Baumann and
Harshbarger 1995) and PAH bile
metabolites (Lin et al. submitted).
Decreased species: Concordant:
Following dredging the composition
of species at this site also changed
(Baumann, pers. comm.).
No evidence
NA
+++
+++
+++
NE
Metals Contamination
Not applicable
No evidence: No references sought.
No evidence: No references sought.
No evidence: No references sought.
No evidence
NA
NE
NE
Considerations from Multiple Lines of Evidence

Consistency of
Evidence
Coherence of
Evidence
PAH contamination
Decreased relative weight: All
consistent.
Increased DELTA: All consistent.
Decreased species: All consistent.

+++
+++
+++

Metals Contamination
Decreased relative weight: All
consistent.
Increased DELTA: Multiple
inconsistencies.
Decreased species: All consistent.
Increased DELTA: No known
explanation.
+++
—
+++
0
 NE = no evidence; NA = not applicable/not available
7-38
U.S. Environmental Protection Agency

-------
                               Stressor Identification Guidance Document
 Table 7-10 (continued).  Strength of evidence analysis for the five candidate causes of
 Impairment B, RM 6.5.
Causal
Consideration
Evidence
Score
Evidence
Score
Evidence
Score
Case-Specific Considerations

Co-occurrence
Temporality
Consistency of
Association
Biological
Gradient
Complete
Exposure
Pathway
Experiment
Ammonia Toxicity
Compatible:
Ammonia
concentration was
doubled relative to
Impairment A.
No evidence
No evidence: Only
one location.
Not applicable:
Other downstream
candidate causes
interfere with this
consideration.
Evidence for all
steps: Fish and
invertebrates
inhabited stream
where ammonia
was present.
No evidence
+
NE
NE
NA
+ +
NE
Low Dissolved oxygen/High
BOD
Compatible: In
1992, BOD was
double the
upstream value
and the lowest DO
levels measured
were 0.9 mg/L less
than upstream.
No evidence
No evidence: Only
one location.
Not applicable:
Other downstream
candidate causes
interfere with this
consideration.
Evidence for all
steps: Fish and
invertebrates
inhabited stream
where conditions
of low DO and high
BOD occurred.
No evidence
+
NE
NE
NA
+ +
NE
Nutrient Enrichment
Compatible:
Compared to RM
7.9, P was
elevated by 0.02
mg/L. N was less.
No evidence
No evidence: Only
one location.
Not applicable:
Other downstream
candidate causes
interfere with this
consideration.
Evidence for all
steps: Fish and
invertebrates
inhabit stream
where P was
elevated.
No evidence
+
NE
NE
NA
+ +
NE
 NE = no evidence; NA = not applicable/not available
Chapter 7: Little Scioto River, Ohio
7-39

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                               Stressor Identification Guidance Document
 Table 7-10 (continued).  Strength of evidence analysis for the five candidate causes of
 Impairment B, RM 6.5.
Causal
Consideration
Evidence

Score

Evidence

Score

Evidence

Score

Considerations Based on Other Situations or Biological Knowledge

Plausibility:
Mechanism











Plausibility:
Stressor-
Response



Ammonia Toxicity
Decreased relative
weight: Plausible:
Ammonia toxicity
could reduce
growth and
survival. Low
survival could alter
the age structure
resulting in
smaller, younger
fish.
Increased DELTA:
Plausible:
Ammonia has
been associated
with anomalies
(Dyer, pers.
comm.).


Decreased
species: Plausible:
Ammonia is known
to be toxic to fish
and invertebrates
(USEPA1998b).


Decreased relative
weight: No
evidence.
Increased DELTA:
No evidence.
Decreased
species:
Inconcordant: The
ammonia
concentrations
were not great
enough to cause
the dramatic
effects seen at
Impairment B.
Ammonia criteria
were not
exceeded.
(USEPA1998b).
+

+







+



NE
NE




Low Dissolved oxygen/High
BOD
Decreased relative
weight: Plausible:
Stress could
reduce growth and
survival. Low
survival could alter
the age structure
resulting in more
smaller, younger
fish.
Increased DELTA:
Not known: No
known mechanism.





Decreased
species: Plausible:
Low DO can kill
fish and
invertebrates
(Allan 1995).


Decreased relative
weight: No
evidence.
Increased DELTA:
Not applicable.
Decreased
species: DO levels
are below Ohio
criteria for MWH
(OEPA1992b).


+

0







+



NE
NA
+



Nutrient Enrichment
Decreased relative
weight:
Implausible:
Increased nutrients
are usually
associated with
increased algal
growth that
augment the
energy available
for growth.
Increased DELTA:
Plausible: Nutrients
are believed to
create conditions
that favor
opportunistic
pathogens and
fungi that cause
lesions, fin erosion,
and interfere with
wound healing
(Rankin et al.
1999).
Loss of species:
Plausible:
Switching to an
autochthonous
energy source
could alter species
survival and
community
com position for
fish and
invertebrates (Allan
1995).
Decreased relative
weight:
Inconcordant.
Increased DELTA:
Inconcordant.
Decreased
species:
Inconcordant: The
magnitude of P
change was not
great enough to
cause dramatic
effects seen at
Impairment B.
Proposed P
criterion was not
exceeded (Rankin
etal. 1999).


+







+




-




 NE = no evidence; NA = not applicable/not available
7-40
U.S. Environmental Protection Agency

-------
                               Stressor Identification Guidance Document
 Table 7-10 (continued). Strength of evidence analysis for the five candidate causes of
 Impairment B, RM 6.5.
Causal
Consideration
Evidence

Score

Evidence

Score

Evidence

Score

Considerations Based on Other Situations or Biological Knowledge (cont'd)

Consistency of
Association











Specificity of
Cause


Analogy
Experiment
Predictive
Performance
Ammonia Toxicity
No evidence











Decreased relative
weight: One of
many.
Increased DELTA:
One of many.
Decreased
species: One of
many.
Not applicable
No evidence: No
reference sought.
No evidence

NE











0
0

0

NA
NE
NE

Low Dissolved oxygen/High
BOD
No evidence.











Decreased relative
weight: One of
many
Increased DELTA:
Not applicable.
Decreased
species: One of
many.
Not applicable
No evidence: No
reference sought.
No evidence

NE











0
NA

0

NA
NE
NE

Nutrient Enrichment
Decreased relative
weight: Many
exceptions.
Increased DELTA:
Many exceptions:
DELTA are
associated with
increased P at
many sites in Ohio,
but at a higher
concentration of P
(Rankin et al.
1999).
Decreased
species: Many
exceptions:
Reduced species
are associated with
many sites in Ohio
increased P, but at
a higher
concentration
(Rankin et al.
1999).
Decreased relative
weight: Not
applicable
Increased DELTA:
One of many.
Decreased
species: One of
many.
Not applicable
No evidence: No
references sought.
No evidence


-





-




NA
0

0

NA
NE
NE

 NE = no evidence; NA = not applicable/not available
Chapter 7: Little Scioto River, Ohio
7-41

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                               Stressor Identification Guidance Document
 Table 7-10 (continued).  Strength of evidence analysis for the five candidate causes of
 Impairment B, RM 6.5.
Causal
Consideration
Evidence
Score
Evidence
Score
Evidence
Score
Considerations from Multiple Lines of Evidence

Consistency of
Evidence
Coherence of
Evidence
Ammonia Toxicity
Decreased relative
weight: All
consistent.
Increased DELTA:
All consistent.
Decreased
species:
Inconsistent:
Magnitude of
change
inconsistent with
magnitude of
effect.
Decreased
species: No
known explanation.
+++
+++

0
Low Dissolved oxygen/High
BOD
Decreased relative
weight: Most
consistent.
Increased DELTA:
Many
inconsistencies:
No known
mechanism.
Decreased
species: Most
consistent.
Increased DELTA:
No known
explanation.
+

+
0
Nutrient Enrichment
Decreased relative
weight: Many
inconsistencies.
Increased DELTA:
Many
inconsistencies:
Magnitude of
change
inconsistent with
magnitude of
effect.
Decreased
species: Many
inconsistencies:
Magnitude of
change
inconsistent with
magnitude of
effect.
Decreased relative
weight, Increased
DELTA, Decreased
species: No
known explanation.
	


0
 NE = no evidence; NA = not applicable/not available
7-42
U.S. Environmental Protection Agency

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                               Stressor Identification Guidance Document
 Table 7-11.  Strength of evidence analysis for the three candidate causes of Impairment C,
 RM5.7.
Causal
Consideration
Evidence

Score

Evidence

Score

Evidence

Score

Case-Specific Considerations

Co-occurrence

Temporality
Consistency of
Association




Biological
Gradient






Metals Contamination
Uncertain: There
were only slight
changes in metal
concentrations in
sediment at RM
5.7 compared to
RM6.5. Only
copper and zinc
increased slightly
and possibly
cadmium. All
others declined.
No evidence
Similar patterns of
fish and
invertebrate
communities are
seen at RM 5.7,
4.4 and 2.7
Increased DELTA:
Strong and
monotonic: From
RM5.7toRM0.4,
copper and
mercury are
strongly correlated
with % DELTA.
Decreased
Tanytarsini: Strong
and monotonic:
The decline in %
tanytarsini was
also strongly
correlated with
copper and
mercury.
0

NE
+




++


++




Ammonia Toxicity
Compatible:
Ammonia
concentrations
were 1 0X or
greater than at RM
6.5. from RM 5.7 to
RM2.7
No evidence
Similar patterns of
fish and
invertebrate
communities are
seen at RM 5.7,
4.4 and 2.7.
Increased DELTA:
None: No
correlation of
ammonia with %
DELTA.
Decreased
Tanytarsini: None:
No correlation of
ammoniawith the
decline in %
Tanytarsini.

+

NE
+







-




Nutrient Enrichment
Compatible: Total
phosphorus and
nitrogen
concentrations are
elevated at RM 5.7
through 2.7. P
values are more
than 24X greater
than at RM 6.5 and
more than 1 0X
greater for nitrogen
than upstream.
No evidence
Similar patterns of
fish communities
are seen at RM 5.7,
4.4 and 2.7.


Increased DELTA:
Strong and
monotonic: %
DELTA was
moderately
correlated with
BOD, N and P.
Decreased
Tanytarsini: Strong
and monotonic:
BOD, nitrate-nitrite
and phosphorus
were all strongly
correlated with
decline in %
Tanytarsini midges
and the ICI.
+

NE
+




++


++




 NE = no evidence; NA = not applicable/not available
Chapter 7: Little Scioto River, Ohio
7-43

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                               Stressor Identification Guidance Document
 Table 7-11 (continued).  Strength of evidence analysis for the three candidate causes of
 Impairment C, RM 5.8
Causal
Consideration
Evidence

Score

Evidence

Score

Evidence

Score

Case-Specific Considerations (cont'd)

Complete
Exposure
Pathway



















Experiment
Metals Contamination
Incomplete
evidence: Lead
and zinc were
detected in water
samples (OEPA
1992a). In
sediment, many
metals were
detected. No
internal
concentrations of
metals were
measured. Water
hardness may
have reduced
metal availability.






No evidence.
+





















NE
Ammonia Toxicity
Evidence for all
steps: Ammonia
levels measured in
water column, so
exposure possible
for fish and
invertebrates.
Ammonia is
directly discharged
into streams by
point sources.
Temperature and
pH conditions are
favorable for
forming unionized
ammonia, the toxic
form of ammonia.
Conditions are
favorable for
conversion of
nitrites to ammonia
(low DO).
No evidence.
+ +





















NE
Nutrient Enrichment
Incomplete
evidence: Nutrient
and phosphorus
concentrations were
measured in water
column, and would
be available for
algal, fungal and
bacterial growth.

Neither algal nor
chlorophyll a
concentrations, the
direct effect of
nutrient enrichment,
nor bacterial
concentrations were
not measured.




No evidence.
+





















NE
Considerations Based on Other Situations or Biological Knowledge
Plausibility:
Mechanism






























Increased DELTA:
Implausible: Metals
do not cause fin
erosion and
lesions (Eisler
2000b).






Decreased
Tanytarsini:
Plausible: Metals
are known to
cause lethal and
sub-lethal effects
to invertebrates
that can extirpate
species from a
site. In a literature
review, lead and
copper were
associated with
mortality and other
metals with
mortality,
reproduction,
growth and
behavior changes
(Eisler 2000b).
-











+



















Increased DELTA:
Plausible:
Ammonia has
been associated
with DELTA (Dyer,
pers. comm.).






Decreased
Tanytarsini:
Plausible:
Ammonia is toxic
to benthic
macroinvertebrates
(USEPA1998b).













+











+



















Increased DELTA:
Plausible: Nutrients
are believed to
create conditions
that favor
opportunistic
pathogens and fungi
that cause lesions,
fin erosion and
interfere with wound
healing (Rankin et
al. 1999).
Decreased
Tanytarsini:
Increased nutrients
are known to
change community
structure primarily
by changing the
food source (Allan
1995).











+











+



















 NE = no evidence; NA = not applicable/not available
7-44
U.S. Environmental Protection Agency

-------
                               Stressor Identification Guidance Document
 Table 7-11 (continued).  Strength of evidence analysis for the three candidate causes of
 Impairment C, RM 5.8.
Causal
Consideration
Evidence

Score

Evidence

Score

Evidence

Score

Considerations Based on Other Situations or Biological Knowledge (cont'd)

Plausibility:
Stressor-
Response







Consistency of
Association

Specificity of
Cause and Effect

Analogy
Experiment
Predictive
Performance
Metals Contamination
Increased DELTA:
Not applicable.
Mechanism not
plausible.



Decreased
Tanytarsini:
Ambiguous: The
cumulative toxic
units exceed PEL
by 1.5 to 2.8 times
in 1988/91 and
1992, respectively.
The cumulative
toxic units for PEL
decreased
compared to
upstream in
1988/91 and 1992.
In 1998,
cumulative PEL
was 3.5 times
greater than at
Impairment B, but
this occurred after
the impairment had
already occurred
(USEPA1996b).
Increased DELTA:
Many exceptions.
Ohio EPA
database.
Decreased
Tanytarsini: No
evidence.
Increased DELTA:
Not applicable.
Decreased
Tanytarsini: One of
many.
Not applicable
No evidence
No evidence
NA



0





NE

NA
0

NA
NE
NE
Ammonia Toxicity
Increased DELTA:
Concordant



Decreased
Tanytarsini:
Quantitatively
consistent:
Ammonia
concentrations are
in a plausible
range to cause
toxic effects
especially on
warm, sunny days.
Conservatively,
ammonia was two
times the USEPA
chronic criteria
(USEPA 1996b).

Increased DELTA:
In most places
(Rankin et al.
1999).
Decreased
Tanytarsini: No
evidence.
Increased DELTA:
One of a few.
Decreased
Tanytarsini: One of
many.
Not applicable
No evidence
No evidence
+



+++




++
NE

++
++

NA
NE
NE
Nutrient Enrichment
Increased DELTA:
Quantitatively
consistent:
%DELTA consistent
with associations of
P concentrations
found in streams
throughout Ohio
(Rankin et al, 1999)
Decreased
Tanytarsini:
Concordant.
Nutrient criteria are
proposed for Ohio
and were exceeded
at RM 5.7 through
RM 0.4 for both
nitrate-nitrite and
phosphorus. At RM
5.7, nitrogen
concentration was
five times the
proposed criterion
value. P
concentration was
more than seven
times the proposed
phosphorus criterion
(Rankin et al. 1999).
Increased DELTA:
In most places
(Rankin et al. 1999).
Decreased
Tanytarsini: No
evidence.
Increased DELTA:
One of a few.
Decreased
Tanytarsini: One of
many.
Not applicable
No evidence
No evidence
+++



+




+ +
NE

++
++

NA
NE
NE
 NE = no evidence; NA = not applicable/not available
Chapter 7: Little Scioto River, Ohio
7-45

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                               Stressor Identification Guidance Document
 Table 7-11 (continued).  Strength of evidence analysis for the three candidate causes of
 Impairment C, RM 5.8.
Causal
Consideration
Evidence

Score

Evidence

Score

Evidence

Score

Considerations from Multiple Lines of Evidence

Consistency of
Evidence





Coherence of
Evidence






Metals Contamination
Increased DELTA:
Multiple
inconsistencies.
Decreased
Tanytarsini: Most
consistent.
Although metals
are toxic the
magnitude and
type of effect do
not seem to
indicate that
metals caused
either the increase
% DELTA or shifts
in invertebrate
metrics. However,
mercury and
copper are both
significantly
correlated with %
DELTA and %
tanytarsini.
Increased DELTA:
No known
explanation.








0





0



0




Ammonia Toxicity
Increased DELTA:
Most consistent.
Decreased
Tanytarsini: Most
consistent.
Ammonia may
have toxic effects,
but % DELTA not
likely to be caused
by ammonia. No
biological
correlation.



Increased DELTA:
Biological gradient
based on few
observations and
may be
confounded by
other stressors
downstream.
Decreased
Tanytarsini:
Biological gradient
based on few
observations and
may be
confounded by
other stressors
downstream.
+
+





0



0




Nutrient Enrichment
Increased DELTA:
All consistent.
Decreased
Tanytarsini: All
consistent.
Reasonable
evidence to suspect
that nitrogen and
phosphorus are
creating conditions
that favor
opportunistic
pathogens.
Proposed criteria
values are
exceeded and high
% DELTA
consistent with
effects seen even in
the absence of
toxics. Shifts in
invertebrate metrics
more uncertain.









+++
++














 NE = no evidence; NA = not applicable/not available
7-46
U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       7.10   Characterize Causes: Identify Probable Causes
CHARACTERIZE CAUSES
Eliminate
Diagnose



Strength of Evi


Identify Probable Cause

dence

           Impairment A (RM 7.9).  At RM 7.9,
           there is a decline in IBI and ICI that is
           characterized by an increase in the
           relative weight offish and percent
           DELTA, a decreased number offish
           and species offish, and a decreased
           percentage of mayflies. Candidate
           Causes #2, PAH, #4, ammonia, and #5,
           low DO/BOD were eliminated (Tables
           7-5 and 7-6).  Candidate causes #1,
           habitat alteration, #3, metal
           contamination, and #6, nutrient enrichment, were evaluated in a strength of evidence
           analysis (Tables 7-9, 7-10 and 7-11). An artificially deepened channel was identified
           as the probable cause for an increase in the relative weight offish.  An embedded
           stream bed was identified as the probable cause for decreased numbers and species
           offish and decreased percentage of mayflies.  The stream bed may have been
           susceptible to becoming embedded due to a lower gradient than upstream.  The
           probable cause for the low but measurable increase in percent DELTA remained
           uncertain. The strength of evidence analysis strongly supports this causal
           relationship.  The quality of the data is high, and the consistency of the evidence is
           good.

