HUDSON RIVER PCBs REASSESSMENT RI/FS
        RESPONSIVENESS SUMMARY FOR
VOLUME 2F-A HUMAN HEALTH RISK ASSESSMENT
          FOR THE MID-HUDSON RIVER
                AUGUST 2000
                      For

           U.S. Environmental Protection Agency
                    Region 2
                      and
             U.S. Army Corps of Engineers
                Kansas City District
                    Book 1 of 1
               JAMS Consultants, Inc.
                 Gradient Corporation

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                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                          REGION 2
           5                           290 BROADWAY
                                   NEW YORK, NY 10007-1866
   August 29, 2000

   To All Interested Parties:

         The U.S. Environmental  Protection Agency (USEPA)  is  pleased  to release  the
   Responsiveness Summary for the Human Health Risk Assessment for the Mid-Hudson River (Mid-
   Hudson HHRA), which is part of Phase 2 of the Reassessment Remedial Investigation/Feasibility
   Study for the Hudson River PCBs Superfund site. For complete coverage, the Mid-Hudson HHRA
   and this Responsiveness Summary should be used together.

         In the Responsiveness Summary, USEPA has responded to all significant written comments
   received during the public comment period on the Mid-Hudson HHRA.  In addition,  the
   Responsiveness Summary contains revised calculations of cancer risks and non-cancer health
   hazards based on the modified future concentrations of PCBs in sediment, water and fish presented
   in USEPA's December 1999 Baseline Ecological Risk Assessment for Future Risks in the Lower
   Hudson  River (ERA Addendum),  the August 2000  Responsiveness Summary for the ERA
   Addendum, and the January 2000 Revised Baseline Modeling  Report.  This  Responsiveness
   Summary also provides separate calculations for cancer risks and non-cancer hazards to children
   eating fish from the Mid-Hudson River. Importantly, the overall conclusions regarding the cancer
   risks and non-cancer hazards due to PCBs in the Mid-Hudson River remain unchanged.

         If you need additional information regarding the Responsiveness Summary for the Mid-
   Hudson  HHRA or  the Reassessment RI/FS  in general, please contact Ann  Rychlenski,  the
   Community Relations Coordinator for this site, at (212) 637-3672.
   Sincerely yours,
./RichardL. Caspe,Director
[)  Emergency and Remedial Response Division
                              Internet Address (URL) • http://wvm.epa.gov
             Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

-------
      HUDSON RIVER PCBs REASSESSMENT RI/FS
        RESPONSIVENESS SUMMARY FOR
VOLUME 2F-A HUMAN HEALTH RISK ASSESSMENT
          FOR THE MID-HUDSON RIVER
                AUGUST 2000
                      For

           U.S. Environmental Protection Agency
                     Region 2
                      and
             U.S. Army Corps of Engineers
                 Kansas City District
                    Book 1 of 1
               TAMS Consultants, Inc.
                 Gradient Corporation

-------
                  HUDSON RIVER PCBs REASSESSMENT RLTS
                   FINAL RESPONSIVENESS SUMMARY FOR
             VOLUME 2F-A HUMAN HEALTH RISK ASSESSEMENT
                        FOR THE MID-HUDSON RIVER

                              Table of Contents
Book 1 of 1
TABLE OF CONTENTS	i
LISTOFTABLES	iii
LIST OF FIGURES	vii
ACRONYMS	viii

I. INTRODUCTION AND COMMENT DIRECTORY FOR THE HUMAN HEALTH RISK ASSESSMENT
  FOR THE MID-HUDSON RIVER (MID-HUDSON HHRA)	i
      1. Introduction	1
      2. Commenting Process	2
            2.1 Distribution of the Mid-Hudson HHRA	2
            2.2 Review Period and Public Availability Meetings	2
            2.3 Receipt of Comments	2
            2.4 Distribution of the Responsiveness Summary	2
      3. Organization of Comments and Responses to Comments	6
            3.1 Identification of Comments	6
            3.2 Location of Responses to Comments	6
      4. Comment Directory	7
            4.1 Guide To Comment Directory	7
            4.2 Comment Directory for the Mid-Hudson HHRA	9

n. RESPONSES To COMMENTS ON THE MID-HUDSON HHRA	11
      Response to General Comments	11
      1. Overview of Mid-Hudson HHRA	14
            1.1 Introduction	14
            1.2 Site Background	14
            1.3 General Risk Assessment Process	15
            1.4 Discussion of 1991 Phase 1 Risk Assessment	15
            1.5 Objectives of Phase 2 Risk Assessment	15
      2. Exposure Assessment	15
            2.1 Exposure Pathways	15
                  2.1.1 Potential Exposure Media	15
                  2.1.2 Potential Receptors	15
                  2.1.3 Potential Exposure Routes	16
            2.2 Quantification of Exposure	16
            2.3 Exposure Point Concentrations	16
                  2.3.1 PCB Concentration in Fish	17
                  2.3.2 PCB Concentration in Sediment	18
                  2.3.3 PCB Concentration in River Water	19
            2.4 Chemical Intake Algorithms	19
                                                            TAMS/Gradient Corporation

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                  HUDSON RIVER PCBs REASSESSMENT RI/FS
                   FINAL RESPONSIVENESS SUMMARY FOR
             VOLUME 2F-A HUMAN HEALTH RISK ASSESSEMENT
                        FOR THE MID-HUDSON RIVER

                               Table of Contents
Book 1 of 1
                  2.4.1 Digestion of Fish	19
                  2.4.2 Digestion of Sediment	21
                  2.4.3 Dermal Contact with Sediment	21
                  2.4.4 Dermal Contact with River Water	21
                  2.4.5 Digestion of River Water	21
      3. Toxicity Assessment	21
            3.1 Non-cancer Toxicity Values	22
            3.2 PCB Cancer Toxicity	24
      4. Risk Characterization	24
            4.1 Non-cancer Hazard Indices	25
            4.2 Cancer Risks	25

in. RISK ASSESSMENT REVISIONS	27
      1. Summary	'.	27
            1.1 Introduction	27
            1.2 Revisions to Exposure Parameter Estimates	27
                  1.2.1 Fish	28
                  1.2.2 Sediment and River Water	28
      2. Results	.'	29
            2.1 Comparison/Discussion	31
REFERENCES	32