           Impairment B (RM 6.5).  At RM 6.5, there is a further decline in the IBI and ICI.
           Specific impairments include an increase in % DELTA, a decrease in the relative
           weight and numbers of species offish, and an additional decrease in percent
           mayflies. Habitat alteration was eliminated as a candidate cause (Tables 7-5  and 7-
           6). In the strength of evidence analysis a single probable cause, PAHs, was found to
           be sufficient to cause all of the specific impairments (Tables 7-10 and 7-12).  Habitat
           alteration continued to impair the site but was not the cause of the increased DELTA,
           decreased relative weight, or  the additional decline in the number of species.  The
           strength of evidence analysis  strongly supports this causal relationship.  The  quality
           of the data is high, and the consistency of the evidence is very good.

           Impairment C (RM 5.7).  At RM 5.7, there is a notable further increase in %
           DELTA and a decrease in %  Tanytarsini. Altered habitat and PAH still cause
           impairments,  but since the level of alteration remains about the same or decreases,
           these candidate causes were eliminated (Tables 7-5 and 7-6).  In the strength  of
           evidence analysis, nutrient enrichment, candidate cause #6, was identified as the
           probable cause for both impairments.  Nevertheless, ammonia toxicity may still be
           important. We have moderate confidence in this characterization.

       The causal characterization of the Little Scioto River could be strengthened by evidence
       from published literature that reports associations applying to  plausible mechanism and
       stressor-response, consistency of association, specificity, and others. It was not the
       intent of this document to prepare an exhaustive list of appropriate evidence, but  such a
       resource is certainly needed to make these types of evidence accessible for future
       characterizations. This case study does demonstrate the stressor identification process
       and the importance of clearly presenting the reasoning and evidence.
Chapter 7: Little Scioto River, Ohio
7-47

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                                Stressor Identification Guidance Document
 Table 7-12. Causal characterization.
        Impairment A - RM 7.9
   Impairment B - RM 6.5
       Impairment C - RM 5.7
   Probable Cause: Habitat Alteration
    Probable Cause: PAH
       Contamination
 Probable Cause: Nutrient Enrichment
 Increased Relative Weight:  Is
 probably caused by the artificial
 deepening of the channel that allows
 larger fish to live there.

 Increased DELTA: The percentage of
 DELTA is commonly associated with
 channelized streams, but the specific
 aspect of the channelization that
 increased DELTA is  unknown.

 Loss of species: Many factors could
 contribute to the loss offish and
 benthic invertebrate  species; however,
 embedded substrates seem to be the
 most likely stressor since upstream
 locations had even lower DO levels
 and yet had a greater variety offish
 and invertebrate species.

 Although metals are present, the
 likelihood of response at the these
 concentrations are low. Furthermore,
 the types of changes in the
 community, especially an increase in
 the relative weight offish, is very
 unlikely with the candidate cause of
 metals.

 Although P levels are slightly higher,
 effects are not associated with these
 phosphorous concentration elsewhere
 and they do not exceed Ohio's
 proposed criteria values for effects.

 Candidate Causes #2, PAH, and #4,
 Ammonia, were eliminated  because
 levels were the same or lower than
 upstream. Candidate Cause #5, Low
 DO /BOD , was also eliminated as an
 overall pathway; however, low DO
 associated with channelization may
 still play a roll especially in  DELTA.

 Siltation and deepened channel are
 consistent with  Impairment A.  The
 magnitude of the alteration and clear
 difference from upstream location
 strongly support this cause.
A single cause is likely for the
three manifestations of
Impairment B:  decreased
relative weight, increased
DELTA, and decreased
species:

The probable cause of
Impairment B is toxic levels
of PAH-contaminated
sediments.  All of the
evidence support PAH
contamination as the cause.
There is a complete exposure
pathway at the location and
clear mechanism of action for
each of the effects. The
single most convincing piece
of evidence is that the
cumulative toxic units of PAH
were more than 300 times
the probable effects level.

Metals are at sufficient
concentrations to cause
effects; however, they were
sometimes at levels close to
upstream levels and were
less than 2% as toxic as the
lowest cumulative toxic units
of PAH. Metal  concentrations
are high enough that they
should be considered a
potentially masked  cause.

Candidate cause #5 is
unlikely because  even
greater levels of BOD did not
cause reduction of dissolved
oxygen downstream.

Candidate Causes #4,
Ammonia, and  #6, Nutrient
Enrichment, are unlikely
given that state criteria levels
were met and the much
stronger evidence for PAH.

Habitat alteration continues
to impair the site, but it is not
the cause of the increased
DELTA, decreased relative
weight, or the additional
decline in the number of
species.
At Impairment C increased % DELTA
and % Tanytarsini may have different
causes.  Increased DELTA in fish is
probably caused by increased P and
NOX.  Nutrients, especially P,  have
been associated with increased fin
erosion and lesions but some
uncertainty exists since P acts
indirectly.

Ammonia is slightly higher than at
Impairment B and exceeded ammonia
criteria values.  Biological gradients
were absent; however, this may have
been a statistical  artifact given the
number of sites available to perform
the analysis and potential interference
from other stressors downstream.

Metals are considered unlikely
because surface lesions are only
occasionally noted as effects from long
term exposure and only some metal
concentrations were slightly greater
than at Impairment B. Metal
concentrations are high enough that
they should be considered a
potentially masked cause.

The probable cause of extirpation of
Tanytarsini at Impairment C is more
uncertain because less is known about
the natural history and stressor
response relationships of these
benthic invertebrates. Candidate
cause #6, nutrient enrichment, still
seems to be the most likely cause
since all of the strength of evidence
considerations were consistent.

PAH contamination and habitat
alteration continue to impair the site,
but they are not the cause of the
increased % DELTA or extirpation of
Tanytarsini.

The causal characterization at
Impairment C is less certain, but the
strength of evidence favors cause #6,
increased nutrients.
        7.11    Discussion


        An important, practical aspect of this study is that even though the primary cause was
        identified in each case, it is obvious that other causes are also present that would
        constrain the biological community if the dominant cause was removed. For instance, if
        PAHs could be independently removed from the river, metals might be high  enough to
7-48
                               U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
       impair the biological assemblage. Likewise, if metals were removed, habitat alteration
       would still affect the biological community and would lower IBI and ICI scores at
       Impairments B and C.

       Another issue is the impact of habitat alteration and its influence on modifying the
       assimilative capacity of the river. In other words, if the physical habitat were improved,
       would the impacts of PAH contamination be lessened?  At Impairment B, this is unlikely
       based on evidence from at least one river elsewhere that has very good physical habitat
       qualities, yet has an impoverished biological community replete with high levels of %
       DELTA due to high PAH concentrations (OEPA 1992b, Cormier et al. 2000b). The
       strength of evidence analysis can provide these insights for the next step in managing
       ecosystems, which is to find ways to identify and apportion the sources for the identified
       causes and then take action to restore and protect the resource.

       At Impairment C, a physical habitat that included wetlands, riparian wetlands, and
       riparian cover might improve the assimilative capacity of the river by providing sinks for
       the nutrient and ammonia loadings.  However, since PAH and metals contamination are
       still high at Impairment C, removal of nutrient loading alone would result in only a very
       small improvement in biological condition.

       At Impairment B, nutrient enrichment was retained as a candidate cause, even though the
       increase in phosphorous was minute. Nutrient enrichment was an unlikely cause, but the
       reasons for it being improbable come from ecological knowledge from examples in other
       watersheds, not from evidence that permits elimination. The reason nutrient enrichment
       was retained was because it failed to meet the criteria for elimination.  The strength of
       evidence is the proper way to show this evidence.

       There are other uncertainties. Wet weather flow data was not available for review.
       Events,  especially near the combined sewer overflow at RM 6.0, could be undetected
       sources of candidate causes.  Downstream from Impairment C, persistent impairments
       may have other causes. For instance, BOD is elevated at RM 5.8; however, its effects
       are usually associated with a certain lag time that results in low DO.

       The results from this particular causal analysis could have several practical applications.
       If it is determined that the river conditions must be  improved due to state regulations,
       federal TMDL (total maximum daily load) rules, citizen action, or other reasons, one
       option is to remove or decrease all potential stressors identified in the  causal analysis;
       that is, remove both channel modification as well as water and sediment contamination.
       However, there may be intermediate pathways that  may be more  cost effective. Factors
       that should be considered in choosing an option include the desired or expected level of
       improvement in river condition, and the usefulness  of the river's resources versus the
       cost to restore the river. Another factor to consider is the mode of restoration. For
       instance, both PAH and metal remediation may require dredging of the contaminated
       sediments. Knowing which agents (PAH,  metals, or a combination of the two) may
       satisfy our curiosity, but it may not change the management action or ecological
       outcome.  However, it might be determined that knowing the cause is important for
       assigning the financial responsibility for clean-up.  In the latter case, additional
       information may be needed, especially  if restoration costs are high.
Chapter 7: Little Scioto River, Ohio                                                              7-49

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                             Stressor Identification Guidance Document
       7.12   References

       Albers, P. 1995. Petroleum and individual polycyclic aromatic hydrocarbons, Pages
           330-355 in Hoffman, David J. et al, ed. Handbook ofEcotoxicology, CRC Press,
           Boca Raton, Florida.

       Allan, J.D. 1995.  Stream ecology: structure andfunction of'running waters. Chapman
           and Hall Publishers, London.

       Baumann, P.C., and Harshbarger, J.C. 1995. Decline in liver neoplasms in wild brown
           bullhead catfish after coking plant closes and environmental PAHs plummet.
           Environ. Health Perspect.  103:168-170.

       Carpenter, S.R., N.F. Caraco, D.L. Correll, R.W. Howarth, A.N. Sharpley and V.H.
           Smith.  1988.  Non-point pollution of surface waters with phosphorus and nitrogen.
           Ecological Applications 8(3):559-568.

       Cormier, S.M., E.L.C. Lin, F.A. Fulk and B. Subramanian. 2000a.  Estimation of
           exposure criteria values for biliary polycyclic aromatic hydrocarbon metabolite
           concentration in white suckers (Catostomus commersoni).  Environmental
           Toxicology and Chemistry 19:1120-1126.

       Cormier, S.M., E.L.C. Lin, M.R Millward, M.K. Schubauer-Berigan, D. Williams, B.
           Subramanian, R. Sanders, B. Counts and D. Altfater. 2000b.  Using regional
           exposure criteria and upstream reference data to characterize spatial and temporal
           exposures to chemical contaminants.  Environmental Toxicology and Chemistry
           19:1127-1135.

       Dodds, K. and E.B. Welsh. 2000. Establishing nutrient criteria in streams. The North
           American Benthological Society 19:186-196.

       Edwards, R., and J. Riepenhoff. 1998.  State turns to feds for cleanup. Columbus
           Dispatch, April 28, 1998.

       Edwards, A.C., H. Twist and G.A. Codd. 2000.  Assessing the impact of terrestrially
           derived phosphorus on flowing water systems.  Journal of Environmental Quality.
           29:117-124.

       Edwards, C.J., B.L. Griswold, RA. Tubb, E.G. Weber, L.C. Woods.  1984. Mitigating
           effects of artificial riffles and pools on the fauna of a channelized warmwater stream.
           North American Journal of Fisheries Management 4:194-203

       Eisler, R.  2000a.  Polycyclic aromatic hydrocarbons.  Pages 1343-1411 in Handbook of
           Chemical Risk Assessment.  Vol. II. Lewis Publishers, Boca Raton, FL.

       	. 2000b. Handbook of Chemical Risk Assessment. Vol.1. Lewis Publishers,
           Boca Raton, FL.

       Gmur, D.J., and U. Varanasi. 1982. Characterization of benzo[a]pyrene metabolites
           isolated from muscle, liver, and bile of a juvenile flatfish.  Carcinogenesis 5:1397-
           1403.
7-50                                                          U. S. Environmental Protection Agency

-------
                             Stressor Identification Guidance Document
       Hickey, C.W. and W.H. Clements. 1998. Effects of heavy metals on benthic
           macroinvertebrate communities in New Zealand streams. Environmental Toxicology
           and Chemistry 17:2338-2346

       Karr, J.R., and I.J. Schlosser.  1977. Impact of near stream vegetation and stream
           morphology on water quality and stream biota. EPA-600-3-77-097. U.S.
           Environmental Protection Agency, Environmental Research Laboratory, Athens, GA.

       Lin, E.L.C., S.M. Cormier, and J.A. Torsella.  1996. Fish biliary polycyclic aromatic
           hydrocarbon metabolites estimated by fixed-wavelength fluorescence: comparison
           with HPLC-fluorescent detection. Ecotoxicol. Environ. Safety 35:16-23.

       Lin, E.L.C., T.W. Neiheisel, B. Subramanian, D.E. Williams, M.R. Millward, and S.M.
           Cormier. Historical monitoring of biomarkers of exposure of brown bullhead in the
           remediated Black River, Ohio and two other Lake Erie tributaries. Submitted to
           Journal of Great Lakes Research.

       Long, E.R., L.J. Field, and D.D. MacDonald.  1998. Predicting toxicity in marine
           sediments with numerical sediment quality guidelines. Envir. Toxicol. Chem.
           17:714-727.

       Meyer, P.P.  and L.A. Barclay.  1990. Field manual for the investigation offish kills.
           Resource Pub.  177. U.S. Fish and Wildlife Service, Washington, B.C.

       Miltner, R.J. and E.T. Rankin. 1998. Primary nutrients and the biotic integrity of rivers
           and streams. Freshwater Biology 40:145-158.

       Norton, S.B. 1999.  Using biological monitoring data to distinguish among types of
           stress in streams of the Eastern Cornbelt Plains Ecoregion. Ph.D. Dissertation,
           Georgetown University, Fairfax, VA.

       Ohio Environmental Protection Agency (OEPA). 1988a. Biological criteria for the
           protection  of aquatic life: Vol. II. users manual for biological assessment ofohio
           surface waters.  Division of Water Quality Planning and Assessment, Ecological
           Assessment Section, Columbus, OH.

       	. 1988b. Biological and water quality study of the Little Scioto River
           watershed, Marion County, OH. OEPA Technical Report prepared by State of Ohio
           Environmental Protection Agency, Division of Surface Water, Columbus, OH.

       	.  1989a. Addendum to: Biological criteria for the protection of aquatic life:
           Volume II. users manual for biological assessment of Ohio surface waters.  Division
           of Water Quality Planning and Assessment, Ecological Assessment Section,
           Columbus, OH.

       	.  1989b. Biological criteria for the protection of aquatic life: Volume III.
           standardized field and laboratory methods for assessing fish and macroinvertebrate
           communities.  Division of Water Quality Planning and Assessment, Ecological
           Assessment Section, Columbus, OH.

       	.  1989c. Manual of Ohio EPA surveillance methods and quality assurance
           practices. Division of Environmental Services, Columbus, OH.


Chapter 7: Little Scioto River, Ohio                                                              7-51

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                             Stressor Identification Guidance Document
                    1992a. Bottom sediment evaluation, Little Scioto River, Marion, Ohio.
           Division of Water Quality Planning and Ecological Assessment Section, Columbus,
           OH.

       	.  1992b. Biological and water quality study of the Ottawa River, Hog
           Creek, Little Hog Creek, and Pike Run.  OEPA Technical Report EAS/1992-9-7.
           Prepared by State of Ohio Environmental Protection Agency, Division of Surface
           Water, Columbus, OH.

       	.  1994. Biological, sediment, and water quality study of the Little Scioto
           River, Marion, Ohio.  OEPA Technical Report EAS/1994-1-1. Division of Surface
           Water, Ecological Assessment Section, Columbus, OH.

       Rankin, E.T.  1989. The qualitative habitat evaluation index (QHEI): rationale,
           methods, and application. State of Ohio Environmental Protection Agency, Division
           of Water Quality Planning and Assessment, Ecological Assessment Section,
           Columbus, OH.

       	.  1995. Habitat indices in water resource quality assessments. Pages 181-
           208 in W.S. Davis and T.P. Simon (editors). Biological Assessment and Criteria.
           Lewis Publishers, Boca Raton, Florida.

       Rankin E., R. Miltner, C. Yoder and D. Mishne. 1999. Association between nutrients,
           habitat, and the aquatic biota in Ohio rivers and streams. Ohio EPA Technical
           bulletin MAS/1999-1. Ohio EPA, Columbus, OH.

       Roubal, W.T., T.K. Lallier, and D.C. Malins.  1977.  Accumulation and metabolism of
           C-14 labeled benzene, naphthalene, and anthracene by young coho salmon
           (Oncorhynchus kisutch) and starry flounder (Platichthys stellatus). Arch. Environ.
           Contam. Toxicol. 5: 513-529.

       Russo, R.C.  1985. Ammonia, nitrate and nitrite. Pages 455-471 in G.M. Rand and S.A.
           Petrocelli (editors). Fundamentals of Aquatic Toxicology.  McGraw Hill,
           Washington, D.C.

       Sheilds, F.D. Jr., S.S. Knight and C.M. Cooper.  1998. Rehabilitation of aquatic habitats
           in warmwater streams damaged by channel incision in Mississippi. Hydrobiologica
           382:63-86

       Smith, V.H., G.D. Tilman and J.C. Nekola.  1999.  Eutrophication: impacts of excess
           nutrient inputs on freshwater, marine and terrestrial ecosystems.  Environmental
           Pollution 100:179-196.

       Tarplee, W.H. Jr., D.E. Louder, and A.J. Weber. 1971. Evaluation of the effects of
           channelization on fish populations in North Carolina's coastal plain streams.  North
           Carolina Wildlife Resources Commission, Raleigh, NC.

       U.S. Environmental Protection Agency (USEPA).  1996b. Calculation and evaluation of
           sediment effect concentrations for the amphipod Hyallela azteca and the midge
           Chironomus riparius. Assessment and Remediation of Contaminated Sediments
           (ARCS) Program.  Great  Lakes National Program Office, Chicago, IL.  EPA 905-
           R96-008.
7-52                                                           U. S. Environmental Protection Agency

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                             Stressor Identification Guidance Document
                    1998b. 1998 update of ambient water quality criteria for ammonia. Office
           of Water, Washington, DC. EPA 822-R-98-008.

       Varanasi, U., J.E. Stein, M. Nishimoto, and T. Horn.  1983.  Benzo[a]pyrene metabolites
           in liver, muscle, gonads, and bile of adult English sole (Parophrys vetulus).  Pages
           1221-1234 in Cooke, M. and A.J. Dennis, eds. Polynuclear Aromatic Hydrocarbons:
           Formation, Metabolism, and Measurement. Battelle, Columbus, OH, USA.