IV. COMMENTS ON THE MID-HUDSON RIVER HUMAN HEALTH RISK ASSESSMENT

      Federal (HF)
      State (HS)
      Local (HL)
      Public Interest (HP)
      General Electric Company (HG)
                                                            TAMSIGradient Corporation

-------
                    HUDSON RIVER PCBs REASSESSMENT RI/FS
                     FINAL RESPONSIVENESS SUMMARY FOR
              VOLUME 2F-A HUMAN HEALTH RISK ASSESSEMENT
                           FOR THE MID-HUDSON RIVER

                                  Table of Contents
Book 1 of 1
LIST OF TABLES

Section I
Table 1
Table 2
Distribution of Mid-Hudson HHRA
Information Repositories
Section m
Table 2-1         Selection Of Exposure Pathways ~ Phase 2 Risk Assessment, Mid-Hudson River
                 (Revised)
Table 2-2         Occurrence, Distribution And Selection Of Chemicals Of Potential Concern, Mid-
                 Hudson River - Fish (Revised)
Table 2-3         Occurrence, Distribution And Selection Of Chemicals Of Potential Concern, Mid-
                 Hudson River - Sediment (Revised)
Table 2-4         Occurrence, Distribution And Selection Of Chemicals Of Potential Concern, Mid-
                 Hudson River - River Water (Revised)
Table 2-5         Summary of 1991 New York Angler Survey, Fish Consumption by Species Reported
Table 2-6         Mid-Hudson River Perch and Bass
Table 2-7         Species-Group Intake Percentages
Table 2-8         Medium-Specific Modeled EPC Summary, Mid-Hudson River Fish (Revised)
Table 2-9         Medium-Specific Modeled EPC Summary, Mid-Hudson River Sediment (Revised)
Table 2-10        Medium-Specific Modeled EPC Summary, Mid-Hudson River Water (Revised)
Table 2-11        County-tt>County In-Migration Data for Albany County, NY
Table 2-12        County-to-County In-Migration Data for Columbia County, NY
Table 2-13        County-to-County In-Migration Data for Dutchess County, NY
Table 2-14        County-to-County In-Migration Data for Greene County, NY
Table 2-15        County-to-County In-Migration Data for Rensselaer County, NY
Table 2-16        County-to-County In-Migration Data for Ulster County, NY
Table 2-17        County-to-County In-Migration Data for the Mid-Hudson River Region
Table 2-18        Computation of 1 -Year Move Probabilities for the Mid-Hudson Region
Table 2-19a       Values Used For Daily Intake Calculations, Mid-Hudson River Fish - Adult Angler
                 (Revised)
Table 2-19b       Values Used For Daily Intake Calculations, Mid-Hudson River Fish - Child Angler
                 (Revised)
Table 2-20        Values Used For Daily Intake Calculations, Mid-Hudson River Sediment - Adult
                 Recreator (Revised)
Table 2-21        Values Used For Daily Intake Calculations, Mid-Hudson River Sediment - Adolescent
                 Recreator (Revised)
Table 2-22        Values Used For Daily Intake Calculations, Mid-Hudson River Sediment - Child
                 Recreator (Revised)
                                          in
                                                  TAMS/Gra
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Book 1 of 1
                    HUDSON RIVER PCBs REASSESSMENT RI/FS
                     FINAL RESPONSIVENESS SUMMARY FOR
               VOLUME 2F-A HUMAN HEALTH RISK ASSESSEMENT
                           FOR THE MID-HUDSON RIVER

                                  Table of Contents
Table 2-23

Table 2-24

Table 2-25

Table 2-26

Table 2-27

Table 2-28


Table 3-1
Table 3-2

Table 4-la-RME

Table 4-lb-RME

Table 4-la-CT

Table 4-1 b-CT

Table 4-2-RME

Table 4-2-CT

Table 4-3-RME


Table 4-3-CT

Table 4-4-RME

Table 4-4-CT

Table 4-5-RME
Values Used For Daily Intake Calculations, Mid-Hudson River Water - Adult Recreator
(Revised)
Values Used For Daily Intake Calculations, Mid-Hudson River Water - Adolescent
Recreator (Revised)
Values Used For Daily Intake Calculations, Mid-Hudson River Water - Child Recreator
(Revised)
Values Used For Daily Intake Calculations, Mid-Hudson River Water - Adult Resident
(Revised)
Values Used For Daily Intake Calculations, Mid-Hudson River Water - Adolescent
Resident (Revised)
Values Used For Daily Intake Calculations, Mid-Hudson River Water - Child Resident
(Revised)

Non-Cancer Toxicity Data - Oral/Dermal, Mid-Hudson River
Cancer Toxicity Data - Oral/Dermal, Mid-Hudson River

Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Fish - Adult Angler (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Fish - Child Angler (Revised)
Calculation of Non-Cancer Hazards, Central Tendency Exposure Mid-Hudson River Fish
- Adult Angler (Revised)
Calculation of Non-Cancer Hazards, Central Tendency Exposure Mid-Hudson River Fish
- Child Angler (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Sediment - Adult Recreator  (Revised)
Calculation of Non-Cancer  Hazards, Central Tendency Exposure Mid-Hudson River
Sediment - Adult Recreator  (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Sediment - Adolescent Recreator (Revised)

Calculation of Non-Cancer  Hazards, Central Tendency Exposure Mid-Hudson River
Sediment - Adolescent Recreator (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Sediment - Child Recreator (Revised)
Calculation of Non-Cancer  Hazards, Central Tendency Exposure Mid-Hudson River
Sediment - Child Recreator (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Water - Adult Recreator (Revised)
                                           IV
                                                  TAMSICradient Corporation

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Book 1 of 1
                    HUDSON RIVER PCBs REASSESSMENT RI/FS
                     FINAL RESPONSIVENESS SUMMARY FOR
               VOLUME 2F-A HUMAN HEALTH RISK ASSESSEMENT
                           FOR THE MID-HUDSON RIVER

                                  Table of Contents
Table 4-5-CT

Table 4-6-RME

Table 4-6-CT

Table 4-7-RME

Table 4-7-CT

Table 4-8-RME

Table 4-8-CT

Table 4-9-RME

Table 4-9-CT

Table 4-10-RME

Table 4-10-CT

Table 4-1 la-RME

Table4-llb-RME

Table4-lla-CT

Table 4-1 Ib-CT

Table 4-12-RME

Table4-12-CT

Table 4-13-RME

Table4-13-CT
Calculation of Non-Cancer Hazards, Central Tendency Exposure Mid-Hudson River
Water - Adult Recreator (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Water - Adolescent Recreator (Revised)
Calculation of Non-Cancer Hazards, Central Tendency Exposure Mid-Hudson River
Water - Adolescent Recreator (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Water - Child Recreator (Revised)
Calculation of Non-Cancer Hazards, Central Tendency Exposure Mid-Hudson River
Water - Child Recreator (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Water - Adult Resident (Revised)
Calculation of Non-Cancer Hazards, Central Tendency Exposure Mid-Hudson River
Water - Adult Resident (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Water - Adolescent Resident (Revised)
Calculation of Non-Cancer Hazards, Central Tendency Exposure Mid-Hudson River
Water - Adolescent Resident (Revised)
Calculation of Non-Cancer Hazards, Reasonable Maximum Exposure Mid-Hudson River
Water - Child Resident (Revised)
Calculation of Non-Cancer Hazards, Central Tendency Exposure Mid-Hudson River
Water - Child Resident (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River Fish -
Adult Angler (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River Fish -
Child Angler (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Fish - Adult
Angler (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Fish - Child
Angler (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River
Sediment - Adult Recreator (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Sediment -
Adult Recreator (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River
Sediment - Adolescent Recreator (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Sediment -
Adolescent Recreator (Revised)
                                                                   TAMS/Gradtent Corporation

-------
                    HUDSON RIVER PCBs REASSESSMENT RI/FS
                     FINAL RESPONSIVENESS SUMMARY FOR
              VOLUME 2F-A HUMAN HEALTH RISK ASSESSEMENT
                           FOR THE MID-HUDSON RIVER

                                  Table of Contents
Book 1 of 1
Table 4-14-RME

Table 4-14-CT

Table 4-15-RME

Table 4-15-CT

Table 4-16-RME

Table 4-16-CT

Table 4-17-RME

Table 4-17-CT

Table 4-18-RME

Table 4-18-CT

Table 4-19-RME

Table 4-19-CT

Table 4-20-RME

Table 4-20-CT

Table 4-21a-RME

Table 4-21b-RME

Table 4-21a-CT

Table 4-21b-CT

Table 4-22-RME
Calculation  of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River
Sediment - Child Recreator (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Sediment -
Child Recreator (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River Water -
Adult Recreator (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Water -
Adult Recreator (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River Water -
Adolescent Recreator (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Water -
Adolescent Recreator (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River Water -
Child Recreator (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Water -
Child Recreator (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River Water -
Adult Resident (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Water -
Adult Resident (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River Water -
Adolescent Resident (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Water -
Adolescent Resident (Revised)
Calculation of Cancer Risks, Reasonable Maximum Exposure Mid-Hudson River Water -
Child Resident (Revised)
Calculation of Cancer Risks, Central Tendency Exposure Mid-Hudson River Water -
Child Resident (Revised)
Summary of Receptor Risks and Hazards for COPCs, Reasonable Maximum Exposure
Mid-Hudson River - Adult Angler (Revised)
Summary of Receptor Risks and Hazards for COPCs, Reasonable Maximum Exposure
Mid-Hudson River - Child Angler (Revised)
Summary of Receptor Risks and Hazards for COPCs, Central Tendency Exposure Mid-
Hudson River - Adult Angler (Revised)
Summary of Receptor Risks and Hazards for COPCs, Central Tendency Exposure Mid-
Hudson River - Child Angler (Revised)
Summary of Receptor Risks and Hazards for COPCs, Reasonable Maximum Exposure
Mid-Hudson River - Adult Recreator (Revised)
                                           VI
                                                                   TAMS/Cradient Corporation

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                   HUDSON RIVER PCBs REASSESSMENT RI/FS
                     FINAL RESPONSIVENESS SUMMARY FOR
              VOLUME 2F-A  HUMAN HEALTH RISK ASSESSEMENT
                           FOR THE MID-HUDSON RIVER

                                 Table of Contents
Book 1 of 1
Table 4-22-CT

Table 4-23-RME

Table 4-23-CT

Table 4-24-RME

Table 4-24-CT

Table 4-25-RME

Table 4-25-CT

Table 4-26-RME

Table 4-26-CT

Table 4-27-RME

Table 4-27-CT
Summary of Receptor Risks and Hazards for COPCs, Central Tendency Exposure Mid-
Hudson River - Adult Recreator (Revised)
Summary of Receptor Risks and Hazards for COPCs, Reasonable Maximum Exposure
Mid-Hudson River - Adolescent Recreator (Revised)
Summary of Receptor Risks and Hazards for COPCs, Central Tendency Exposure Mid-
Hudson River - Adolescent Recreator (Revised)
Summary of Receptor Risks and Hazards for COPCs, Reasonable Maximum Exposure
Mid-Hudson River - Child Recreator (Revised)
Summary of Receptor Risks and Hazards for COPCs, Central Tendency Exposure Mid-
Hudson River - Child Recreator (Revised)
Summary of Receptor Risks and Hazards for COPCs, Reasonable Maximum Exposure
Mid-Hudson River - Adult Resident (Revised)
Summary of Receptor Risks and Hazards for COPCs, Central Tendency Exposure Mid-
Hudson River - Adult Resident (Revised)
Summary of Receptor Risks and Hazards for COPCs, Reasonable Maximum Exposure
Mid-Hudson River - Adolescent Resident (Revised)
Summary of Receptor Risks and Hazards for COPCs, Central Tendency Exposure Mid-
Hudson River - Adolescent Resident (Revised)
Summary of Receptor Risks and Hazards for COPCs, Reasonable Maximum Exposure
Mid-Hudson River - Child Resident (Revised)
Summary of Receptor Risks and Hazards for COPCs, Central Tendency Exposure Mid-
Hudson River - Child Resident (Revised)
LIST OF FIGURES