       Yoder, C.O., and E.T. Rankin. 1995a. Biological criteria program development and
           implementation in Ohio. Pages 109-144 in W.S.  Davis and T.P. Simon, eds.
           Biological Assessment and Criteria:  Tools for Water Resource Planning and
           Decision Making. Lewis Publishers, Boca Raton, FL.

       	.  1995b.  Biological response signatures and the area of degradation value:
           New tools for interpreting  multi-metric data. Pages 236-286 in Biological
           Assessment and Criteria: Tools for Water Resource Planning and Decisionmaking
           Lewis Publishers, Boca Raton, FL..

       Yount, J.D., and G.J. Niemi. 1990. Recovery of lotic communities and ecosystems from
           disturbance; A narrative review of case studies.  Environmental Management
           14:547-569.
Chapter 7: Little Scioto River, Ohio                                                             7-53

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Table 7-13. Fish metrics for the Little Scioto River 1987 and 1992.*
Response
Total No. of Species
No. of Darter Species
No. of Sunfish species
No. of Sucker Species
No. of Intolerant Species
Percent Tolerant Species
Percent Omnivores
Percent Insectivores
Percent Pioneering Species
No. of Individuals
Percent Simple Lithophilic
Species
Percent DELTA
Relative Weight
IBI
River Mile
{9.2}
(9.2)
{19.3}
(22)
{5}
(5.5)
{3}
(4)
{1.3}
(2.5)
{1}
(D
{35.45}
(60.69)
{33.28}
(56.21)
{53.41}
(35.96)
{35.49}
(69.85)
{808.5}
(1104.6)
{21 .24}
(12.8)
{0.13}
(0.14)
{4.021}
(8.6)
{332
(33)
(7.9)
(13)
(0)
(5)
(3)
0
(69.12)
(44.95)
(53.07)
(28.41)
(206)
(18.19)
(1.64)
(74.9)
(23)
{6.5}
(6.5)
{13}
(8.3)
{0}
(0)
{3}
(2.3)
{1}
(1.3)
{0}
(0)
{82.43}
(85.12)
{57.2}
(56.72)
{40.99}
(39.77)
{22.52}
(26.39)
{416.3}
(335)
{2.7}
(42.69)
{0.0}
(9.98)
{34.2}
(38.7)
{24}
(19)
{6.0}
(5.7)
{10}
(10.7)
{0}
(0)
{1.3}
(3.3)
{1.7}
(1.7)
{0}
(0)
{94.28}
(68.14)
{72.47}
(46.84)
{16.73}
(47.8)
{21.94}
(21.76)
{237.33}
(174)
{24.01}
(26.2)
{16.46}
(14.51)
{29.773}
(17.031)
{14}
(19)
(4.4)
(7.7)
(0)
(3)
(D
(0)
(82.75)
(71.37)
(21.91)
(17.81)
(137)
(31.45)
(22.37)
(7.2)
(18)
(3.1)
{3.3}
{0}
{0.7}
{0.7}
{0}
{98.2}
{94.15}
{3.95}
{4.05}
{84.7}
{5.88}
{32.8}
{10.7}
{12}
{2.7}
(2.7)
{6}
(7.7)
{0}
(0)
{0.3}
(2.7)
{1}
(1.3)
{0}
(0)
{94.95}
(70.85)
{85.4}
(51.77)
{10.18}
(42.51)
{7.58}
(23.31)
{237.33
}
(94)
{9.14}
(24.91)
{14.22}
(10.99)
{24.482
}
(6.3)
{13}
(19)
{0.1}
(0.3)
{8.7}
(9.7)
{0.3}
{1}
(2.7)
{2}
(2.7)
{0}
{63.41}
(38.64)
{62.72}
(31.92)
{32.74}
(55.36)
{5.33}
(22.1)
{78}
(75)
{19.01}
(28.08)
{16.19}
(10.04)
{46.079}
(21.1)
{14}
(25)
                                                                                                                                  Q.
                                                                                                                                  Q.
                                                                                                                                  rt;
                                                                                                                                  o'
                                                                                                                                  3
                                                                                                                                  D)
                                                                                                                                  D)
                                                                                                                                  CT

                                                                                                                                  (D

-------
Table 7-14.  Macroinvertebrate metrics for the Little Scioto River 1987 and 1992.*
Response
Total Number of Macroinvertebrates
Total No. of Taxa collected at a Site, both
Qualitative and Quantitative
Total No. of Quantitative Taxa
No. of Mayfly Taxa
No. of Caddisfly Taxa
No. of Dipteran Taxa
No. of Qualitative EPTTaxa
Percent Mayfly Taxa
Percent Caddisfly Taxa
Percent Tanytarsini Midges
Percent Dipterans
Percent Non-insects
Percent Tolerant Organisms
Percent Cricotopus
ICI
River Mile
{9.2}
(9.2)
{773}
(1464)
{51}
(47)
{34}
(36)
{6}
(7)
{2}
(3)
{19}
(20)
{10}
(8)
{56.016}
(58.811)
{4.657}
(6.557)
{1.552}
(3.347)
{26.132}
(32.445)
{7.762}
(1.639)
{4.916}
(8.607)
{0.388}
(0.48)
{40}
(38)
(7.9)
(1952)
(38)
(30)
(2)
(0)
(18)
(1)
(16.393)
(0)
(3.381)
(74.795)
(5.43)
(15.061)
(0)
(16)
{6.5}
(6.5)
{1116}
(2815)
{38}
(29)
{25}
(18)
{3}
(2)
{2}
(0)
{15}
(12)
{2}
(0)
{20.251}
(5.009)
{0.179}
(0)
{4.48}
(2.345)
{55.018}
(57.336)
{20.43}
(37.549)
{37.993}
(77.371)
{6.631}
(0)
{22}
(8)
{5.8}
(5.7)
{207}
(1600)
{26}
(32)
{13}
(18)
{2}
(2)
{0}
(0)
{7}
(13)
{1}
(1)
{3.382}
(2)
{0}
(0)
{0.966}
(0)
{37.198}
(91)
{56.039}
(7)
{61.353}
(67.75)
{0}
(8)
{8}
(6)
(4.4)
(1899)
(27)
(20)
(1)
(1)
(13)
(0)
(0.263)
(0.053)
(0)
(74.829)
(21.959)
(54.766)
(2.53)
(10)
{3.2}
{763}
{28}
{14}
{1}
{0}
{10}
{4}
{1.573}
{0}
{3.67}
{95.937}
{0.524}
{20.315}
{0}
{8}
{2.7}
(2.1)
{1779}
(5242)
{28}
(41)
{13}
(23)
{0}
(2)
{0}
(3)
{11}
(14)
{2}
(6)
{0}
(0.114)
{0}
(0.267)
{0}
(0.343)
{23.834}
(97.138)
{75.998}
(2.461)
{89.545}
(29.569)
{4.947}
(0.301)
{4}
(18)
{0.4}
(0.4)
{645}
(1151)
{24}
(37)
{16}
(26)
{2}
(3)
{0}
(1)
{12}
(16)
{1}
(2)
{1.24}
(3.215)
{0}
(0.087)
{0}
(2.085)
{61.085}
(91.659)
{37.674}
(4.344)
{52.713}
(59.34)
{4.961}
(2.172)
{6}
(18)
*{}=1987; ()= 1992

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                              Stressor Identification Guidance Document
         Table 7-15.  QHEI metrics for the Little Scioto River 1987 and 1992.*
Metric
Substrate
Cover
Cover
Types
Channel
Riparian
Pool
Riffle
Gradient
QHEI
River Mile
{9.2}
(9.2)
{18}
(16)
{10}
(14)
{3}
(6)
{18}
(17)
{9}
(6)
{8}
(11)
{5}
(6)
{6}
(6)
{74}
(76)
(7.9)
(5)
(10)
(4)
(10)
(5.5)
(8)
(0)
(4)
(42.5)
{6.5}
(6.5)
{1}
(1)
{9}
(11)
{2}
(6)
{6}
(10)
{4}
(4)
{6}
(8)
{0}
(0)
{4}
(4)
{30}
(38.5)
{6.0
}
{1}
{13}
{6}
{10}
{4}
{8}
{0}
{4}
{40}
(5.7
)
0)
(10)
(4)
(10)
(6)
(9)
(0)
(4)
(40)
(4.4)
(5)
(10)
(4)
(10)
(6)
(6)
(0)
(2)
(39)
{3.1}
{1}
{11}
{4}
{11}
{5}
{6}
{0}
{2}
{36}
{2.7}
(2.7)
{1}
(5)
{13}
(11)
{6}
(6)
{10.5}
(10)
{6}
(8)
{8}
(8)
{0}
(0)
{2}
(2)
{40.5}
(42)
{0.1}
(0.3)
{1}
(5)
{12}
(9)
{5}
(6)
{10}
(7)
{8}
(5.5)
{8}
(8)
{0}
(0)
{4}
(4)
{43}
(38.5)
             = 1987;() = 1992
7-56
U.S. Environmental Protection Agency

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Table 7-16. Average concentrations of selected sediment organic compounds (mg/kg) in the Little Scioto River, Ohio, by river mile
in 1987, 1991, 1992 and 1998.*
Compound
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
River Mile
[11.1]
[0.59]ND
[0.59]ND
[0.072]J
[0.068]J
[0.058]J
/9.42\
(9.5)
[9.21]
(ND)
[0.7]ND
(ND)
[0.70]ND
(ND)
[0.043]J
(ND)
[0.052]J
(ND)
[0.052]J
(7.9)
(ND)
(ND)
(ND)
(ND)
(ND)
/7.15\
[7.09]
[0.047]J
[0.037]J
/15\J
[0.059]J
/25\
[0.051]J
[0.046]J
{6.5}
/6.6\
(6.5)
[6.6]
{14.8}
(ND)
[760]J
{66.8}
(ND)
[100]J
{44.7}
/15VJ
(8.2)J
[310]J
{23.6}
/20\J
(18.1)
[200]J
{213.2}
(9.9)J
[160]J
/5.8\
(5.8)
[6.2]
/150\
(5)
[5]
/360\
(27.1)
[41]
/185\
(16.5)
[42]J
/215\
(16.8)
[95]
(12.87)
[80]
(4.4)
(4.3)
(7.9)
(6.9)
(6.9)
(4.6)
{2.7}
/2.7\
(2.7)
[2.65]
{1.3}
(ND)
[0.930]J
{2.3}
(ND)
[3.7]
{4.3}
(2)J
[8.2]
{2.0}
(1.6)J
[12]
{21.3}
(ND)
[10]
(0.4)
(ND)
(3.3)
(15.8)
(13.8)
(10.5)

-------
Table 7-16 (continued). Average concentrations of selected sediment organic compounds (mg/kg) in the Little Scioto River, Ohio,
by river mile in 1987, 1991, 1992 and 1998.*
Compound
Benzo(ghi)perylene
Benzo(a)pyrene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
River Mile
[11.1]
[0.052]J
[0.067]J
[0.087]J
[0.59]ND
[0.19]J
/9.42\
(9.5)
[9.21]
(ND)
[0.044]J
(ND)
[0.053]J
(ND)
[0.065]J
(ND)
[0.7]ND
(ND)
[0.097]J
(7.9)
(ND)
(ND)
(ND)
(ND)
(ND)
/7.15\
[7.09]
/10VJ
[0.030]J
/10VJ
[0.043]J
/15VJ
[0.081]J
[0.56]N
D
/20VJ
[0.20]J
{6.5}
/6.6\
(6.5)
[6.6]
{144.1}
(49.5)
[150]ND
{141.1}
(14.8)J
[210]J
{119.5}
/15\J
(16.5)
[390]J
{33.3}
(ND)
[150]ND
{78.4}
/50\
(8.2)J
[100]J
/5.8\
(5.8)
[6.2]
/65\
(11.2)
[19]
/125\
(15.8)
[14]
/305\
(20.8)
[13]
(4.6)
[16]ND
/550\
(37.6)
[44]J
(4.4)
(4.9)
(7.2)
(9.9)
(ND)
(13.5)
{2.7}
/2.7\
(2.7)
[2.65]
{16.5}
(ND)
[13]
{11.4}
(ND)
[12]
{9.7}
(1.6)J
[13]
{2.1}
(ND)
[3.7]
{6.3}
(ND)
[14]
(0.4)
(6.9)
(11.5)
(ND)
(3.3)
(22.4)

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Table 7-16 (continued).  Average concentrations of selected sediment organic compounds (mg/kg) in the Little Scioto River, Ohio,
by river mile in 1987, 1991, 1992 and 1998.*
Compound
Fluorene
lndeno(1 ,2,3-cd)pyrene
Naphthalene
Phenanthrene
River Mile
[11.1]
[0.590]ND
[0.045]J
[0.59]ND
[0.14]J
/9.42\
(9.5)
[9.21]
(ND)
[0.70]ND
(ND)
[0.037]J
(ND)
[0.70]ND
(ND)
[0.053]J
(7.9)
(ND)
(ND)
(ND)
(ND)
/7.15\
[7.09]
[0.059]J
/5\J
[0.56]ND
[0.56]ND
[0.1 1]J
{6.5}
/6.6\
(6.5)
[6.6]
{18.3}
(ND)
[830]J
{156.0}
(13.2)J
[150]ND
{22.9}
(ND)
[260]
{88.3}
/40\J
(ND)
[230]
/5.8\
(5.8)
[6.2]
/200\
(7.0)
[20]
/60\
(14.5)
[16]
/70\
(4.6)
[18]J
/470\
(24.1)
[38]J
(4.4)
(4.0)
(6.6)
(ND)
(12.9)
{2.7}
/2.7\
(2.7)
[2.65]
{1.2}
(ND)
[0.98]J
{18.6}
(ND)
[10]
{1.6}
(ND)
[0.28]J
{2.0}
(ND)
[2.8]J
(0.4)
(ND)
(10.5)
(ND)
(2.6)J
 {}= 1987;/\= 1991; () = 1992;[] = 1998

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Table 7-16 (Continued). Average concentrations of selected sediment organic compounds (mg/kg) in the Little Scioto River, Ohio,
by river mile in 1987, 1991, 1992 and 1998.*
Compound
Pyrene
River Mile
[11.1]
[0.2]J
/9.42\
(9.5)
[9.21]
(ND)
[0.1 ]J
(7.9)
(ND)
/7.15\
[7.09]
/15VJ
[0.2]J
{6.5}
/6.6\
(6.5)
[6.6]
{67.5}
/30\J
(ND)
[810]J
/5.8\
(5.8)
[6.2]
/405\
(23.8)
[32]J
(4.4)
(10.2)
{2.7}
/2.7\
(2.7)
[2.65]
{5.2}
(ND)
[10]
(0.4)
(17.5)
{} = 1987 data from OEPA 1988, sample depth unknown
/ \ = 1991  data from OEPA 1992a, sample depth unknown
() = 1992-93 data from OEPA 1994, sample from 1-6" except RM 7.9 sample from 8-12"
[ ] = 1998 data from OEPA unpublished, sample depth unknown
J is an estimated value that is above zero but below the practical quantitation limit.

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Table 7-17.  Average concentrations (mg/kg) of selected metals in sediment from the Little Scioto River, Ohio, by river mile in 1987,
1991,1992 and 1998.*
Metal




Arsenic



Cadmium



Chromium



Copper


Lead



Mercury



River Mile


[11.1]




[3.6]J



[0.1]ND



[8.1]J


[15.7]



[23.8]



[0.1]ND
/9.4\
(9.5)
[9.2]


/<10\
(<10)
[8.3]J

/<1 .0\
(<1.0)
[0.1]ND

/5.8\
(7.3)
[14.3]J

(7.4)
[24.1]

/<10\
(12.1)
[20.4]

/<0.1\
(<0.1)
[0.2]J


(7.9)



(12.4)



(<1.0)



(13.6)


(17.2)



(19.1)



(<0.1)

/7.2\

[7.1]


/<10\

[6.0]J

/<1 .0\

[0.2]

/13.2\

[8.9]


[22.9]

/25.5\

[24]J

/<0.1\

[0.1]J
{6.5}
/6.6\
(6.5)
[6.6]
{11.2}
/<10\
(<10)
[10.8]J
{1.8}
/3.4\
(<1.0)
[0.1]ND
{47.6}
/415\
(208)
[32.3]J
{68}
(79)
[39.2]
{170}
/175.5\
(172)
[46.4]

/0.3\
(0.33)
[0.3]J
/5.8\
(5.8)
[6.2]


/<10\
(13.8)
[9.8]J

/1.0\
(<1.0)
[2.0]

/39.2\
(60.9)
[50.4]

(56.0)
[133]

/59.5\
(84.6)
[220]J

/0.2\
(0.2)
[0.6]J


(4.4)



(11.3)



(10.5)



(302)


(76.8)



(93.4)



(0.8)

{2.7}
/2.7\
(2.67)
[2.65]
{9.49}

(<10)
[9.0]
{4.39}

(1.0)
[1.4]
{134}

(71.2)
[77.1]
{83}
(42.4)
[79.3]
{160}

(108)
[180]J


(0.12)
[0.4]J


(0.36)



(<10)



(1.6)



(48.6)


(24.5)



(38)



(<0.1)


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Table 7-17 (continued).  Average concentrations (mg/kg) of selected metals in sediment from the Little Scioto River, Ohio, by river mile in
1987, 1991,1992 and 1998.*
Metal

Zinc

River Mile
[11.1]

[48.2]
/9.4\
(9.5)
[9.2]

(30.6)
[81.4]
(7.9)

(79.0)
/7.2\
[7.1]

[66.6]
{6.5}
/6.6\
(6.5)
[6.6]
{187}
(173)
[89.2]
/5.8\
(5.8)
[6.2]

(141)
[280]J
(4.4)

(226)
{2.7}
/2.7\
(2.67)
[2.65]
{760}
(408)
[316]J
(0.36)

(96.8)
{} = 1987 data from OEPA 1988, sample depth unknown
/ \ = 1991  data from OEPA 1992, sample depth unknown
() = 1992-93 data from OEPA 1994, sample from 1-6" except RM 7.9 sample from 8-12"
[ ] = 1998 data from OEPA unpublished, sample depth unknown
J is an estimated value that is above zero but below the practical quantitation limit.