Section m
Figure 2-1     Average PCB Concentration in Brown Bullhead (Revised)
Figure 2-2     Average PCB Concentration in Yellow Perch (Revised)
Figure 2-3     Average PCB Concentration in Largemouth Bass (Revised)
Figure 2-4     Average PCB Concentration in Striped Bass (Revised)
Figure 2-5     Average PCB Concentration in White Perch (Revised)
Figure 2-6     Average PCB Concentration by Species (averaged over location) (Revised)
Figure 2-7     Average Total PCB Concentration in Sediment (Revised)
Figure 2-8     Average Total PCB Concentration in River Water (Revised)
                                          Vll
                                                 TMAS/Gradient Corporation

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ACRONYMS
 ATSDR
 BERA
 GDI
 CERCLA
 CIP
 CLH
 CSF
 CTE
 EPC
 FDA
 FS
 GE
 HHRA
 HHRASOW
 HI
 HQ
 HROC
 IRIS
 NCP
 NOAA
 NPL
 NYSDEC
 NYSDOH
 PCB
 RBMR
 RfD
 RI
 RI/FS
 RM
 RME
 ROD
 SARA
 SCEMC
 TCDD
 TEF
 TSCA
 UCL
 USEPA
 USF&W
Agency for Toxic Substances and Disease Registry
Baseline Ecological Risk Assessment
Chronic Daily Intake
Comprehensive Environmental Response, Compensation, and Liability Act
Community Interaction Program
Chemical Land Holdings
Carcinogenic Slope Factor
Central Tendency Exposure
Exposure Point Concentration
Food and Drug Administration
Feasibib'ty Study
General Electric Company
Human Health Risk Assessment
Human Health Risk Assessment Scope of Work
Hazard Index
Hazard Quotient
Hudson River PCBs Oversight Committee
Integrated Risk Information System
National Oil and Hazardous Substances Pollution Contingency Plan
National Oceanic and Atmospheric Administration
National Priorities List
New York State Department of Environmental Conservation
New York State Department of Health
Polychlorinated Biphenyl
Revised Baseline Modeling Report
Reference Dose
Remedial Investigation
Remedial Investigation/Feasibility Study
River Mile
Reasonable Maximum Exposure
Record of Decision
Superfund Amendments and Reauthorization Act of 1986
Saratoga County Environmental Management Council
2,3,7,8-Tetrachlorodibenzo-p-dioxin
Toxicity Equivalency Factor
Toxic Substances Control Act
Upper Confidence Limit
United States Environmental Protection Agency
United States Fish and Wildlife
                                          VIII
                                                  TAMSIGradiem Corporation

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Introduction

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I.    INTRODUCTION AND COMMENT DIRECTORY FOR THE HUMAN HEALTH
      RISK ASSESSMENT FOR THE MID-HUDSON RIVER (MID-HUDSON HHRA)

1.    INTRODUCTION

      The U.S. Environmental Protection Agency (USEPA) has prepared this Responsiveness
Summary for Volume 2F-A Human Health Risk Assessment Report for the Mid-Hudson River
(Mid-Hudson HHRA), Hudson River PCBs Reassessment Remedial Investigation/Feasibility
Study (Reassessment R]/FS), dated December 1999 (USEPA,  1999a).   This Responsiveness
Summary addresses comments received during the public comment period on the Mid-Hudson
HHRA (USEPA, 1999a).

      For the Reassessment RFFS, USEPA has established a Community Interaction Program
(CIP) to elicit feedback from the public through regular meetings and discussion and to facilitate
review of and comment upon work plans and  reports prepared during  all phases  of the
Reassessment R17FS.

      The Mid-Hudson HHRA is incorporated by reference and is not reproduced herein. The
comment responses and revisions noted herein are considered to amend the Mid-Hudson HHRA.
For complete coverage, the Mid-Hudson HHRA and this Mid-Hudson Responsiveness Summary
must be used together.

      The first part of this Responsiveness Summary is entitled "Introduction and Comment
Directory  for the Human Health  Risk Assessment for  the Mid-Hudson River (Mid-Hudson
HHRA)."  It describes the Mid-Hudson HHRA review and commenting process, explains the
organization and format of comments and responses, and contains a comment directory.

      The second part, entitled  "Responses  to Comments  on the Human  Health  Risk
Assessment  for the Mid-Hudson  River,"  contains  USEPA's  responses  to  all  significant
comments. Responses are grouped according to  the section number of the Mid-Hudson HHRA
to which they refer.  For example, responses to comments on Section 2.1 of the Mid-Hudson
HHRA are found in Section 2.1 of the Responsiveness Summary. Additional information about
how to locate responses to comments is contained in the Comment Directory.

      The third part, entitled "Risk Assessment Revisions," presents the revised results for the
Mid-Hudson  HHRA, incorporating  the  modified forecast  concentrations  of  PCBs in  fish,
sediments, and river water.  To facilitate comparison to the December 1999 Mid-Hudson HHRA
results (USEPA,  1999a),  all  table and  figure  numberings  have retained their original
designations.

      The fourth part, entitled "Comments on the Human Health Risk Assessment for the Mid-
Hudson  River," contains copies of the comments submitted to the USEPA on the Mid-Hudson
HHRA.  The comments are identified by commenter and comment number, as further explained
in the Comment Directory.
                                                               JAMS/Gradient Corporation

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2.    COMMENTING PROCESS

      This section documents and explains the commenting process.and the organization of
comments and responses in this document. To find a response to a particular comment, the reader
may skip this section and go to the tab labeled "Comment Directory."