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Table 7-18.  Average concentrations of selected water chemistry parameters (mg/L) in the Little Scioto River, Ohio, by river mile in 1987,
1992 and 1998.*
Compound
Ammonia
Dissolved
oxygen**
BOD
Nitrate- nitrite,
NOX
Phosphorus,
total P
Hardness,
CaCO3
River Mile
[11.1]
[0.1,0.3]

[<2.0, 6.6]
[0.7,3.3]
[0.5,0.6]
[222,250]
(9.2)
[9.2]
(<0.05)
[<0.05,<0.0
5]
(12.2,8.8)
(1.0)
[<2.0, <2.0]
(1.2)
[0.4, 0.2]
(0.06)
[1.8,0.1]
(329)
[275, 269]
{7.9}
(7.9)
(<0.05)
{4.6,
2.8}
(7.9,
5.7)
(1.0)
(1.4)
(0.07)
(327)
[7.1]
[0.11,
<0.05]

[<2.0, 2.1]
[0.73, <0.1]
[0.36,0.13]
[281 , 407]
{6.5}
(6.5)
(0.12)
{7.27, 1.9}
(2.3)
(0.8)
(0.09)
(389)
{5.8}
(5.8)
[6.2]
(1.16)
[0.35, 0.69]
{8.3, 4.2}
(8.23,
4.21)
(4.7)
[4.6,13]
(8.1)
[0.33, 2.37]
{1.65}
(2.17)
[1.9, 1.21]
(278)
[224,261]
{4.4}
(4.4)
(1.44)
{8.8, 3.2}
(5.2, 4.3)
(4.2)
(6.6)
(1 .96)
(280)
{2.7}
(2.7)
[2.7]
(2.10)
[0.67, 1.1]
{6.67, 2.0}
(4.1,3.0)
(3.5)
[3.3,4.1]
(4.5)
[3.5, 0.9]
{2.71}
(1 .80)
[1.18, 1.31]
(306)
[228,210]
{0.4}
(0.4)
(0.58)
{6.74, 2.5}
(5.6, 4.4)
(2.2)
(4.47)
(1.34)
(320)
   {} = 1987 (OEPA 1988b; () = 1992-1993 (OEPA 1994) [ ] = 1998 (OEPA August and October, unpublished data).
   Dissolved Oxygen {maximum, minimum}, data from 1987 (OEPA, 1988b).
                  (maximum, minimum from box plots), data from 1992 (OEPA,  1994.

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                             Stressor Identification Guidance Document
       Table 7-19.  PAH concentrations at nearest upstream location and locations of
       impairments (mg/kg). (Hyalella azteca sediment effects concentrations, PEL and TEL,
       normalized to sediment WET weight.)
Chemical
PEL TEL
Benzo(a)pyrene (BAP)
0.32 0.03
Naphthalene (NAPH)
0.14 0.02
Fluorene
0.15 0.01
Phenanthrene
0.41 0.02
Anthracene
0.17 0.03
Fluoranthene
0.32 0.04
Pyrene
0.49 0.02
Benzo[a]anthracene
0.28 0.03
Chrysene
0.41 0.02
Benzo(g,h,i)perylene
0.25 0.01
PAH sediment concentration
Nearest
Upstream
Location
(0)
[0.053] #
(0)
[0]
(0)
[0]
(0)
[0.053] #
(0)
[0]
(0)
[0.097] #
(0)
[0.076] #
(0)
[0.043] #
(0)
[0.065] #
(0)
[0.044] #
Impairment
A
(0)
[0.043] #
(0)
[0]
(0)
[0.059] #
(0)
[0.11]#
(0)
[0.037] #
(0)
[0.2] #
(0)
[0.16]#
(0)
[0.059] #
(0)
[0.081 ]#
(0)
[0.03] #
Impairment
B
/141.1\*
(14.8)*
[210]*
/22.9\*
(0)
[260]*
(0)
[830] *
(0)
[230] *
(0)
[100]*
(8.2) *
[100]*
(0)
[810]*
(8.2) *
[310]*
(16.5)*
[390] *
(49.5) *
[150]*
Impairment
C
/125\*
(15.8)*
[14]*
/70\*
(4.6) *
[18]*
/200\ *
(7)*
[20]*
/470\ *
(24.1)*
[38]*
/360\ *
(27.1)*
[41]*
/550\ *
(37.6) *
[44]*
/405\ *
(23.8) *
[32]*
/185\*
(16.5)*
[42]*
/305\ *
(20.8) *
[13]*
/65\*
(1 1 .2) *
[19]*
       (*) exceeds PEL and TEL; (#) exceeds TEL.
       Zero = below detection; No Entry = No data
 /\= 1987-1991, ( ) = 1992, []  = 1998.
for that year
7-64
                U.S. Environmental Protection Agency

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                             Stressor Identification Guidance Document
       Table 7-20.  Metals concentrations at nearest upstream location and locations of
       impairments (mg/kg). (Hyalella azteca sediment effects concentrations, PEL and TEL,
       normalized to sediment wet weight.)
Chemical
PEL TEL
As
48.4 10.8
Cd
3.2 0.58
Cr
119.4 32.3
Cu
101.2 28
Pb
81.7 37.2
Zn
544 98.1
Nearest
Upstream
Location
/5\
(5)
[8.3]
/0.5\
(0.5)
[0]
/5.8\
(7.3)
[14.3]
(7.4)
[24.1]
(12.1)
[20.4]
(30.6)
[81 .4]
Impairment
A
/8\
(12.4)#
[6]
/0.5\
(0.5)
[0.2]
/13.2\
(13.6)
[8.9]
(17.2)
[22.9]
(19.1)
[24]
(79)
[66.6]
Impairment
B
/11.2\#
(0)
[10.8] #
/1.8\#
(0.5)
[0.1]
/47.6\#
(208) *
[32.3] #
/68\#
(79) #
[39.2] #
/170\*
(1 72) *
[46.4] #
/187\#
(1 73) #
[89.2]
Impairment
C
/8\
(13.8)#
[9.8]
/1\
(0.5)
[2]#
/39.2\#
(60.9) #
[50.4] #
(56) #
[133]*
/59.5\#
(84.6) *
[220] *
(141)#
[280] #
       (*) exceeds PEL and TEL; (#) exceeds TEL.  *ND= not detected, NA = not available, / \:
       1987-1991,( ) = 1992, [ ] = 1998. Zero = below detection; No Entry = No data for that
       year
Chapter 7: Little Scioto River, Ohio
7-65

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      APPENDIX A
  OVERVIEW OF WATER
MANAGEMENT PROGRAMS
  SUPPORTED BY THE SI

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                            Stressor Identification Guidance Document
Appendix A
Overview of Water
Management Programs
Supported by the SI
       The following sections describe several major water management programs and how the
       SI process can support them.

       A.1   Water Quality Assessment Reports Under CWA Section 305(b)

       In 1987, EPA's Office of Water recommended that regulatory authorities increase the
       use of biological monitoring to better characterize aquatic systems. State and Tribal
       agencies were directed to protect the fishable and swimmable goals of the Clean Water
       Act.  Under Section 305(b), States, Territories, the District of Columbia, interstate water
       commissions, and participating American Indian Tribes are required to assess and report
       on the quality of their waters (USEPA  1997).  The results of 305(b) assessments are not
       raw data, but rather are statements about the degree to which each waterbody supports
       the uses designated in state or tribal water quality standards. Each State and Tribe
       aggregates these assessments and extensive programmatic information in a 305(b) report,
       which is a detailed document usually including information from multiple agencies.
       EPA then uses individual 305(b) reports to prepare a biennial National Water Quality
       Inventory Report to Congress.  This report is the primary vehicle for informing Congress
       and the public about water quality conditions in  the United States.

       Most of the information contained in 305(b) assessments is based on data collected and
       evaluated by states, tribes, and other jurisdictions over the two-year period immediately
       preceding issuance of the report. The Report to  Congress contains national summary
       information about water quality conditions in rivers, lakes, estuaries, wetlands, coastal
       waters, the Great Lakes, and groundwater. The report also contains information about
       public health and aquatic ecosystem concerns, water quality monitoring, and state and
       federal water pollution management programs.

       States and Tribes base their 305(b) water quality determinations on whether waterbodies
       are clean enough to support basic uses, such as aquatic life, swimming, fishing, and
       drinking supply. These uses, along with appropriate national criteria and anti-
       degradation statements, are part of the water quality standards set by each state or tribe
       to protect its waters.  These standards must be approved by EPA.

       Water quality for each individual use is rated as  either:

              *•   Good/Fully Supporting

              *•   Good/Threatened
              >   Fair/Partially Supporting

              >   Poor/Not Supporting

              >   Poor/Not Attainable
Appendix A: Overview of Water Management Programs                                            A-1

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                              Stressor Identification Guidance Document
       For waterbodies with more than one use, information is consolidated into a summary use
       support designation of general water quality conditions.  These uses are characterized as
       either:

               >  Good/Fully Supporting All Uses

               *•  Good/Threatened for One or More Uses

               *•  Impaired for One or More Uses

       Once a state or tribe has determined, under section 305(b), that a waterbody is impaired
       for one or more uses, the state or tribe is required to identify the source and cause of
       impairment. Some causes are much easier to identify than others.  For example, a case
       where impairment is caused by a specific chemical from a point source discharge might
       be straightforward and easily analyzed.  Monitoring programs, however, must deal with
       impacts caused not only by chemical toxicity, but also conventional pollutants (e.g.,
       temperature, pH and dissolved oxygen) and anthropogenic pollutants from non-point
       sources.  Monitoring agencies need the ability to evaluate the relative impact that a
       particular pollutant or other stressor has on the biological integrity of a receiving water.

       A.2    303(d) Lists and TMDLs

       Section 303 of the 1972 Clean Water Act requires States, Territories and authorized
       Tribes to establish water quality standards and Total Maximum Daily Loads TMDLs) for
       EPA review and approval. Water quality standards identify the uses for each  waterbody
       (e.g., drinking water supply,  contact recreation, aquatic life support) and the water
       quality criteria to  support that use. Water quality criteria can be either numeric (e.g., no
       more than 10 |-ig/L of copper) or narrative (e.g., nutrients are not to exceed levels which
       cause an imbalance  of aquatic flora and fauna). Water quality standards also  include
       antidegradation policies to prevent deterioration of existing high quality waters.

       Under Section 303(d), States, Territories and authorized Tribes must identify  impaired
       waters and establish TMDLs for these waters.  Impaired waters are those that do not
       meet applicable water quality standards, even after point sources of pollution  have
       installed the minimum required levels of pollution control technology. States, Territories
       and authorized Tribes are required to submit their list of impaired every two years.

       States, Territories and authorized Tribes are required to establish priority rankings for
       impaired waters on the 303(d) lists and develop TMDLs for these waters.  A TMDL
       specifies the maximum amount of a pollutant that a waterbody can receive and still meet
       water quality standards, and  allocates pollutant loadings among point and nonpoint
       pollutant sources. EPA must approve or disapprove lists and TMDLs established by
       States, Territories and authorized Tribes. If a State, Territory or authorized Tribe
       submission is inadequate, EPA must identify the impaired waters and establish the
       TMDL.

       TMDLs are a critical component of the water quality program.  They provide  the analytic
       underpinning for watershed decisions and promote integrated program planning,
       implementation, and funding. For example, controlling sediment and/or nutrient
       loadings can protect aquatic habitat, wetlands, endangered species, and drinking water
       sources.  As requirements are strengthened and public communication emphasized,
       sound procedures for identifying stressors and management solutions will become more
       important.


A-2                                                            U.S.  Environmental Protection Agency

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                               Stressor Identification Guidance Document
        Development of a TMDL varies based on numerous factors including environmental
        setting, waterbody type, source type/behavior, and pollutant type/behavior. However,
        TMDL development generally includes the following activities:

               1.       Problem Identification: characterization of the impairment and
                       identification of the pollutant causing the impairment;

               2.       Identification of Water Quality Targets: establishment of the TMDL
                       endpoint or target value, which is typically the applicable numeric water
                       quality criterion or a numeric interpretation of the narrative water quality
                       standard;

               3.       Source Assessment: estimation of the point, nonpoint and background
                       sources of pollutants of concern, including magnitude and location of
                       sources;

               4.       Allocations: identification of appropriate wasteload allocations for point
                       sources and load allocations for nonpoint sources;

               5.       Link Between Numeric Target(s) and Pollutant(s) of Concern: Analysis
                       of the  relationship between numeric target(s) and identified pollutant
                       sources. For each pollutant, describes the analytical basis for conclusion
                       that sum of wasteload allocations, load allocations, and margin of safety
                       does not exceed the loading capacity of the receiving water(s).

               6.       Calculation of the explicit or implicit margin of safety for each pollutant
                       and description of accounting for seasonal variations and critical
                       conditions in the TMDL.

        A.2.1  Causes for Impairment: Pollutants and Pollution

        Waterbodies are impaired by a variety of stressors. Recent data indicate that the top
        causes for impairment include sedimentation/siltation/turbidity and suspended solids
        (16%), nutrients (13%), pathogens (13%), and dissolved oxygen ( 10%). These stressors
        are often associated with sources or activities that fall under the Clean Water Act
        definition of pollutant, or pollution. Pollution is defined in Section  502(19) as the "man-
        made or man-induced  alteration of the chemical, physical, biological, and radiological
        integrity of water."

        Section 303(d) requires the identification and listing of all impaired waterbodies
        regardless of the origin or source of the pollution or pollutant.  Current regulations
        require that TMDLs be calculated only for pollutants. Pollutants are defined in Section
        502(6) as "dredged spoil, solid waste, incinerator residue, sewage, garbage, heat, and
        industrial, municipal, and agricultural waste discharged into water."

        Both pollution and pollutants are "stressors" that can be identified and evaluated using
        the SI process. Under current regulations, those calculating TMDLs will benefit directly
        from guidance on  identifying stressors considered pollutants under the Clean Water Act.
        The SI guidance can also assist in establishing the causal linkage between a pollutant and
        the biological impairment, and thus provide a basis for the development of a TMDL.  For
        example, if a pollutant causes ecosystem changes that alter the fish community, the
Appendix A: Overview of Water Management Programs                                               A-3

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                             Stressor Identification Guidance Document
       altered biological community is an impairment that can be traced to a pollutant for which
       a TMDL can be calculated.

       A.2.2  EPA Actions to Implement the TMDL Program

       In an effort to speed the Nation's progress toward achieving water quality standards and
       improving the TMDL program, EPA began, in 1996, a comprehensive evaluation of
       EPA's and the states' implementation of their Clean Water Act section 303(d)
       responsibilities.  EPA convened a committee under the Federal Advisory Committee Act,
       composed of 20 individuals with diverse backgrounds, including agriculture, forestry,
       environmental advocacy, industry, and state, local, and tribal governments.  The
       committee issued its recommendations in  1998.  These recommendations were used to
       guide the development of proposed changes to the TMDL regulations, which EPA issued
       in draft in August, 1999. After a long comment period, hundreds of meetings and
       conference calls, much debate, and the Agency's review and serious consideration of
       over 34,000 comments, the final rule was  published on July 13, 2000. However,
       Congress added a "rider" to one of their appropriations bills that prohibits EPA from
       spending FY2000 and FY2001 money to implement this new rule. The current rule
       remains in effect until 30 days after Congress permits EPA to implement the new rule.
       TMDLs continue to be developed and completed under the current rule, as required by
       the 1972 law and many court orders. The regulations that currently apply are those that
       were issued in 1985 and amended in 1992 (40 CFR Part 130, section 130.7). These
       regulations mandate that states, territories, and authorized tribes list impaired  and
       threatened waters and develop TMDLs.

       A.2.3  Stressor Identification and the TMDL Program

       EPA developed the SI process to assist water resource managers in identifying and
       delineating stressors causing biological impairments to waterbodies. While not all water
       quality impairments listed under 303(d) are linked directly to biological components of
       waterbodies, a sample of submittals from  19  states indicate that approximately one-half
       of waterbodies listed as impaired under 303(d) are not meeting biological designated
       uses (e.g., aquatic life, cold water fishery). The SI process will have direct utility to
       States, Tribes, and EPA by providing sound approaches to evaluating the causes of
       biological impairments under the TMDL Program.

       As used in the SI process, the term Stressor is synonymous with the terms pollutant and
       pollution which,  under Section 303(d), are considered causes of impairment.  The
       identification of pollutant stressors resulting in biological impairment to waterbodies,
       and the diagnostic evaluation of the sources of these  stressors, is an essential first step in
       calculating Total Maximum Daily Loads under Section 303(d) of the Clean Water Act.
       For pollution stressors (e.g., habitat degradation, water control structures), for which
       TMDLs are not calculated, SI results can be used to identify the sources of the pollution
       for use in alternative watershed management activities.

       A.3   State/Local Watershed Management

       Since 1991, EPA has promoted a watershed protection approach to help address the
       nation's remaining water resource challenges (USEPA 1991a).  The watershed approach
       is an integrated, holistic strategy for protecting and managing surface water and
       groundwater resources by watershed, a naturally defined hydrologic unit. For any given
       watershed, the approach considers not only the water resource; such as a stream, river,


A-4                                                            U.S. Environmental Protection Agency

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                              Stressor Identification Guidance Document
        lake, estuary, or aquifer; but all of the land from which water drains into that resource.
        The watershed approach uses all aspects of water resource quality—physical (e.g.,
        temperature, flow, mixing, habitat); chemical (e.g., conventional and toxic pollutants,
        such as nutrients and pesticides); and biological (e.g., health and integrity of biotic
        communities, biodiversity).  EPA's Office of Water has worked to orient and coordinate
        point source, non-point source, surface water, wetlands, coastal, groundwater, and
        drinking water programs within a watershed context.

        The watershed approach is not a program but a way to organize programs,  so that the use
        of SI will vary  with the program conducting the investigation. The watershed approach,
        however, can facilitate an SI investigation since information is already integrated from
        various sources, such as point source discharges and non-point source runoff. This
        integrated information can help investigators make sense of disturbances through
        knowledge of potential sources of stressors that might feed into that location or might
        affect the food source or some other essential ecosystem component by affecting the
        natural continuum (Vannote et al. 1980).

        The challenge for identifying stressors for watershed-based programs is proper scaling.
        Even though the SI may be initiated by a program using the watershed approach, the
        impairment may not be watershed wide. Impairment to the biological system may be
        difficult to determine on a watershed scale.  Similarities among biota tend to follow
        ecoregions, rather than watersheds.  Several  ecoregions may exist within a watershed,
        especially where elevation differences are great. The biota within any given ecoregion
        may respond differently to a given stressor than the biota within a neighboring ecoregion.
        Accurate scaling of the problem is important any time a biological impairment is found,
        but especially with the watershed approach, to ensure that the information  is used to full
        advantage in identifying and characterizing stressors.

        A.4    Non-point Source 319 Management

        The 1987 Water Quality Act Amendments to the Clean Water Act added section 319,
        which established a national program to assess and control non-point source (NFS)
        pollution. Under this program, states and tribes are asked to assess their NFS pollution
        problems and submit their assessments to EPA.  The assessments included a list of
        navigable waters within the State or Tribal Territories, which without additional action
        to control NFS pollution, cannot reasonably be expected to attain or maintain applicable
        water quality standards or the goals and requirements of the Clean Water Act.  Section
        319 also requires identification of categories and subcategories of NFS pollution that
        contribute to impairment of waters, descriptions of procedures for identifying and
        implementing best management practices, control measures for reducing NFS pollution,
        and descriptions of State, Tribal, and local programs used to abate NFS pollution.