      2.1    Distribution of the Mid-Hudson HHRA

      The Mid-Hudson HHRA, issued in December 1999, was distributed to federal and state
agencies and officials, participants in the OOP, and General Electric Company (GE), as shown in
Table 1. Distribution was made to approximately 100 agencies, groups, and individuals. Copies
of the Mid-Hudson HHRA also were made  available for public review in 16 information
repositories,  as shown in Table 2 and on the USEPA Region 2 internet web page, entitled
"Hudson River PCBs Superfund Site Reassessment," at www.epa.gov/hudson.

      2.2    Review Period and Public Availability Meetings

      USEPA held a formal comment period on the Mid-Hudson HHRA from December 29,
1999 to January 28, 2000. USEPA held a Joint Liaison Group meeting on January 11, 2000 in
Poughkeepsie, New York that  was  open to the public to present the  Mid-Hudson HHRA.
Subsequently, USEPA sponsored an availability session to answer questions on January 18,2000
in Poughkeepsie, New York.  These meetings were conducted in accordance with USEPA's
"Community Relations in Superfund: Handbook, Interim Version" (1998a). Minutes of the Joint
Liaison  Group meeting are  available for public review  at the Information Repositories listed in
Table 2.

       As stated in USEPA's letter  transmitting the  Mid-Hudson HHRA, all citizens were
encouraged to participate in the Reassessment process and to join one of the Liaison Groups
formed as part of the CIP.

       2.3    Receipt of Comments

       Comments on the Mid-Hudson HHRA  were received in letters sent to USEPA and oral
statements made at the January  11, 2000 Joint Liaison  Group meeting. USEPA's responses to
oral statements made at the Joint Liaison Group meeting are provided in the meeting minutes.
Written  comments were  received  from  seven  commenters;  total  comments  numbered
approximately seventy.  All significant written comments received on the Mid-Hudson HHRA
are addressed in this Responsiveness Summary.

       2.4    Distribution of the Responsiveness Summary

       This Responsiveness Summary is being distributed to, among others,  the Liaison Group
Chairs and Co-Chairs and interested public officials. This Responsiveness Summary also is being
placed in the 16 Information Repositories and is part of the Administrative Record.
                                                                  TAMS/Gradient Corporation

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                                    TABLE 1
                    DISTRIBUTION OF MID-HUDSON HHRA

HUDSON RIVER PCBs OVERSIGHT COMMITTEE MEMBERS

            USEPA ERRD Deputy Division Director (Chair)
            USEPA Project Managers                              .
            USEPA Community Relations Coordinator, Chair of the Steering Committee
            NYSDEC Division of Hazardous Waste Management representative
            NYSDEC Division of Construction Management representative
            National Oceanic and Atmospheric Administration (NOAA) representative
            Agency for Toxic Substances and Disease Registry (ATSDR) representative
            US Army Corps of Engineers representative
            New York State Thruway Authority (Department of Canals) representative
            USDOI (US Fish and Wildlife Service) representative
            New York State Department of Health (NYSDOH) representative
            GE representative
            Liaison Group Chair people
            Scientific and Technical Committee representative

 SCIENTIFIC AND TECHNICAL COMMITTEE MEMBERS

       The members of the Science and Technical Committee (STC) are scientists and technical
 researchers who provide technical input by evaluating the scientific data collected on the
 Reassessment RI/FS, identifying additional sources of information and on-going research
 relevant to the Reassessment RI/FS, and commenting on USEPA documents. Members of the
 STC are familiar with the site, PCBs, modeling, toxicology, and other relevant disciplines.

             Dr. Daniel Abramowicz
       -     Dr. Donald Aulenbach
             Dr. James Bonner, Texas A&M University
             Dr. Richard Bopp, Rensselaer Polytechnic Institute
             Dr. Brian Bush, SUNY - Albany
             Dr. Lenore Clesceri, Rensselaer Polytechnic Institute
             Mr. Kenneth Darmer
             Mr. John Davis, New York State Dept. of Law
             Dr. Robert Dexter, EVS Consultants, Inc.
             Dr. Kevin Farley, Manhattan College
             Dr. Jay Field, National Oceanic and Atmospheric Administration
             Dr. Ken Pearsall, U.S. Geological Survey
             Dr. John Herbich, Texas A&M University
             Dr. Behrus Jahan-Parwar, SUNY - Albany
             Dr. Nancy Kim, New York State Dept. of Health
             Dr. William Nicholson, Mt. Sinai Medical Center
             Dr. George Putman, SUNY - Albany
             Dr. G-Yull Rhee, New York State Dept. of Health
             Dr. Francis Reilly, The Reilly Group
             Ms. Anne Secord, U.S. Fish and Wildlife Service
             Dr. Ronald Sloan, New York State Dept. of Environmental Conservation
                                                                 TAMS/Gnufrenf Corporation

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                                    TABLE 1
                 DISTRIBUTION OF MID-HUDSON HHRA (cont.)
STEERING COMMITTEE MEMBERS

      -     USEPA Community Relations Coordinator (Chair)
            Governmental Liaison Group Chair and two Co-chairs
      -     Citizen Liaison Group Chair and two Co-chairs
            Agricultural Liaison Group Chair and two Co-chairs
      -     Environmental Liaison Group Chair and two Co-chairs
            USEPA Project Managers
            NYSDEC Technical representative
            NYSDEC Community Affairs representative


FEDERAL AND STATE REPRESENTATIVES

      Copies of the Mid-Hudson HHRA were sent to relevant federal and state representatives
who have been involved with this project. These include, in part, the following:

            The Hon. Daniel P. Moynihan            -     The Hon. Michael McNulty
            The Hon. Charles Schumer               -     The Hon. Sue Kelly
            The Hon. John Sweeney                 -     The Hon. Benjamin Oilman
            The Hon. Nita Lowey                   -     The Hon. Richard Brodsky
            The Hon. Maurice Hinchey               -     The Hon. Bobby D'Andrea
            The Hon. Ronald B. Stafford



INFORMATION REPOSITORIES

      Copies of the Mid-Hudson HHRA were placed in 16 Information Repositories (see Table
2).
                                                                TAMSIGradient Corporation

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                                    TABLE 2
                         INFORMATION REPOSITORIES
Adriance Memorial Library
93 Market Street
Poughkeepsie, NY 12601

Catskill Public Library
1 Franklin Street
Catskill, NY 12414

A Cornell Cooperative Extension
Sea Grant Office
74 John Street
Kingston, NY 12401

Crandall Library
City Park
Glens Falls, NY 12801

County Clerk's Office
Washington County Office Building
Upper Broadway
Fort Edward, NY 12828

* A Marist College Library
Marist College
290 North Road
Poughkeepsie, NY 12601

* New York State Library
CEC Empire State Plaza
Albany, NY 12230

New York State Department
 of Environmental Conservation
Division of Hazardous Waste Remediation
50 Wolf Road, Room 212
Albany, NY 12233
* A R. G. Folsom Library
Rensselaer Polytechnic Institute
Troy, NY 12180-3590

Saratoga County EMC
50 West High Street
Ballston Spa, NY 12020

* Saratoga Springs Public Library
49 Henry Street
Saratoga Springs, NY 12866

* A SUNY at Albany Library
1400 Washington Avenue
Albany, NY 12222

* A Sojourner Truth Library
SUNYatNewPaltz
New Paltz, NY 12561

Troy Public Library
100 Second Street
Troy, NY 12180

United States Environmental Protection Agency
290 Broadway
New York, NY 10007

White Plains Public Library
100 Martine Avenue
White Plains, NY 12601

*      Repositories with Database Report
       CD-ROM (as of 10/98)

A     Repositories without Project
       Documents Binder (as of 10/98)
                                                                 TMAS/Gradient Corporation

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3.     ORGANIZATION OF COMMENTS AND RESPONSES TO COMMENTS

       3.1    Identification of Comments

       Each submission commenting on the Mid-Hudson HHRA was assigned the letter "H" for
Mid-Hudson HHRA, and one of the following letter codes:

          F    -    Federal agencies and officials;
          S    -   State agencies and officials;
          L    -   Local agencies and officials;
          P    -   Public Interest Groups and Individuals; and
          G    -   General Electric Company.

       The letter codes were assigned for the convenience of readers and to assist in the
organization of this document. Priority or special treatment was neither intended nor given in the
responses to comments.

       Once a letter code was assigned, each submission was then assigned a number, in the
order that it was received and processed, such as HP-1. Each different comment within a
submission was assigned a separate sub-number. Thus, if a federal agency submitted three
different comments, they are designated HF-1.1, HF-1.2, and HF-1.3.  Comment letters have
been reprinted in section IV of this document, following the fifth tab.

       The alphanumeric code associated with each reprinted written submission is marked at
the top right corner of the first page of the comment letter. The sub-numbers designating
individual comments are marked in the margin. Comment submissions are reprinted in
numerical order by letter code in the following order: F, S, L, P, and G.

       3.2   Location of Responses to Comments

       The Comment Directory, following this text, contains a complete listing of all
commenters and comments. The comment directory table is organized as follows:

       •  The first column lists the names of commenters. Comments are grouped in the
          following order: HF (Federal), HS (State), HL (Local), HP (Public Interest Groups
          and Individuals) and HG (General Electric Company).

       •  The second column identifies the alphanumeric comment code, e.g., HF-1.1, assigned
          to each comment.

       •  The third column identifies the location of the response by the Mid-Hudson HHRA
          section number. For example, comments on Section 3.2 of the Mid-Hudson HHRA
          can be found in the corresponding Section 3.2 of the Responses section.

       •  The fourth, fifth, and sixth columns list key words that describe the subject matter of
          each comment.  Readers will find these key words helpful as a means to identify
          subjects of interest and related comments.
                                                                   TAMS/Cradienl Corporation

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4.     COMMENT DIRECTORY
      This section contains the Comment Directory, preceded by a diagram illustrating how to
find responses to comments. As stated in the Introduction, this document does not reproduce the
Mid-Hudson HHRA. Readers are urged to utilize this Responsiveness Summary in conjunction
with the Mid-Hudson HHRA.

      4.1   Guide To Comment Directory
Step 1
Find the commenter or the key
words of interest in the
Comment Directory.
Step 2
Obtain the alphanumeric
comment codes and the
corresponding section of the
Mid-Hudson HHRA.
StepS
Find the responses following the
Responses tab. Use the Table of
Contents to locate the page of
the Responsiveness Summary
for the Mid-Hudson HHRA
section.
Key to Comment Codes:
Comment codes are in this format HX-a.b
H= Mid-Hudson HHRA
X=Commenter Group
(F=Federal, S=State, L=Local, P= Public Interest Groups and Individuals, G=General Electric
Company)
a=Numbered letter within the commenter group
b=Numbered comment
Example:
      COMMENT DIRECTORY FOR THE MID-HUDSON HHRA
AGENCY/
NAME
NOAA/Rosman
COMMENT
CODE
HF-1.6
REPORT
SECTION
2.3.1
KEY WORDS
1
Carp
2
Catfish
3
Eel
                                                           TAMS/Cradient Corporation

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THIS PAGE LEFT INTENTIONALLY BLANK.
                                      TMASIGradient Corporation

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Comment Directory

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4.2  COMMENT DIRECTORY FOR THE MID-HUDSON HHRA
AGENCY/NAME COMMENT REPORT KEYWORDS
CODE SECTION 1 2 3