        NFS programs need to identify and control NFS pollutants. Since NFS pollutants can be
        difficult to trace, identifying the source of these pollutants is probably the greatest
        challenge for NFS programs.  The SI process can help investigators obtain greater
        confidence that stressors have been accurately identified.  Attributing responsibility to a
        particular source can be very straightforward and obvious or very difficult.  Mechanisms
        used to attribute responsibility need to be assessed for each situation, and common sense
        should be used. For example, runoff may be obviously coming from one farm. In
        another situation, runoff may encounter multiple potential sources of pollution, including
        a poultry farm, a cattle feedlot, and an abandoned mine. In the latter situation, if nutrient
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                              Stressor Identification Guidance Document
       loading is the identified stressor, attributing responsibility between the poultry farm and
       cattle feedlot may be difficult, but ruling out the abandoned mine would be simple.

       A.5   Permitting Programs

       A.5.1 NPDES Permits

       All discrete sources of wastewater are required to obtain a National Pollutant Discharge
       Elimination System (NPDES) permit (or State equivalent) that regulates the facility's
       discharge of pollutants. This approach to controlling and eliminating water pollution is
       focused on pollutants determined to be harmful to receiving waters and sources of such
       pollutants. Authority for issuing NPDES permits is established under Section 402 of the
       CWA. A summary of the Water Quality-based "Standards to Permits" Process for
       Toxics Control (adapted from the Technical Support Document for WQ-based Toxics
       Control, TSD, USEPA 1991a) lists nine steps:

               1.      Define water quality objectives, criteria, and standards;

               2.      Establish priority waterbodies;

               3.      Characterize effluent - chemical-specific or Whole Effluent Toxicity
                      (WET);
                      a)  evaluate for excursions above standards,
                      b)  determine reasonable potential, and
                      c)  generate effluent data;

               4.      Evaluate exposure (critical flow, fate modeling, and mixing) and
                      calculate wasteload allocation;

               5.      Define required discharge characteristics by the waste load allocation;

               6.      Derive permit requirements;

               7.      Evaluate toxicity reduction and/or investigate indicator parameters (as
                      needed, for permits containing WET monitoring or limits);

               8.      Issue final permit with monitoring requirements - average monthly and
                      maximum daily average weekly for publicly operated treatment works)
                      limits; and

               9.      Track compliance.

       Sometimes the monitoring requirements include biological assessment of the receiving
       water. The permit can contain a reopener clause to allow the limits and monitoring
       requirements to be adjusted if biological impairment is found in the receiving water.

       The SI guidance is somewhat analogous in function to the Toxicity Reduction Evaluation
       (TRE) and Toxicity Identification Evaluation (TIE) guidance used in Step  7 above
       (USEPA 1988a,b,c, 1991b, 1993a,b). In the permitting process, toxicity is controlled
       through limits for specific chemicals and limits for whole effluent toxicity. When permit
       monitoring shows that an effluent has toxicity above the amount allowed by the permit,
       the discharger is often required to conduct a TRE to determine if a simple solution exists


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        for reducing the toxicity, e.g., housekeeping procedures for cleaning fluids, or pH
        buffering of the effluent. If the solution is not apparent from the TRE, additional TIE
        procedures may be required. TIE procedures guide investigators through additional data
        collection to determine the toxic component(s) of the waste stream.  These procedures
        include both aquatic toxicity methods and chemistry methods.

        When WET or chemical testing show that the effluent is toxic, this does not mean that an
        impairment will necessarily be found in the aquatic biota within the zone of influence of
        the discharge.  Effluent limits include safety factors in their calculations. The waste load
        allocation (Step 4, above) is calculated based on worst-case estimations. For example,
        effluent limits for toxicity or for a toxic chemical are based on low-flow conditions in
        streams and rivers (often the lowest seven-day flow in a ten-year period). Effluent limits
        may be exceeded, a TRE/TIE conducted,  and the problem solved without incurring
        measurable impairment in the receiving water biota. The current trend is to lessen this
        safety buffer by customizing water quality-based permit limits  to local conditions
        through such mechanisms as dynamic modeling of waste load allocation (USEPA 1991a)
        and recalculation of water quality standards or use of the water-effects ratio (USEPA
        1994).

        Conversely, ambient biological assessments may show impairment in the aquatic biota
        below a permitted discharge without a measured permit limit exceedence.  The role of
        the effluent in causing the impairment is not readily apparent in this case.  The effluent
        stream could have been toxic during periods when toxic parameters were not being
        measured; effluent toxicity tests could have been insufficiently sensitive through
        inappropriate selection of test organisms or operator error; or impairment could have
        been caused by stressors other than effluent discharge.  Accurate attribution of
        responsibility can be very critical in NPDES permitting cases, both for fairness and
        success in stressor control. A SI should be conducted to distinguish effects caused by the
        effluent discharge and effects from other  stressors.

        A.5.2 Cooling Tower Intake 316(b) Permitting

        Under section 316(b) of the CWA, any NPDES permitted discharger which intakes
        cooling water must not cause an adverse environmental impact to the waterbody. To
        determine if a cooling water intake structure is  causing adverse environmental impacts to
        the waterbody, the overall health of the waterbody should be known. Where biological
        impairments are found,  stressor identification procedures should help investigators
        identify the different stressors causing the waterbody to be impaired, including the intake
        structure. A high degree of certainty is needed.

        A. 5.3 Dredge and Fill Permitting

        Under Section  401 of the CWA, different types of federal permitting activities (such as
        wetlands  dredge and fill permitting) require a certification that there will be no adverse
        impact on water quality as a result of the activity.  This certification process is the 401
        Water Quality  Certification. Under Section 404 of the  CWA, the discharge of dredge
        and fill materials into a wetland is illegal  unless authorized by  a 404 Permit.  The 404
        Permit must receive a 401 Water Quality  Certification.

        Stressor identification procedures will help investigators identify the different types of
        stress an activity may place on water quality that can then be addressed through
        conditions in the 401  Certification. Stressor identification procedures may help to


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       identify unanticipated stress from a dredge and fill activity on water quality or the
       biological community after the activity is underway.  Stressor identification procedures
       may also help in pre-permitting evaluations of the potential impacts of 404 permitting by
       assessing different potential stressors on the wetland in advance.

       A.6   Compliance and Enforcement

       Since 1972, Section 309 of the Clean Water Act has provided statutory authority for a
       range of enforcement responses for entities or individuals who fail to comply with the
       Act. At the extreme end of this range, actions can result in criminal penalties. EPA has
       national and regional programs in place to investigate and prosecute cases. States and
       Tribes may have their own compliance and enforcement investigation programs.

       A.6.1  Investigations

       When a violation occurs, an investigator must first ascertain what must be done to
       achieve compliance with the Clean Water Act. Under a Section 309 order, the violator
       must come in full compliance with the Clean Water Act; which, under Article 101,
       directs the  restoration and maintenance of the biological integrity of the nation's waters.
       When non-compliance is due to biological impairment or non-attainment of biological
       integrity, the investigator must determine the cause of the impairment before
       implementing a program to restore biological integrity and achieve  compliance. This is a
       direct use of the SI process.

       The degree of environmental harm is a very important factor that investigators and
       judges evaluate when assessing criminal penalties. The SI process  should be helpful in
       determining whether the causes of impairment are consistent with the causes that would
       likely have resulted from the source under investigation. The  SI process can also help to
       determine the likelihood that one Stressor versus another caused the impairment. In
       cases where separation of Stressor mechanisms is fairly clear cut, the SI process can help
       investigators determine the significance of the available evidence in determining whether
       the alleged Stressor caused the noted environmental harm.  However, the SI process is
       limited to evaluating causes. If more than one Stressor or source are involved, allocating
       the relative contribution of each Stressor or source to the environmental harm may
       require additional tools, such as allocation methodologies, that are beyond the scope of
       this document.

       A.6.2  Enforcement Proceedings

       In an enforcement action, the enforcement official seeks for a court to order the
       defendant to cease  the harmful action, or give injunctive relief. Identifying the causes of
       impairment is a crucial step in identifying the actions that would constitute injunctive
       relief.  The SI process should benefit enforcement officials and expert witnesses by
       helping them identify responsible stressors and organize cogent evidence supporting the
       identified causal scenario.  The SI process adds uniformity to the organization and
       analysis of data.

       A special program that is often used to grant injunctive relief is the Supplemental
       Environmental Project (SEP). Under this program, a judge may allow a defendant to
       improve the environment in lieu of paying a portion of a federal fine to the National
       Treasury. The environmental benefit gained through an SEP may not directly alter the
       harm that the defendant caused originally, but is seen as alternate compensation. For


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        example, rather than paying a fine of $ 1 million, a defendant might pay a $600,000 fine
        and build a bike path with a 30-foot riparian buffer zone (for runoff reduction) along the
        impacted creek, or even a neighboring stream.

        When the SI process identifies multiple stressors as the cause of impairment, the
        information can still be valuable to the SEP program because the alternate stressors may
        help direct compensatory action. If, for example, the SI process identifies a stressor
        scenario with two stressors working in conjunction and the defendant is responsible for
        only one of the two stressors, a judge might approve a plan for the defendant to use
        resources to conduct an SEP project that reduces the second stressor, in lieu of a portion
        of the fine.

        Targeting resources is very important to investigation and enforcement efforts. EPA
        often uses 303d lists of impaired waterbodies to target these efforts. The SI process can
        supplement the information in the 303d lists so that stressors may be targeted within
        targeted waterbodies. Targeting may also be important in assessing future legislative
        needs when mechanisms for stressor control are inadequate in national rules and policies,
        and in current state and tribal statutes. Targeting stressors for increased control may
        identify changes to instigate.

        A.7    Risk Assessment

        Risk assessment is a scientific process that includes stressor identification, receptor
        characterization and endpoint selection, exposure assessment, stress-response
        assessment, and risk characterization (USEPA 1998a, Suter 1993).  Risk management is
        a decision-making process that combines human-health and ecological assessment results
        with political, legal, economic, and ethical values to develop and enforce environmental
        standards, criteria, and regulations.  Risk assessment can be performed on a site-specific
        basis, or can be geographically-based (e.g., watershed scale). It can be used to assess
        human health or ecological risks.

        Results of bioassessment studies can be used in watershed ecological risk assessments to
        develop broad-scale empirical models of biological responses to stressors. Such models
        can be combined with exposure information to predict risk from specific stressors and
        anticipate the success of management actions. Accurate stressor identification is  an
        integral part of this process and can help ensure that management actions are properly
        targeted and efficient in producing the desired results.

        A.8    Wetlands Assessments

        Although few states have fully incorporated wetlands into water quality standards or
        biological assessment programs, a growing number have started to develop biological
        assessment methods for wetlands. During the past five years, several state and federal
        agencies have independently started to develop bioassessment methods for wetlands.
        Minnesota, Montana, North Dakota, and Ohio have been pioneers among the states.  The
        Biological Resource Division of the U.S. Geological Service, Wetlands Science Institute
        of the Natural Resources Conservation Service, and EPA have been the leading federal
        agencies.

        The SI process and tools specific to wetlands investigations are very much needed by
        wetlands managers.  In recent 305(b) Reports, states identified sedimentation, nutrient
        enrichment, fill and drainage, pesticides, and flow alterations as the major causes of


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       wetlands degradation. Biological assessment methods will allow resource managers to
       evaluate the condition of wetlands and may provide some indication of the types of
       stressors involved. Once bioassessment methods are completed and incorporated into
       monitoring programs, wetlands may be listed as impaired due to biological impairment.
       SI methods will be needed to identify stressors causing biological impairment so that
       resource managers can better remedy the problems. More information about wetland
       bioassessments is available at the EPA Wetlands Division web page
       (www .epa. go v/o wow/wetlands).

       A.9   Preservation and  Restoration Programs

       Preservation and restoration programs like the National Estuary Program and the
       Superfund Program can also benefit from the SI process.

       A. 9.1 National Estuary Program

       The National Estuary Program (NEP) was established in 1987 by amendments to the
       Clean Water Act to identify, restore, and protect nationally significant estuaries of the
       United States.  Unlike traditional regulatory approaches to environmental protection, the
       NEP targets a broad range of issues and engages local communities in the process.  The
       program focuses not only on improving water quality in an estuary, but also  on
       maintaining the integrity of the whole system, its chemical, physical, and biological
       properties, and its economic, recreational, and aesthetic values.

       The NEP is designed to encourage local communities to take responsibility for managing
       their own estuaries.  Each NEP is made up of representatives from federal, state and
       local government agencies responsible for managing the estuary's resources, as well as
       members of the community — citizens, business leaders, educators, and researchers.
       These stakeholders work together to identify problems in the estuary, develop specific
       actions to address those problems, and create and implement a formal management plan
       to restore and protect the estuary. Twenty-eight estuary programs are currently working
       to safeguard the health of some of our nation's most important coastal waters.

       The SI process should be useful to the NEP, and other preservation programs, by helping
       stakeholders identify sources and causes of impairments.  This information would feed
       into the development of a management plan.

       A. 9.2 Superfund

       The Comprehensive Environmental Response,  Compensation, and Liability Act
       (CERCLA), commonly known as Superfund, was enacted in 1980 (and amended in
       1986) for hazardous waste cleanup.   This law created a tax on the chemical  and
       petroleum industries and provided federal authority to respond to releases  or threatened
       releases of hazardous substances that may endanger public health or the environment.
       The money collected from the taxation went to a trust fund for cleaning up abandoned or
       uncontrolled hazardous waste sites.  CERCLA  also established prohibitions  and
       requirements for closed and abandoned hazardous waste sites; defined liability of
       persons responsible for releases of hazardous waste at these sites; and established
       funding for cleanup when no responsible  party could be identified.

       Since the basis for actions is whether the hazardous substance may endanger public
       health or the environment, identifying the stressor(s) causing environmental  harm is


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        important. For cleanup sites where other stressors (e.g., habitat alteration) are also likely
        causes of impairment, any cleanup and ecosystem recovery plans would need to take into
        account the effects of these  stressors. Allocating the amount of responsibility that may
        be attributed to each stressor is beyond the scope of the SI process, but knowledge of any
        additional stressors that may be causing effects can be valuable in determining expected
        outcomes of recovery activities.
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    APPENDIX B
WORKSHEET MODEL

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                              Stressor Identification Guidance Document
Appendix  B
Worksheet  Model


        The following pages contain a worksheet model that may be used with the SI process.
        This is only an example and may not fit every case without alterations.

        B.1 Instructions for Using the Worksheet Model

        This worksheet follows the SI process outlined in this document. The wortajheet was
        designed to be flexible. At certain points, the user will be asked to stop (^g^g) and
        consider the evidence gathered thus far, in order to determine whether the process is
        complete or requires further analysis.  For detailed guidance, the user will need to refer
        to the sections of the document that are cited at each step.

              1.   To begin, write the name of the investigator and date for reference.

              2.   Fill in the appropriate information in Unit I: List Candidate Causes.  To
                  determine the types of information to include throughout the worksheet,
                  please refer to the cited sections of the document.

              3.   Summarize and document the data and analyses in Unit II, Part A.  Then,
                  you may use either of the following options:

                  *•  Option 1: Analyze the strongest evidence. If you feel that you have
                      enough case specific data to eliminate some causes, analyze this data
                      using Unit II, Part B and proceed to Unit III, Step 1: Eliminate
                      Alternatives. Note: You may also look at other types of evidence that
                      can be used for elimination in Unit II, Parts C and D. To do this, fill in
                      only the blanks in Parts C and D that are designated by the letter E (for
                      elimination) under the heading Associated Causal Characterization
                      Method in Unit III. Review this additional evidence to see if it allows
                      you to eliminate any alternatives.

                  *•  If you still have more than one likely causal scenario that could not be
                      readily eliminated, or if you want to thoroughly review all evidence,
                      proceed to Unit II, Parts C and D. Complete relevant sections of Parts
                      C and D for each candidate cause that you listed in Unit I. Then
                      proceed to Unit IIIand characterize the cause using diagnosis or strength
                      of evidence, as appropriate (described under #4 below).

                  *•  Option 2: List all available evidence in Unit II before going on to Unit
                      III: Characterize Causes.  Using either option, you may still choose to
                      do additional iterations if the available evidence is insufficient.

                  *•  Go to Unit III, Characterize Causes.  For those candidate causes listed
                      in Unit I that were not eliminated while analyzing the evidence listed in
                      Unit II (i.e., those causes not designated asE in Parts C and D under
                      the heading Associated Causal Characterization Method in Unit III),
                      complete Step 1: Eliminate Alternatives and try to further eliminate


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                              Stressor Identification Guidance Document
                      causes. Analyze this evidence carefully; if the evidence is not strong
                      enough to eliminate a candidate, it still may be useful for the strength of
                      evidence analysis. Using the worksheet in Unit III, Step 1, determine:

                   *•  If the primary cause is so dominant that it masks the effects of others,
                      then re-evaluate whether the other stressors should be retained. A cause
                      should not be eliminated if it is potentially masked.  Instead, strength of
                      analysis should be used.

                   >  If only one candidate cause remains, go to Unit IV: Sufficiency of
                      Evidence. Note: You still may want to look at the diagnostic and
                      strength of evidence information to strengthen your case. If so, go to
                      Unit III, Step 2.

                   >  If more than one candidate cause remains, go to Unit III, Step 2 to look
                      for diagnostic evidence.

                   >  If no candidate causes remain, go to Unit V. You will need to do  another
                      iteration with more information.

                   *•  Next, try diagnosis. Look for evidence designated as D under the
                      column labeled Associated Causal Characterization Method in Unit III
                      in Unit II, Part C tables.  Using the worksheet in Unit III, Step 2,
                      determine:

                   >  If only one candidate cause remains, go to Unit IV: Sufficiency of
                      Evidence. Note: You may still want to do a strength of evidence
                      analysis to strengthen your case. If so, go to Unit III, Step  3.

                   >  If more than one candidate cause remains, go to Unit III, Step 3
                      (Strength of Evidence Analysis).

                   >  If no candidate causes remain go to  Unit Fand do  another iteration with
                      more information.

                   >  Many investigators will want to complete the strength of evidence
                      analysis even if elimination or diagnosis have identified the stressor.
                      This part of the SI process helps determine how strong  a case an
                      investigator can make for a particular stressor. Look for evidence
                      designated as S under the column labeled Associated Causal
                      Characterization Method in  Unit III in Unit II Part C, and  also consider
                      the evidence gathered in Part D. Analyze this evidence carefully using
                      the worksheet in Unit III, Steps 3, 4, and 5.