NOAA/Rosman
NOAA/Rosman
NOAA/Rosman
NOAA/Rosman
NOAA/Rosman

NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports
NYSDEC/Ports

SCEMC/Balet
SCEMC/Balet
SCEMC/Balet
SCEMC/Balet
SCEMC/Balet
SCEMC/Balet
SCEMC/ Balet
SCEMO Balet
SCEMC/ Balet
SCEMC/ Balet
SCEMC/ Balet

Scenic Hudson
Scenic Hudson
Scenic Hudson
Scenic Hudson
Scenic Hudson
Scenic Hudson

AMC/Gardner
AMC/Gardner
AMC/Gardner
AMC/Gardner

LeRoy
LeRoy

HF- 1
HF- 2
HF- 3
HF- .4
HF- .5

HS- .1
HS- 2
HS- 3
HS- 4
HS- 5
HS- 6
HS- 7
HS- 8
HS- 9
HS-1 10
HS-1 11
HS- 12
HS- 13
HS- 14
HS- 15

HL- 1
HL- 2
HL- 3
HL- .4
HL- 5
HL- 6
HL- .7
HL- 8
HL-19
HL-1 10
HL-1 11

HP-1 1
HP- 1. 2
HP-1 3
HP- 1.4
HP-1 5
HP-1 6

HP-21
HP-22
HP-23
HP-24

HP-3 1
HP-32

1.2
23
23
2.4
2.3 1

213
General
24
24
2 12
42
General
23 1
2.12
4
24
32
3
3.1
3 1

General
2.3
23
General
23
General
General
23 1
2.3
23 1
General

General
General
24 1
General
General
General

General
General
24 1
General

24.1
General

Risk assessment
Baseline modeling
Baseline modeling
Stan date
Carp

Residential exposures
Rogers Island
Lifetime
Past exposures
Children
NCP
Cancer risks
Species fractions
Children
FDA tolerance level
Lifetime
Toxicity values
RflD derivation
Aroclor 1016
Toxicily profile

Baseline modeling
Farley model
PCB loading
Upper Hudson HHRA
Farley model
Exposure assessment
Toxicity assessment
Striped bass
River Miles
RME
Risk characterization

Cleanup
Timerrame
Fish consumption
Institutional controls
Cleanup level
Cleanup

Timeframe
Cleanup level
Fish consumption
Cleanup

Fish ingestion rate
Community studies

Lower Hudson
Farley model
Supplemental analyses
1999
Catfish

Homegrown crops
Risk assessment
Exposure duration
Risk assessment
High-end
Acceptable risk range
Individual
Brown Bullhead
High-end
Fish concentrations
Exposure duration
Selection
Uncertainties
Aroclor 1254
Out of date

Farley model
Review
Contnbution
Earlier comments
Congeners
Upper Hudson HHRA
Upper Hudson HHRA
PCB concentration
Representative
PCB concentration
Upper Hudson HHRA


Cleanup
Advisories
Cleanup
FDA level


Cleanup
FDA level
Advisories


Exposure duration
Epidemiology

Definition of site area
Uncertainty
Incorporation
Underestimate
Eel

Local produce and meat
Comparison
High-end

Fish consumption
Risk Management
Population
Catfish
Fish consumption
Comparison
High-end
Cancer slope factors
New Information
Comparison
New information

Availability

Lower Hudson

Extrapolations
Earlier comments
Earlier comments

Averaging
Fish
Earlier comments



HHRA

Inadequate Protection



nadequate Protection
HHRA


Conservatisms
Actual vs. hypothetical
                                                                   TAMS/ Gradient Coiporalion

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4.2  COMMENT DIRECTORY FOR THE MID-HUDSON HHRA
AGENCY/NAME COMMENT REPORT
CODE SECTION
LeRoy
LeRoy
LeRoy
LeRoy
LeRoy
LeRoy
LeRoy
LeRoy
LeRoy
LeRoy
LeRoy
LeRoy


GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
GE
HP-3.3
HP-3.4
HP-3.5
HP-3.6
HP-3.7
HP-3.8
HP-3.9
HP-3.10
HP-3.11
HP-3.12
HP-3.13
HP-3.14


HG-1.1
HG-1.2
HG-1.3
HG-1.4
HG-1.5
HG-1.6
HG-1.7
HG-1.8
HG-1.9
HG-1.10
HG-1.11
HG-1 12
HG-1.1 3
HG-1. 14
HG-1. 15
HG-1. 16
HG-1. 17
HG-1. 18
HG-1. 19
HG-1. 20
HG-1.21
General
General
General
General
General
2.3.1
General
4
2.4.1
General
General
General


4
General
2.3
General
1.2
3
3
2.4.1
2.4.1
2.3.1
3.1
3.1
4.2
1.2
2.3
General
General
General
3
3
General
1
PCB concentrations
Fish advisories
Community studies
Fish advisories
Health advisories
Fish concentrations
Community studies
FDA limits
Fish ingestion rate
PCB concentrations
Community studies
Health advisories


Exposure parameters
Exposure assumptions
Baseline modeling
Probabilistic analysis
Risk assessment
PCB Toxicity
Kimbrough study
Fish consumption rates
Cooking loss
Species preference
PCBRfD
PCBRfD
Kimbrough study
Risk assessment
Baseline modeling
Probabilistic assessment
Overview
Probabilistic assessment
Kimbrough study
PCB Toxicity
Exposure assumptions
KEYWORDS
2
Decline with time
NY waterbodies
Clean-up
NY waterbodies
Public education
Edible tissues
Epidemiology
Commercial Food
Conservatisms
Decline with time
Cancer
Public education


High End
Toxicity assumptions
Uncertainties
Point estimate
Mid-Hudson
Animal studies
Critique
Connelly survey
Probability distribution
Connelly survey
Re-evaluation
Uncertainty
Critique
Mid-Hudson
Predicted PCB cone.
Mid-Hudson HHRA
Comments
Mid-Hudson HHRA
Critique
Risks
Risks
3
Risk management
Risk management
Risk management