                   *•  Unit III Steps 3,  4, and 5 allow the investigator to compare evidence,
                      side-by-side, for candidate causes. The step used depends on the  type of
                      evidence.  Scores are assigned to each candidate cause to reflect that
                      cause's relevance to each causal consideration. (For more  detailed
                      information on comparing stressors, refer to the sections cited in the
                      worksheets).  Compare scores  among the  candidate causes, and then go
                      to Unit IV, Sufficiency of Evidence.
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*•  List the most likely cause in Unit IV, and determine if the evidence is
   sufficient for the intended use.

+  If yes, your SI is complete,  report results.

+  If no, go to Unit V, Reconsider Impairment.

*•  Reconsider whether the impairment was real and describe the results.

*•  If no, your SI is complete, report results.

+  If yes, go to Unit VI, Collect More Data.

*•  Determine whether all reasonable causes were analyzed.

*•  If no, complete Unit VI, Follow-on 1 to determine whether additional
   scenarios should be analyzed (back to  Unit I), or whether the process
   should be ended and the results reported as inconclusive.

*•  If yes, go to Unit VI, Follow-on 2 to determine whether additional data
   should be collected and another iteration begun (back to  Unit I), or
   whether the process should be ended and the results reported as
   inconclusive.

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                                         Stressor Identification Guidance Document
                                       Stressor Identification Worksheet
      Investigator
Date Completed^
UNIT I. LIST CANDIDATE CAUSES

Describe the impairment.
(see Chapter 2. 2)
Make a map. (Unit I part A)
(see Chapter 2. 2)
Define the Scope of the Investigation.
(see Chapter 2. 3)
List the candidate causes
(see Chapter 2. 4)
Develop a conceptual model for the case. (Unit
I, part B)
(see Chapter 2. 5)
Results / Notes





Candidate Causes
# i.
#2.
#3.
      Go to Unit II,  Analyze Evidence.
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UNIT I. LIST CANDIDATE CAUSES
Part A. Make a map to document geographic features relevant to the analysis.
• Draw a map or insert map of study area.
• Include natural and man-made features such as dams, sources, tributaries, landfills, dredge areas, jetties, sand
bars, waterfalls, wetlands, salt water intrusion, etc. See Chapter 2.2.
• Show location of impairment.



Appendix B: Worksheet Model
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UNIT I. LIST CANDIDATE CAUSES
Part B. Make a conceptual model of the case.
• Draw a conceptual model of the case. See Chapter 2.5.
• Include hypothesized sources, stressors and important environmental processes that lead to the impairment.
• Label candidate causes.



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                                         Stressor Identification Guidance Document
                                                          UNIT II
       Part A. Summarize and document associations between the candidate cause and the effect from the case.
          •  Insert tables, graphs and/or figures of relevant data. See Chapter 3.1.
          •  Insert statistical analyses including correlations, geographic associations, etc. See Chapter 3, textbox 3-2.
          •  You may want to look at other types of evidence that can be used for elimination in Unit II, Part B and C.
       If you feel that you have enough case specific data to eliminate some causes, proceed to Unit III
       Step 1 (Eliminate Alternatives). If not, proceed to Unit II Part B.
Appendix B: Worksheet Model
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                                          Stressor Identification Guidance Document
                                                      UNIT II
Part B. Measurements associated with the causal mechanism (Chapter 3.3).

         Evidence can be used for Elimination (E) Diagnosis (D) or Strength of Evidence (S), as noted below.
     •   Prepare a separate table for each candidate cause.
     •   Use this as a reminder of types of data that could be used in the analysis. Not all questions may be appropriate.

Candidate Cause:
           Example Questions:
  Yes/No/
Question Not
  Relevant
Associated Causal
 Characterization
 Method in Unit
       III*
Supporting Analysis
Are symptoms or other responses specific to
or characteristic of a type of stressor found in
organisms from the impaired community?
                D, S
Are there internal measures of exposure (e.g.,
body burdens, biomarkers) found in
organisms from the impaired community?
                E,D, S
Is an intermediate product of an ecological
process present?
                E, S
Do distributions of stressors and receptors
coincide?
                E, S
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                                         Stressor Identification Guidance Document
           Example Questions:
  Yes/No/
Question Not
  Relevant
Associated Causal
 Characterization
 Method in Unit
      III*
Supporting Analysis
 Have there been expected changes in the
 abundance of predators, prey, or competitors?
 Are there expected effects on other receptors?
 Other
       'E = Elimination; D = Diagnosis; S = Strength of Evidence
       If you feel that your evidence can be used to identify the cause through diagnosis, go to Unit III,
       Step 2. If not, continue with the analysis of evidence in Unit II Parts C and D.
Appendix B: Worksheet Model
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                                           Stressor Identification Guidance Document
                                                       UNIT II
 Part C. Associations of effects mitigation with manipulation of causes (Chapter 3.4).

       •   Evidence can be used for elimination ONLY if it is from the site.
       •   Prepare a separate table for each candidate cause.
       •   Use this as a reminder of the types of data that could be used in the analysis. Not all questions may be appropriate.

 Candidate Cause:
                 Questions:
    Yes/No/
Information not
   available/
  Question not
  Applicable
 Asso-
 ciated
 Causal
Charac-
 teriza-
  tion
Method
 in Unit
  III*
Supporting Analysis
 Does elimination of the source reduce or
 eliminate the effect?
                   S,E
 Does the introduction of previously
 unexposed organisms result in an effect?
 Does the isolation of organisms from one
 cause reveal the effects of others?
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Questions:
Does the testing of chemical fractions of site
media result in toxicity being associated with
a particular fraction (i.e., TIE)?
Other




Yes/No/
Information not
available/
Question not
Applicable




Asso-
ciated
Causal
Charac-
teriza-
tion
Method
in Unit
III*
S











Supporting Analysis




       'E = Elimination; D = Diagnosis;  S = Strength of Evidence
       If you have enough data to determine the cause, proceed to Unit III Step 1 (Elimination) or Step
       2 (Diagnosis) or Step 3 (Strength of Evidence), as appropriate. If not or uncertain, proceed to Unit
       II Part D.
Appendix B: Worksheet Model
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                                                 Stressor Identification Guidance Document
                                                              UNIT II
 Part D.  Using effects data from elsewhere (Chapter 3.2).

       •   Use this table to incorporate data from other situations that support the analysis. Not all questions may be appropriate for a
           given candidate cause.
       •   This evidence is applicable to Strength of Evidence (S) characterization method.
       •   Prepare a separate table for each candidate cause.

 Candidate Cause:
        Type of
       Candidate
         Cause
Characterization
   of Exposure
(Intensity, Time,
   and Space)
   Data
Available?
 Yes (note
location of
 data)/No
Exposure-Response
(E-R) Relationship
E-R Available?
   Yes (note
location of data)
    /No/Not
   Relevant
Would effects
be expected at
     the
environmental
  conditions
  seen in the
   case?
   (Yes/No)
Location of supporting
       analysis
 Chemical
What is the
concentration in
the medium at the
site?
             What is the
             concentration-response
             relationship (seen in the
             lab or the field)?
                        What is the
                        internal
                        concentration in
                        organisms at the
                        site?
                               What is the internal
                               external concentration-
                               response relationship
                               (seen in the lab or the
                               field)?
                        What is the
                        concentration in
                        the biomarker at
                        the site?
                               What is the biomarker-
                               response relationship?
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                                                   Stressor Identification Guidance Document





Type of
Candidate
Cause
Effluent




Contaminated ambient
media



Habitat



Water Withdrawal or
Drought



Thermal Energy






Characterization
of Exposure
(Intensity, Time,
and Space)
What is the
dilution of the
effluent at the
location of the
impairment?
What were the
location and time
of collection and
the results of
analyses?
What are the
structural
attributes of the
habitat?
Are hydrograph
readings and
summary statistics
(e.g., 7Q10)
available?
Are temperature
records available?




Data
Available?
Yes (note
location of
data)/No




























Exposure-Response
(E-R) Relationship
What are the laboratory
test (i.e., WET) results
from 100% effluent or
diluted effluent?

What are the results of
laboratory tests of
ambient media?


Are empirical models
available that relate
habitat characteristics
to biological responses
What are the results of
instream flow models
(e.g., IFIM)?


What are the thermal
tolerances of the
impacted organisms?



E-R Available?
Yes (note
location of data)
/No/Not
Relevant






















Would effects
be expected at
the
environmental
conditions
seen in the
case?
(Yes/No)




























Location of supporting
analysis






















Appendix B: Worksheet Model
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                                                    Stressor Identification Guidance Document
Type of
Candidate
Cause
Siltation
(Suspended)
Siltation
(Bed-load)
Dissolved Oxygen and
Oxygen-Demanding
Contaminants
(e.g., BOD, COD)
Excess Mineral
Nutrients
Characterization
of Exposure
(Intensity, Time,
and Space)
What is the total
suspended solids
(TSS)
concentration?
What is the degree
of embeddedness
and texture of the
silt?
Review the
dissolved oxygen
data (esp.
predawn).
Review the BOD,
COD data from
the source.
What were the
dissolved mineral
nutrient
concentrations?

Data
Available?
Yes (note
location of
data)/No






Exposure-Response
(E-R) Relationship
What is the
concentration-response
relationship (seen in the
lab or field)?
Are empirical models
available to
characterize the
effects?
What is the
concentration-response
relationship (from lab
or other field studies)?
Are there oxygen
demand models that
can be used to predict
effects?
What is the
concentration-response
relationship (from lab
or other field studies)?
Are there
nutrient/eutrophication
models that can be used
to predict effects?
E-R Available?
Yes (note
location of data)
/No/Not
Relevant






Would effects
be expected at
the
environmental
conditions
seen in the
case?
(Yes/No)






Location of supporting
analysis






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                                            Stressor Identification Guidance Document



Type of
Candidate
Cause
Nonindigenous
Species

Pathogen
Other



Characterization
of Exposure
(Intensity, Time,
and Space)
Is a nonindigenous
species present or
abundant?

Is a pathogen
present? If so, is it
abundant?



Data
Available?
Yes (note
location of
data)/No







Exposure-Response
(E-R) Relationship
Are ecological models
available to
characterize the
effects?
Are any symptoms or
diseases observed?



E-R Available?
Yes (note
location of data)
/No/Not
Relevant




Would effects
be expected at
the
environmental
conditions
seen in the
case?
(Yes/No)







Location of supporting
analysis




       Go to Unit III, Characterize Causes.
Appendix B: Worksheet Model
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                                           Stressor Identification Guidance Document
                                      UNIT III. CHARACTERIZE CAUSES
 Step 1.  Eliminate Alternatives (Section 4.1.1) and compare supporting evidence where causes were
 eliminated.
           For each candidate cause indicate Yes, No, No Evidence (NE), or Not Applicable (NA).
           If more than one stressor is necessary for a cause to be sufficient (i.e., temperature and dissolved oxygen), indicate
           response for each stressor.
        •   Use extra pages for more than 3 candidate causes.
        •   Provide comments as necessary.
             Case-Specific
             Consideration
Candidate Cause # 1

(Yes / No / NE / NA)
Candidate Cause # 2

(Yes / No / NE / NA)
Candidate Cause # 3

(Yes / No / NE / NA)
 Temporal Co-occurrence
 Did the effect precede the stressor in time?

 (If the effects preceded a proposed cause
 and effects are not obscured by another
 sufficient cause, then it cannot be the
 primary cause.)
 Temporal Gradient
 Did the effect increase or decrease over
 time in association with an increase or
 decrease in the stressor?

 (If the effect increases or decreases over
 time without a corresponding increase or
 decrease in the stressor, then the stressor
 cannot be the primary cause.)
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                                                Stressor Identification Guidance Document
               Case-Specific
               Consideration
Candidate Cause # 1

(Yes / No / NE / NA)
Candidate Cause # 2

(Yes / No / NE / NA)
Candidate Cause # 3

(Yes / No / NE / NA)
 Spatial Co-occurrence
 Is there an upstream/downstream
 conjunction of candidate cause and effect?

 (If the effect occurs upstream of the source
 or does not occur regularly downstream,
 e.g., is distributed spatially independently
 of a plume, sediment deposition areas, etc.,
 and effects are not obscured by another
 sufficient cause,  then the candidate cannot
 be the primary cause).
 Co-occurrence with Reference Site(s)
 Is there a reference site/impaired site
 conjunction of candidate cause and effect?

 (If the cause occurs at reference sites as
 well as  the impaired sit, it can be
 eliminated.)
 Spatial Gradient
 Does the effect increase or decrease across
 a given region in association with an
 increase or decrease in the stressor?

 (If the effect increases or decreases over a
 given region without a corresponding
 increase or decrease in the stressor, then
 the stressor cannot be the primary cause.)
Appendix B: Worksheet Model
                                                                                B-17

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                                               Stressor Identification Guidance Document
              Case-Specific
              Consideration
Candidate Cause # 1

(Yes / No / NE / NA)
Candidate Cause # 2

(Yes / No / NE / NA)
Candidate Cause # 3

(Yes / No / NE / NA)
 Biological Gradient Is a decrease in the
 magnitude or proportion of an effect seen
 along a decreasing gradient of the stressor?

 (A constant or increasing level of effect
 with decreasing exposure would eliminate
 a cause.)
 Complete Exposure Pathway,
 Question 1:  Is there evidence that the
 stressor did not co-occur with, contact, or
 enter the receptor(s) showing the effect?

 (If there is no route of exposure, or, for
 appropriate stressors, if tissue burdens or
 other measures of exposure were not found
 to occur in affected organisms,  the cause
 may be eliminated.)
 Complete Exposure Pathway,
 Question 2: Is there evidence that a
 necessary intermediate step in the causal
 chain of events did not occur?

 (If a link in a known chain of events can be
 shown to be missing, the cause may be
 eliminated.)
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                                       Stressor Identification Guidance Document
Case-Specific
Consideration
Experiment, Temporality
Did the effects continue when the candidate
cause was removed (allowing for rates of
recovery)?
(If effects continue despite elimination of
the candidate cause, that cause can be
eliminated.)
Other
Candidate Cause # 1
(Yes / No / NE / NA)


Candidate Cause # 2
(Yes / No / NE / NA)


Candidate Cause # 3
(Yes / No / NE / NA)


      After completing Step 1 (above) for each candidate cause listed in Unit I:

            •   If only one candidate cause remains, elimination is definitive. Go to Unit IV.
            •   If more than one candidate cause remains, go back to Unit II,  Part B. If Unit II Part B is
                complete, go to Unit III Step 2.
                If no candidate causes remains, go to Unit V.
Appendix B: Worksheet Model
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                                        Stressor Identification Guidance Document
UNIT III
Step 2. Characterize cause using diagnostic evidence (Section 4.1.2).
If diagnostic evidence was found in Unit n Part D, determine if the evidence is sufficient to define the cause using this
table.
• If evidence is not sufficient to diagnose the cause, it may still be used in the strength of evidence in Unit HI Step 3 .
Use extra pages for more than 3 candidate causes.
Candidate Cause
# 1
#2
#3
Type of Diagnostic
Evidence



Description of Evidence



      After completing Step 2 for all causes remaining after the elimination step (Step 1):

            •   If diagnosis is definitive. Go to Unit IV.
            •   If diagnosis is uncertain, go back to Unit II Parts B, C and D. If Unit II Parts B, C, and D
                are complete, proceed to Unit III Step 3.
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                                            Stressor Identification Guidance Document
                                                       UNIT III
 Step 3. Analyze strength of evidence (Section 4.1.3) for Case-Specific Considerations.

            Use extra pages for more than 3 candidate causes.
      Causal
   Considerations
    and possible
       scores
      Candidate Cause # 1
Evidence and Literature
       Citation
Score
              Candidate Cause # 2
Evidence and Literature
       Citation
Score
                                       Candidate Cause # 3
Evidence and Literature
       Citation
Score
 Co-occurrence
 Compatible (+),
 Uncertain (0),
 Incompatible (—),
 No evidence (NE)

 (The stressor has
 either contacted
 the affected
 organisms, their
 food source, or
 some parameter
 that can affect the
 organisms.)
Appendix B: Worksheet Model
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                                                    Stressor Identification Guidance Document
Causal
Considerations
and possible
scores
Temporality
Compatible (+),
Uncertain (0),
Incompatible ( — ),
No evidence (NE)
(A cause must
always precede its
effects.)
Consistency of
Association
Invariant (++),
In many places and
times (+),
At background
frequencies (-),
No Evidence (NE)
(The repeated
observation of a
similar
relationship of the
effect and
candidate cause in
different places
and times.)
Candidate Cause # 1
Evidence and Literature
Citation







Score







Candidate Cause # 2
Evidence and Literature
Citation







Score







Candidate Cause # 3
Evidence and Literature
Citation







Score







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                                                   Stressor Identification Guidance Document
Causal
Considerations
and possible
scores
Biological
Gradient
Strong and
monotonic (+++),
Weak or other than
monotonic (+),
None (-),
Clear association
but wrong sign
Not applicable
(NA)
(The effect
increases in a
regular manner
with increasing
exposure.)
Candidate Cause # 1
Evidence and Literature
Citation








Score








Candidate Cause # 2
Evidence and Literature
Citation








Score








Candidate Cause # 3
Evidence and Literature
Citation








Score








Appendix B: Worksheet Model
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                                                    Stressor Identification Guidance Document
Causal
Considerations
and possible
scores
Complete
Exposure
Pathway
Evidence for all
steps (++),
Incomplete
evidence (+),
Ambiguous (0),
Some steps missing
or implausible (-),
No evidence (NE)
(The stressor co-
occurs with or
contacts the
receptor(s).)
Candidate Cause # 1
Evidence and Literature
Citation





Score





Candidate Cause # 2
Evidence and Literature
Citation





Score





Candidate Cause # 3
Evidence and Literature
Citation





Score





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                                                   Stressor Identification Guidance Document
Causal
Considerations
and possible
scores
Experiment
Experimental
studies Concordant
Ambiguous (0),
Inconcordant ( 	 )
No evidence (NE)
(Toxicity tests or
other controlled
experimental
studies
demonstrated that
the candidate
cause can induce
the observed
effect.)
Candidate Cause # 1
Evidence and Literature
Citation









Score









Candidate Cause # 2
Evidence and Literature
Citation









Score









Candidate Cause # 3
Evidence and Literature
Citation









Score









Appendix B: Worksheet Model
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                                           Stressor Identification Guidance Document
                                                      UNIT III
 Step 4.  Analyze strength of evidence (Section 4.1.3)  using Evidence from Other Situations or from
 Biological Knowledge.

            Use extra pages for more than 3 candidate causes.
       Causal
  Consideration and
    possible scores
                            Candidate Cause # 1
   Evidence and
Literature Citation
Score
                                         Candidate Cause # 2
Evidence and Literature
       Citation
Score
                                                   Candidate Cause # 3
   Evidence and
Literature Citation
Score
 Plausibility:
 Mechanism
 Evidence of
 Mechanism (++),
 Plausible (+),
 Not Known (0),
 Implausible (-)

 (It is plausible that
 the effect resulted
 from the cause given
 what is known about
 the biology, physics,
 and chemistry of the
 candidate cause, the
 receiving
 environment, and the
 affected organisms.)
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                                                   Stressor Identification Guidance Document
Causal
Consideration and
possible scores
Plausibility:
Stressor- Response
Quantitatively
consistent (+++),
Concordant (+),
Ambiguous (0),
Inconcordant (-), No
evidence (NE)
(Given a known
relationship between
the candidate cause
and the effect, effects
would be expected at
the level of Stressor
seen in the
environment.)
Candidate Cause # 1
Evidence and
Literature Citation
















Score
















Candidate Cause # 2
Evidence and Literature
Citation
















Score
















Candidate Cause # 3
Evidence and
Literature Citation
















Score
















Appendix B: Worksheet Model
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                                                    Stressor Identification Guidance Document
Causal
Consideration and
possible scores
Consistency of
Association
Invariant (+++), In
most places (++),
In some places (+),
At background
frequency (-),
Not applicable (NA)
(The repeated
observation of the
effect and candidate
cause is similar in
different places and
times.)
Candidate Cause # 1
Evidence and
Literature Citation




Score




Candidate Cause # 2
Evidence and Literature
Citation




Score




Candidate Cause # 3
Evidence and
Literature Citation




Score




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                                                   Stressor Identification Guidance Document
Causal
Consideration and
possible scores
Analogy: Positive
Analogous cases:
Many or few but
clear (++),
Few or unclear (+),
None (0)
(The hypothesized
relationship between
cause and effect
similar to other well-
established cases.)
Analogy: Negative
Analogous cases:
Many or few but
clear (- -),
Few or unclear
None (0)
(The hypothesized
relationship between
cause and effect is
dissimilar to other
well-established
cases.)
Candidate Cause # 1
Evidence and
Literature Citation










Score









Candidate Cause # 2
Evidence and Literature
Citation










Score









Candidate Cause # 3
Evidence and
Literature Citation










Score









Appendix B: Worksheet Model
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                                                    Stressor Identification Guidance Document
Causal
Consideration and
possible scores
Specificity of
Cause*
Note: only
applicable if the
cause is plausible or
is consistently
associated with the
effect.
Only possible cause
One of a few (+),
One of many (0), Not
applicable (NA)
(The effect observed
at the site is known
to have only one or a
few known causes.)
Candidate Cause # 1
Evidence and
Literature Citation









Score









Candidate Cause # 2
Evidence and Literature
Citation









Score









Candidate Cause # 3
Evidence and
Literature Citation









Score









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                                                   Stressor Identification Guidance Document
Causal
Consideration and
possible scores
Experiment
Experimental
studies: Concordant
Ambiguous (0),
Inconcordant
No evidence (NE)
(Toxicity tests or
other controlled
experimental studies
demonstrated that
the candidate cause
can induce the
observed effect.)
Candidate Cause # 1
Evidence and
Literature Citation




Score




Candidate Cause # 2
Evidence and Literature
Citation




Score




Candidate Cause # 3
Evidence and
Literature Citation




Score




Appendix B: Worksheet Model
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                                                    Stressor Identification Guidance Document
Causal
Consideration and
possible scores
Predictive
Performance
Prediction:
Confirmed specific
or multiple (+++),
Confirmed general
(++), Ambiguous (0),
Failed (- - -),
No evidence (NE)
(The candidate cause
has any initially
unobserved
properties that were
predicted to occur
and the prediction
was subsequently
confirmed at the
site.)
Candidate Cause # 1
Evidence and
Literature Citation


















Score


















Candidate Cause # 2
Evidence and Literature
Citation


















Score


















Candidate Cause # 3
Evidence and
Literature Citation


















Score


















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                                             Stressor Identification Guidance Document
                                                        UNIT III
 Step 5. Analyze strength of evidence (Section 4.1.3) based on multiple lines of evidence.

        •   Use extra pages for more than 3 candidate causes.
       Causal
  Consideration and
    possible scores
     Candidate Cause # 1
   Evidence and
Literature Citation
Score
                  Candidate Cause # 2
Evidence and Literature
       Citation
Score
                                        Candidate Cause # 3
   Evidence and
Literature Citation
Score
 Consistency of
 Evidence
 All consistent (+++),
 Most consistent (+),
 Multiple
 inconsistencies
 (...)

 (The hypothesized
 relationship between
 the cause and effect
 is consistent across
 all available
 evidence.)
Appendix B: Worksheet Model
                                                                                              B-33

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                                       Stressor Identification Guidance Document
Causal
Consideration and
possible scores
Coherence of
Evidence
Evidence:
Inconsistency
explained by a
credible mechanism
No known
explanation (0)
No entry if all
consistent
(A mechanistic
conceptual model
explains any
apparent
inconsistencies
among the lines of
evidence.)
Candidate Cause # 1
Evidence and
Literature Citation










Score










Candidate Cause # 2
Evidence and Literature
Citation










Score










Candidate Cause # 3
Evidence and
Literature Citation










Score










      Compare evidence among the candidate causes, then go to Unit IV to summarize your findings.
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                                      Stressor Identification Guidance Document
                          IV. SUFFICIENCY OF EVIDENCE (Chapter 4.2)
 Most Likely Candidate Cause:
 Is Evidence Sufficient for the Management Purpose?

          Q YES  SI COMPLETE, REPORT RESULTS
D NO GO TO UNIT V, RECONSIDER
      IMPAIRMENT
Summary of Characterization
Candidate Cause
# 1.
#2.
#3.
Cause



Reasoning & Confidence




Appendix B: Worksheet Model
                                          B-35

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                                         Stressor Identification Guidance Document
                                   V. RECONSIDER IMPAIRMENT
                                      Does Biological Impairment Really Exist?
                                                   (Section 5.1)
Reconsider the impairment by auditing the quality of the methods used to generate and manage the data, by using better
analysis tools, and by eliminating any suspicious data or analyses.
Describe Reconsideration:
Were effects real?

          D NO    SI COMPLETE, REPORT RESULTS.

          D YES   GO TO UNIT VI, COLLECT MORE INFORMATION.
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                                        Stressor Identification Guidance Document
                          VI. COLLECT MORE INFORMATION (Section 52)
Were all reasonable causes analyzed?

          D NO    Go to Follow-on 1.

          D YES   Go to Follow-on 2.

Follow-on 1:        Make sure that all reasonable causes were analyzed.

      •   If additional scenarios are indicated, repeat process, beginning at Unit 1.

      •   If a good faith effort was implemented with reasonable time and resource expenditures, consult management goals
          and determine if the process should be ended with inconclusive results.

          SI COMPLETED, REPORT RESULTS AS INCONCLUSIVE.

Follow-on 2:        Look at the supporting evidence in Unit II, Analyze Evidence.

      •   Prioritize information needs for likely candidate causes, collect new information and repeat the process, beginning
          at Unit 1.

      •   If a good faith effort was implemented with reasonable time and resource expenditures, consult management goals
          and determine if the process should be ended with inconclusive results.

          SI COMPLETED, REPORT RESULTS AS INCONCLUSIVE.
Appendix B: Worksheet Model                                                                                      B-37

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    APPENDIX C
GLOSSARY OF TERMS

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                             Stressor Identification Guidance Document
Appendix C
 Glossary  of Terms
       Ambient monitoring:
       Ambient waters:

       Analogy:
       Bioassessment
       (biological assessment):
All forms of monitoring conducted beyond the
immediate influence of a discharge pipe or injection
well and may include sampling of sediments and living
resources.

water bodies that are in the environment.

a comparison of two things, based on their similarity in
one or more respects. In SI, the criterion of an analogy
refers specifically to similar causes.
evaluation of the condition of an ecosystem that uses
biological surveys and other direct measurements of the
resident biota.
       Biocriteria
       (biological criteria):
       Biogenic:
       Biological gradient:
       Biomarker:
       Body burden:
       Candidate cause:
       Categorical regression:
numerical values or narrative expressions that describe
the reference biological condition of aquatic
communities inhabiting waters of a given designated
aquatic life use. Biocriteria are benchmarks for
evaluation and management of water resources

produced by biological processes. For example, organic
acids produced by decomposition of plant litter are
biogenic acids.

a regular increase or decrease in a measured biological
attribute with respect to space (e.g., below an outfall),
time (e.g., since a flood), or an environmental property
(e.g., temperature).

contaminant-induced physiological, biochemical, or
histological response of an organism.

the concentration of a contaminant in a whole organism
or a specified organ or tissue.

a hypothesized cause of an environmental impairment
which is sufficiently credible to be analyzed.

regression analysis in which the dependent variable is
defined  by a categorical scale rather than as a count or
continuous variable.
Appendix C: Glossary of Terms
                                                      C-l

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                               Stressor Identification Guidance Document
        Causal analysis:
        Causal mechanism:

        Causal relationship:

        Causal association:



        Causal evidence:



        Causal inference:



        Causal characterization:
        Causal considerations:
        Cause:
        Co-occurren ce:
        Coherency of evidence:
a process in which data and other information are
organized and evaluated using quantitative and logical
techniques to determine the likely cause of an observed
condition.

the process by which a cause induces an effect.

the relationship between a cause and its effect.

a correlation or other association between measures or
observations of two entities or processes which occurs
because of an underlying causal relationship.

the results of an analysis of data to reveal an association
between the environmental condition and a candidate
cause.

the component of a causal analysis that is specifically
concerned with the interpretation of the evidence to
determine the most likely cause.

a step in the stressor identification process in which the
proposed cause is described, the evidence for its causal
relationship to the  impairment is summarized, and
uncertainties are presented.

logical categories of evidence that are consistently
applied to support or refute a hypothesized cause. A
causal consideration (e.g., biological gradient) is
evaluated using causal evidence (e.g., a regression of
benthic invertebrate diversity against sediment PCB
concentration).

1. that which produces an effect (a general definition).
2. a stressor or set of stressors that occur at an intensity,
duration and frequency of exposure that results in a
change in the ecological condition (a Si-specific
definition).

the spatial co-location of the candidate cause and effect.

the final  consideration in a strength of evidence analysis.
If the results of all of the causal considerations in a
strength of evidence analysis are not consistent, they
may still be coherent,  if a mechanistic conceptual or
mathematical model explains the apparent
inconsistencies.
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                              Stressor Identification Guidance Document
        Complete exposure
       pathway:
        Concentration-response
        model:
        Consideration:
        Consistency of association:
        Consistency of evidence:
       Diagnostic analysis:
       Diagnostic protocol:


       Dilution ratio:

       Ecoepidemiology:


       Endpoint species:

       Eutroph ication:



       Experiment:



       Expert judgement:


       Exposure:
the physical course a stressor takes from the source to
the receptors (e.g., organisms or community) of interest.
(Evidence for a complete exposure pathway is case-
specific and may include measurements such as body
burdens of chemicals, presence of parasites or
pathogens, or biomarkers of exposure.)
a quantitative (usually statistical) model of the
relationship between the concentration of a chemical to
which a population or community of organisms is
exposed and the frequency or magnitude of a biological
response.

see Causal consideration.

the degree to which an effect and candidate cause have
been determined to co-occur in different places or times.

the degree to which the causal considerations in a
strength of evidence analysis are in agreement
concerning a candidate cause.

a type of causal analysis in which effects that are
characteristic of a particular cause are used to determine
whether that candidate cause may be responsible for an
impairment.

a standard procedure for performing a diagnostic
analysis.

the ratio of the stream flow to the wastewater flow

the study of the nature and causes of effects on
ecological systems.

a species that is the object of an assessment or test.

enrichment of a water body with nutrients, resulting in
high levels of primary production, often leading to
depletion of dissolved oxygen.

the manipulation of a candidate cause by eliminating a
source or altering exposure  so as to evaluate its
relationship to an effect.

a method of causal inference based on the knowledge
and skill of the assessors rather than a formal method.

the co-occurrence or contact of a stressor and the
resource that becomes impaired.
Appendix C:  Glossary of Terms
                                                        C-3

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                              Stressor Identification Guidance Document
       Exposure-response
       relationships:
       Impairment:


       Indirect causation:



       Indirect effects:



       Inferential logic:


       Initial response:


       Intermediate processes:
       Internal exposure:


       Logic of abduction:


       Mechanism:

       Necropsy:



       Negative evidence:

       Opportun istic:


       Pathogens:
a qualitative or quantitative (usually statistical) model of
the relationship between an exposure metric (e.g., the
concentration of a chemical or the abundance or an
exotic species) to which a population or community of
organisms is exposed and the frequency or magnitude of
a biological response.

a detrimental effect on the biological integrity of a water
body that prevents attainment of the designated use.

the induction of effects through a series of cause-effect
relationships, so that the impaired resource may not
even be exposed to the initial cause.

changes in a resource that are due to a series of cause-
effect relationships rather than to direct exposure to a
contaminant or other stressor.

a process for reasoning from the evidence to a necessary
and specific conclusion.

the response of an organism, population or community
to direct exposure to  a stressor.

processes that  occur between the occurrence of a
stressor in an ecosystem and the induction of the effect
of concern. For example, the reduction in algal
abundance is an intermediate process between the
introduction of a non-native filter feeder and the
reduction in abundance of native planktivorous species.

exposure of an organism to bioaccumulated
contaminants.

inference from data to the hypothesis that best accounts
for the data.

the process by which a system is changed.

a post-mortem examination or inspection intended to
determine the cause of death or the nature of
pathological changes.

evidence that tends to refute  a candidate cause.

having the ability to exploit newly available habitats or
resources.

organisms that are capable of inducing a disease in a
susceptible host.
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                              Stressor Identification Guidance Document
       Plausibility:


       Positive evidence:

       Predictive performance:
       Principal cause:


       Pseudoreplication:
       Publicly Owned Treatment
        Works (POTW):
       Receptors:


       Replicate:



       Source:
        Spatial gradient:


        Specificity:

        Specificity of cause:


        Specificity of effect:
the degree to which a cause and effect relationship
would be expected, given known facts.

evidence that tends to support a candidate cause.

the degree to which a candidate cause has led to
predictions concerning conditions in the receiving
system which have been subsequently  confirmed by
observation or measurement.

the cause that makes the largest contribution to the
effect.

the treatment of multiple samples that are subject to the
same treatment as replicates for statistical purposes.  For
example, multiple samples of benthic invertebrates taken
in a channelized stream are pseudo- replicates because
they are not independent. True replicates would be
taken from different channelized streams.
a water treatment facility, as defined by Section 212 of
the Clean Water Act, that is used in the storage,
treatment, recycling, and reclamation of municipal
sewage or industrial wastes of a liquid nature and is
owned by a municipality or other governmental entity.
It usually refers to sewage treatment plants.

organisms, populations, or ecosystems that are exposed
to a contaminant or other stressor.

(a) one of a set of independent systems which have been
randomly assigned a treatment; or (b) to generate a set
of such systems.

an origination point, area, or entity that releases or emits
a stressor.  A source can alter the normal intensity,
frequency, or duration of a natural attribute, whereby the
attribute then becomes a stressor.

a graded change in the magnitude of some quantity or
dimension measured on a transect

the quality of being specific rather than general.

only one candidate cause or a few similar causes can
induce the observed effect.

one type of effect is characteristically induced by a
candidate cause. The absence of that effect  is evidence
for eliminating the  candidate cause.
Appendix C:  Glossary of Terms
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                              Stressor Identification Guidance Document
       Strength-of-evidence
       analysis:
       Strength of association:
       Stressor:
       Supplemental
       Environmental Project
        (SEP):
       Symptomatology:



       Temporal relationship:


       Temporal gradient:
       Total Maximum Daily
       Load (TMDL):
       Toxicity Reduction
       Evaluation (TRE):
       Toxicity Identification
       and Evaluation (TIE):
an inferential process that uses all relevant evidence in a
systematic process to determine which candidate cause
is most likely to have induced the effect of concern.

the size of the effect produced by an increment in the
candidate cause. A candidate cause that is associated
with a large change in the level of effect is more likely
to be the  true cause than one that is weakly associated.

any physical, chemical, or biological entity that can
induce an adverse response.
a special program that is often used to grant injunctive
relief.

a set of signs of the action of a causal agent on
organisms. A set of symptoms with a common cause
constitutes a symptomatology.

the relationship between the time of occurrence of a
candidate  cause and of the effect of concern.

a graded change in the magnitude of some quantity or
dimension measured over time.
the total allowable pollutant load to a receiving water
such that any additional loading will produce a violation
of water-quality standards.
a site-specific study conducted in a stepwise process
designed to identify the causative agent(s) of effluent
toxicity, isolate the sources of toxicity, evaluate the
effectiveness of toxicity control options, and then
confirm the reduction in effluent toxicity.
a process that identifies the toxic components of an
effluent or ambient medium by a process of chemically
manipulating the effluent or medium and testing the
resulting material.
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   APPENDIX D
LITERATURE CITED

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                             Stressor Identification Guidance Document
Appendix D
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                              Stressor Identification Guidance Document
                                            Index

       A
       Algal growth, 6-6-6-8, 6-10, 6-12, 7-11
       Ammonia concentrations, 7-2-7-3, 7-11, 7-14, 7-18-7-22, 7-25-7-31, 7-39-7-48, 7-63
       Analogy
               description, 4-12
               Little Scioto River case study, 7-35, 7-38, 7-41, 7-45
               Presumpscot River case study, 6-15
       Androscoggin River case study, 6-11-6-13
       Aquatic life standards, 6-1, 6-3, 6-5, 6-13
       Aquatic life use
               defined, 1-1
       Arkansas River case study, 4-11

       B
       Beneficial use designation
               defined, 1-1
       Benthic macroinvertebrates
               effects of heavy metal exposure, 4-11
               Little Scioto River case study, 7-1-7-8, 7-24
               Presumpscot River case study, 6-1-6-18
       Biocriteria
               defined, 1-1
       Biological gradient
               Arkansas River case study, 4-11
               described, 4-10
               Little Scioto River case study, 7-32, 7-36, 7-39, 7-43
               Presumpscot River case study, 6-14
       Biological integrity
               describing impairments, 2-1-2-3
               overview of Stressor Identification, 1-3-1-5
               role of Stressor Identification process in water management programs, 1-6-1-9
               Stressor Identification process, ES-1
               using results of Stressor Identification, 1-5-1-6
               water quality management, ES-2
       Biological oxygen demand
               Little Scioto River case study, 7-11, 7-14, 7-18, 7-20, 7-23-7-28, 7-39-7-49,
               7-63
               Presumpscot River case study, 6-6-6-7, 6-9, 6-12
       BOD. See Biological oxygen demand

       C
       Candidate causes
               analyzing evidence, 3-1-3-11
               categories of relationships, 3-1-3-2
               characterizing causes, 4-1^-18
               conceptual models, 2-5-2-7
               describing the impairment, 2-1-2-3
               key terms, 2-1
               listing, 2-4-2-5
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                              Stressor Identification Guidance Document
               overview of Stressor Identification, 1-3-1-5
               principal causes, 2-4
               scope of the investigation, 2-3-2-4
               unlikely stressors, 2-5
               using existing lists of stressors, 2-4
       Case studies
               Androscoggin River, 6-11-6-13
               Arkansas River, 4-11
               DDT, 5-2
               Lake Washington, 4-13
               Little Scioto River, 7-1-7-65
               Presumpscot River, 6-1-6-18
       Causal evidence
               associations between measurements of candidate causes and effects, 3-2-3-6,
               4-5^-6
               associations of effects with mitigation or manipulation of causes, 3-10-3-11, 4-6
               causal considerations, 4-9-4-14
               confidence evaluation, 4-17^-18
               diagnostic analysis, 4-7^-8
               eliminating alternatives, 4-3^-7
               identifying probable cause, 4-17^4-18
               matching evidence with causal considerations, 4-14
               measurements associated with the causal mechanism, 3-9-3-10, 4-6
               methods for characterization, 4-1^-17
               strength of evidence analysis, 4-8^4-17
               using effects data from elsewhere,  3-6-3-9
               weighing causal considerations, 4-14-4-11
       Cause
               defined, 2-1
       CERCLA. See Comprehensive Environmental Response, Compensation, and Liability
       Act
       Channelization, 7-6, 7-11, 7-13, 7-24, 7-47, 7-48
       Chemical contaminants. See also Toxic compounds
               Little Scioto River Case Study, 7-11, 7-14-7-22, 7-24-7-25, 7-27, 7-29-7-30, 7-
               32-7-48
               Koch's postulates, 4-9
       Chemical oxygen demand, 7-11
       Chironomus riparius, 7-29
       Chlorophyll a, 6-2, 6-10
       Class C aquatic life standards, 6-1, 6-3, 6-5, 6-13
       Clean Water Act, 1-6, 1-9, A-l-A-11, ES-1
               319 program, 1-7, A-5-A-6
               404 Permits, 1-8, A-7-A-8
               section 303(d), 1-6, A-2-A-4
               section 305(b), 1-6, A-1
               section 309, A-8
               section 316(b), 1-7, A-7
               section 319, A-5
               section 401, 1-7, A-7-A-8
               section 402, 1-7, A-6
               section 502, A-3
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       Co-occurrence
               Arkansas River case study, 4-11
               DDT case study, 5-2
               description, 4-10
               Little Scioto River case study, 7-32, 7-36, 7-39, 7-43
               Presumpscot River case study, 6-14
       COD. See Chemical oxygen demand
       Coherence of evidence
               description, 4-14
               Little Scioto River case study, 7-35, 7-38, 7-42, 7-46
               Presumpscot River case study, 6-16
       Colorado
               Arkansas River case study, 4-11
       Combined sewer outfalls, 7-11
       Community data plot,  3-4
       Complete exposure pathway
               DDT case study, 5-2
               description, 4-1 CM-11
               Little Scioto River case study, 7-32, 7-36, 7-39, 7-44
               Presumpscot River case study, 6-15
       Comprehensive Environmental Response, Compensation, and Liability Act, 1-9, 7-10, A-
       10-A-ll
       Comprehensive State Water Quality Assessment, 1-2
       Conceptual models, 2-5-2-7, 5-2
       Consistency of association
               description, 4-11
               Lake Washington case study, 4-13
               Little Scioto River case study, 7-32-7-39, 7-41, 7-43, 7-45
               Presumpscot River case study, 6-14-6-15
       Consistency of evidence
               description, 4-14
               Little Scioto River case study, 7-35, 7-38, 7-42, 7-46
               Presumpscot River case study, 6-16
       Cooling tower intake permitting, A-7
       Cooling water intake program, 1-7
       Cricotopus sp., 7-9-7-10, 7-19-7-20, 7-30
       CSOs. See Combined sewer outfalls
       CWA. See Clean Water Act

       D
       Data Quality Assessment, 3-2
       Data quality issues,  1-2
       Data Quality Objectives process, 3-2
       DDT case study, 5-2
       Deformities, fin erosion, lesions, tumors and anomalies, 7-1-7-4, 7-8-7-10, 7-20-7-23,
       7-27-7-30, 7-33-7-49
       DELTA. See Deformities, fin erosion, lesions, tumors and anomalies
       Department of Natural Resources (Maryland)
               website, 2-4
       Dissolved oxygen
               Little Scioto River case study, 7-3,  7-11, 7-14, 7-20, 7-23-7-31, 7-39-7-49, 7-63
               Presumpscot River case study, 6-6-6-10, 6-13, 6-17


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                              Stressor Identification Guidance Document
       DNR. See Department of Natural Resources
       DO. See Dissolved oxygen
       DQA. See Data Quality Assessment
       DQO. See Data Quality Objectives process
       Dredge and fill permitting, A-7-A-8

       E
       Eastern Corn Belt Plains, 7-30
       Ecological Risk Assessment, 1-2
       Edmondson, W.T., 4-13
       Effect
               defined, 2-1
       Elimination of alternatives, 4-3-4-7, 6-8-6-11, 7-26-7-27
       EMAP. See Environmental Monitoring and Assessment Program
       Enforcement actions
               EPA responsibilities, A-8-A-9
               role of Stressor Identification process, 1-8
       Environmental Monitoring and Assessment Program, 2-4
       EPA. See U.S. Environmental Protection Agency
       Ephemeroptera-Plecoptera-Trichoptera, 6-1, 6-5-6-6, 7-9
       EPT. See Ephemeroptera-Plecoptera-Trichoptera
       EROD. See Ethoxy resorufin[O]deethylase
       Ethoxy resorufin[O]deethylase, 7-5, 7-24
       Eutrophication, 6-6
       Experiments
               Arkansas River case study, 4-11
               DDT case study, 5-2
               description, 4-12
               Lake Washington case study, 4-13
               Little Scioto River case study, 7-35-7-36, 7-38-7-39, 7-41, 7-44-7-45
               Presumpscot River case study, 6-14-6-15
       Expert judgment, 4-1
       Exposure
               defined, 2-1

       F
       False positives, 5-1
       Federal Advisory Committee Act, A-4
       Field experiments
               types of, 3-10
       Fill permitting, A-7-A-8
       Fish kills
               diagnostic protocols, 4-7
       Floe. See TSS with floe

       G
       Glossary of terms, C-l-C-6

       H
       Habitat degradation
               Little Scioto River case study, 7-11, 7-13, 7-21, 7-24-7-28, 7-32-7-36
               Presumpscot River case study, 6-8, 6-11, 6-12, 6-14-6-17


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       Heavy metals. See Metals
       Hyalella azteca, 7-29, 7-33, 7-64-7-65

       I
       IBI. See Index of Biotic Integrity
       ICI. See Invertebrate Community Index
       Impoundment, 6-7-6-8, 6-10-6-12, 6-14-6-17
       Index of Biotic Integrity, 2-2, 7-1, 7-4-7-9, 7-13, 7-19-7-20, 7-47
       Invertebrate Community Index, 2-2, 7-1, 7-4-7-9, 7-19-7-20, 7-47

       K
       Kansas Biotic Index, 3-11
       Kansas Department of Health and Environment
              water quality documentation, 3-11
       KBI. See Kansas Biotic Index
       KDHE. See Kansas Department of Health and Environment
       Koch's postulates, 4-9

       L
       Lake Washington case study, 4-13
       Landfills, 7-6, 7-10
       Little Scioto River case study
       analyzing evidence for diagnosis, 7-28
              characterizing causes, 7-26-7-28
              comparing strength of evidence, 7-28-7-31
              conceptual model of candidate causes for stressor identification, 7-12
              discussion, 7-48-7-49
              eliminating alternatives, 7-13-7-26
              evidence of impairment, 7-5-7-10
              executive summary, 7-1-7-4
              fish metrics, 7-54
              identifying probable causes, 7-47-7-48
              introduction, 7-4-7-5
              list of candidate causes, 7-10-7-13
              macroinvertebrate metrics, 7-55
              map, 7-6
              metals concentrations, 7-61-7-62, 7-65
              PAH concentrations, 7-64
              QHEI metrics, 7-56
              sediment organic compounds concentrations, 7-57-7-60
              strength of evidence analysis, 7-28-7-46
              water chemistry parameters, 7-63

       M
       Macroinvertebrate biotic index, 3-11
       Macroinvertebrates. See Benthic macroinvertebrates
       Maine
              Presumpscot River case study, 6-1-6-18
              Maine Department of Environmental Protection, 6-3, 6-18
       Maps
              describing impairments, 2-2-2-3
              Little Scioto River case study, 7-6


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                              Stressor Identification Guidance Document
               Presumpscot River case study, 6-4
       Maryland
               Department of Natural Resources website, 2-4
       Mayflies, 7-9-7-10
       MBI. See Macroinvertebrate biotic index
       MDEP. See Maine Department of Environmental Protection
       Mechanisms
               description, 4-12
               Little Scioto River case study, 7-33, 7-37, 7-40, 7-44
               Presumpscot River case study, 6-15
       Mechanistic conceptual models, 3-9-3-10
       Metals
               Arkansas River case study, 4-11
               Little Scioto River case study, 7-2-7-3, 7-11, 7-14, 7-17, 7-19, 7-22, 7-24-7-38,
               7-61-7-62, 7-65
               Presumpscot River case study, 6-13
       Midges. See Tanytarsini midges
       MIWB. See Modified Index of Well-being
       Modified Index of Well-being, 7-8
       Modified Warmwater Habitat, 7-5, 7-7
       Monte Carlo simulation, 4-17
       MWH. See Modified Warmwater Habitat

       N
       National Estuary Program, 1-9, A-10
       National Pollutant Discharge Elimination System permit program
               monitoring requirements, A-6-A-7
               role of Stressor Identification process, 1-7
       National Water Quality Inventory Report to Congress, A-l
       NEP. See National Estuary Program
       Nitrates, 7-14, 7-18, 7-20, 7-27, 7-30-7-31, 7-63
       Nitrification, 3-11
       Nitrites, 7-14, 7-18,  7-20, 7-27, 7-30-7-31,  7-63
       Nitrogen, 7-2
       Non-point source pollution
               management under section 319 of the CWA, A-5-A-6
               role of Stressor Identification process in control program, 1-7
       NPDES. See National Pollutant Discharge Elimination System permit program
       NFS. See Non-point source pollution
       Nutrients
               enrichment, 7-13, 7-23, 7-26-7-28,  7-32-7-36, 7-39-7-49
               excess, 6-6-6-7, 6-10, 6-12
               loading, 3-11

       O
       OEPA. See Ohio Environmental Protection Agency
       Ohio
               Little Scioto River case study, 7-1-7-65
               Ohio Environmental Protection Agency, 7-1, 7-5, 7-10
       Organic enrichment, 3-11,7-11
       Ortho-phosphate, 6-10
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        P
        PAH. See Polycyclic aromatic hydrocarbons
        Pathogens
               Koch's postulates, 4-9
        PEL. See Probable effect levels
        Permitting programs, A-6-A-8
        pH levels, 7-30
        Phosphorous, 7-2-7-3, 7-14, 7-18
        Phosphorus, total
               Little Scioto River case study, 7-20, 7-27, 7-30-7-31, 7-63
               Presumpscot River case study, 6-1-6-18
        Plausibility
               Arkansas River case study, 4-11
               DDT case study, 5-2
               description, 4-12
               Little Scioto River case study, 7-33, 7-37, 7-40, 7-44-7-45
               Presumpscot River case study, 6-15
        Pollutants
               defined, A-3
        Pollution
               defined, A-3
        Pollution control
               measuring effectiveness, 1-9
        Polycyclic aromatic hydrocarbons, 7-1-7-4, 7-10-7-30, 7-36-7-38, 7-47-7-49, 7-64
        Predictive performance
               description, 4-13^-14
               Little Scioto River case study, 7-35, 7-38, 7-41, 7-45
               Presumpscot River case study, 6-16
        Preservation programs, 1-9, A-10
        Presumpscot River case study
               background information, 6-3-6-5
               biological indicators of non-attainment, 6-6
               comparison with Androscoggin River, 6-11-6-13
               conceptual model of stressor impact, 6-7
               eliminating candidate causes, 6-8-6-12
               executive summary, 6-1-6-3
               identifying probable cause, 6-17
               list of candidate causes, 6-5-6-8
               map, 6-4
               significance of results, 6-18
               strength of evidence analysis, 6-11-6-16
               using results, 6-18
        Probable effect levels,  7-29-7-30, 7-33, 7-64-7-65
        Pseudoreplication, 3-7
        Pulp and paper mill discharge, 6-1-6-18

        Q
        QHEI. See Qualitative Habitat Evaluation Index
        Qualitative Habitat Evaluation Index, 7-1, 7-4-7-5, 7-13-7-14, 7-20, 7-24, 7-27, 7-56
        Quality System website, 3-2
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                              Stressor Identification Guidance Document
        R
        R-EMAP. See Regional Environmental Monitoring and Assessment Program
        Regional Environmental Monitoring and Assessment Program, 4-11
        Restoration programs, 1-9, A-10-A-11
        Risk assessment, 1-8, A-9

        S
        SECs. See Sediment effect concentrations
        Sediment effect concentrations, 7-29
        Sediment organic compounds, 7-57-7-60
        Sedimentation, 6-7-6-8, 6-10, 6-12, 6-14-6-17
        SEP. See Supplemental Environmental Project
        SI. See Stressor Identification
        Source
               defined, 2-1
        Spatial co-location associations, 3-4
        Spatial co-occurrence, 4-11, 6-14
        Spatial gradient associations, 3-4
        Spearman rank correlations, 7-14, 7-19-7-20
        Specificity of cause
               description, 4-13
               Little Scioto River case study, 7-35, 7-37, 7-41, 7-45
               Presumpscot River case study, 6-15
        Statistical techniques
               analyzing observational data in Stressor Identification, 3-7
               evaluating confidence in causal identification, 4-17
        Stressor Identification
               analyzing evidence, 3-1-3-11
               applications of the process, ES-2-ES-3
               associations between measures of exposure and measures of effects, 3-8
               characterizing causes, 4-1^-18
               data quality issues, 1-2
               document overview, ES-3-ES-4
               EPA objectives, 1-1
               flow of information from data acquisition to analysis phase, 3-3
               function and description, ES-1
               intended audience, ES-2
               iteration options, 5-1-5-3
               listing candidate causes, 2-1-2-7
               management context, 1-4
               mechanistic association with site data, 3-9-3-10
               overview of process, 1-3-1-5
               process iterations, 1-5
               role in water management programs, 1-6-1-9
               scope of guidance,  1-2
               TMDL program and, A-4
               using results, 1-5-1-6
               using statistical techniques for analyzing observational data, 3-7
               water management programs, A-l-A-11
               worksheet model, B-l-B-37
        Stressor-responses
               Arkansas River case study, 4-11


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               DDT case study, 5-2
               description, 4-12
               Little Scioto River case study, 7-33, 7-37, 7-40, 7-45
               Presumpscot River case study, 6-15
       Superfund, 1-9, 7-10, A-10-A-11
       Supplemental Environmental Project, A-8-A-9

       T
       Tanytarsini midges, 7-1, 7-3-7-4,  7-8-7-10, 7-19-7-23, 7-27, 7-43-7-48
       TEL. See Threshold effect levels
       Temporal gradient associations, 3-4
       Temporal relationships, 3-4
       Temporality
               description, 4-10
               Little Scioto River case study, 7-32, 7-36, 7-39, 7-43
               Presumpscot River case study, 6-14
       Threshold effect levels, 7-29-7-30, 7-33, 7-64-7-65
       TIE. See Toxicity Identification and Evaluation program
       TMDL. See Total Maximum Daily Load
       Total Maximum Daily Load
               Clear Water Act requirements, A-2-A-3
               EPA actions, A-4
               Presumpscot River case study, 6-2-6-3, 6-18
               Stressor Identification process, 1-6, ES-2
       Total phosphorus
               Presumpscot River case study, 6-1-6-18
       Toxic compounds. See also Chemical contaminants
               Little Scioto River Case Study, 7-11, 7-14-7-22, 7-24-7-25, 7-27, 7-29-7-30, 7-
               32-7-48
               Presumpscot River case study, 6-5-6-8, 6-12, 6-14-6-17
       Toxicity data plot, 3-4
       Toxicity Identification and Evaluation program, 4-5, A-6-A-7
       Toxicity Reduction Evaluation, A-6-A-7
       TP. See Total phosphorus
       TRE. See Toxicity Reduction Evaluation
       TSS with floe
               Presumpscot River case study, 6-1-6-18
       Type I error, 5-1

       U
       U.S. Environmental Protection Agency
               compliance and enforcement of CWA, A-8-A-9
               Data Quality Objectives process, 3-2
               Environmental Monitoring and Assessment Program, 2-4
               Quality System website, 3-2
               TMDL program implementation, A-4
               Wetlands Division website, A-10

       W
       Warmwater Habitat, 7-5-7-7
       Washington
               Lake Washington case study, 4-13


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                              Stressor Identification Guidance Document
       Waste water treatment plants, 7-6, 7-10-7-11, 7-28
       Water chemistry parameters, 7-63
       Water hardness, 7-18, 7-63
       Water management programs, A-l-A-11
       Water quality
               overview of Stressor Identification, 1-3-1-5
               ratings, A-l-A-2
               Stressor Identification process, 1-6-1-9, ES-2-ES-3
       Water Quality Act Amendments, A-5
       Water Quality Certification
               dredge and fill permitting, A-7
               role of Stressor Identification process, 1-7
       Water Quality Classification, 6-18
       Watershed management programs
               role of Stressor Identification process, 1-6
               state and local programs, A-4-A-5
       Wetlands assessments
               methods, A-9-A-10
               role of Stressor Identification process, 1-8
       Wetlands permitting
               role of Stressor Identification process, 1-8
       Worksheet model, B-l-B-37
       WWH. See Warmwater Habitat
       WWTP. See Waste water treatment plants
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