Research




Risk management

Risk management


Unrealistic
Unrealistic
Unreviewed
Mid-Hudson
Definition of site area
Epidemiological studies
Cancer slope factor
Flaws
Monte Carlo
Barclay data
Uncertainty factors
Probability distribution
Cancer slope factor
Definition of site area
Flaws
Monte Carlo
Risk assessment
Monte Carlo
Re-evaluation
Overestimate
Overestimate
                                         10
                                                                  TAMS/ Gradient Corporation

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Responses

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II.    RESPONSES TO COMMENTS ON THE MID-HUDSON HHRA

Responses to General Comments

Response to HL-1.4. HL-1.6. HL-1.7. HL-1.11

       These comments refer to comments previously submitted on the Upper Hudson HHRA (USEPA,
1999b), that  are also  applicable to the Mid-Hudson HHRA  (USEPA,  1999a). These comments are
addressed in the March 2000 Responsiveness Summary for the Upper Hudson HHRA (USEPA, 2000a)
and are not repeated here. The reader is referred to pp. 13,19-22, 26-37, and 41-46 of the March, 2000
Responsiveness Summary for the Upper Hudson HHRA (USEPA, 2000a).

Response to HG-1.2. HG-1.17. HG-1.21

       Consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
(USEPA, 1990) and USEPA policy and guidance (USEPA, 1989a, 1989b, 1991a, 1992, 1995, 1996, and
1997a), the exposure parameters used in the Mid-Hudson HHRA are appropriately protective of human
health and do not reflect a worst-case exposure scenario. Specifically, USEPA evaluated both high-end
(Reasonable Maximum Exposure or RME) and central tendency exposure (CTE or average) cancer risks
and non-cancer hazards  in  the Mid-Hudson HHRA.  The RME is the maximum exposure that is
reasonably expected to occur in  the Mid-Hudson River under  baseline conditions (e.g., no  active
remediation of the PCB-contaminated sediments in the Upper Hudson River and no institutional controls,
such as the fish consumption advisories currently in place).  The RME is reasonable because it  is a
product of factors,  such  as concentrations  (e.g., fish, sediment, and surface water)  and exposure
frequency and duration,  that are an  appropriate mix of values that reflect averages and high-end
distributions (USEPA,  1989a, 1989b, 1991a, 1997a).

       The fish ingestion rates and exposure durations for the Mid-Hudson HHRA were derived from
the 1991 New York Angler study (Connelly et al.,  1992) and population mobility data from the U.S.
Census Bureau for the  six counties surrounding the Mid-Hudson River (see, p. 13, Mid-Hudson HHRA,
USEPA, 1999a).  The fraction from source was assumed to be  1 (i.e., 100%) (see, pp.  12-13, Mid-
Hudson HHRA, USEPA, 1999a),  which is reasonable given the length (90 miles) of the Mid-Hudson
River and the variety of fish species it can support.  The concentrations of PCBs in fish beginning in
1999 were based on modeled PCB concentrations in fish, summarized in the Baseline Ecological Risk
Assessment for Future Risks in  the Lower Hudson River (ERA Addendum, USEPA, 1999c).  The
modeled concentrations were subsequently updated for this Responsiveness Summary based on those
summarized in the Responsiveness Summary for the ERA Addendum (USEPA, 2000d).  The forecast
results were based on upstream PCB boundary loads presented in the Revised Baseline Modeling Report
(USEPA, 2000b).  The toxicity values were taken from USEPA's Integrated Risk Information System or
IRIS, which is USEPA's consensus database of toxicity values and considers both toxicological studies
in animals and human epidemiological studies in determining appropriate toxicity values for use in risk
assessments throughout the Agency (see. Appendix C of the Upper Hudson HHRA (USEPA, 1999b),  and
Responsiveness Summary for HHRASOW (USEPA, 1999d), pp. 25-26).
                                                                     IMASICradienl Corporation
                                          II

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Response to HG-1.4. HG-1.16. HG-1.18

       Although  a  Monte  Carlo  analysis was originally planned for the Mid-Hudson HHRA (as
discussed in the HHRA Scope of Work, USEPA, 1998b), it was subsequently deemed unnecessary. The
PCB concentrations in the Mid-Hudson River are lower than the Upper Hudson River, the shape of the
exposure distributions for the Mid-Hudson HHRA would be expected to be the same as or similar to
those used  in the  Upper Hudson HHRA, and the results from the Upper Hudson HHRA Monte Carlo
analysis were consistent with the point estimate results.

       A point estimate approach is not the equivalent of a screening level approach. A point estimate
approach can be and was used to develop valid central tendency and high-end estimates of exposure, non-
cancer hazards, and cancer  risks, and is a common risk assessment practice, consistent with USEPA
policy (USEPA, 1989b).  While  a Monte Carlo analysis can  be a useful tool,  USEPA guidance does not
require the use of a Monte Carlo analysis (USEPA, 1997b).

       Note that as recognized  in the footnote in comment HG-1.16, there is a typographical error in the
last paragraph  of Section 4.2 of the Mid-Hudson HHRA (USEPA,  1999a).   The statement should read
"The  cancer risks associated with RME fish ingestion exceed the cancer risk range generally allowed
under federal Superfund law."

Response to HS-1.2

       In a separate matter, in July 1999 USEPA released a Human Health Risk Assessment for Rogers
Island, located in  the Town of Fort Edward in the Upper  Hudson River (USEPA, 1999e).  Both the
Rogers Island and the Mid-Hudson River risk assessments quantify cancer risks and non-cancer hazards
to human health using USEPA  policy and guidance and the current toxicity  values for PCBs (USEPA,
1989a, 1989b,  1991a, 1992, 1995,  1996, and 1999f-h). However, the risk assessments quantify cancer
risks and non-cancer hazards for different exposure pathways and using site-specific exposure values
developed for  the two different sites.  For example, the Rogers Island risk  assessment evaluated both
residential and recreational exposure over a relatively small area, whereas the Mid-Hudson River risk
assessment  evaluated recreational exposure only, over a 90-mile stretch of river. In cases where the risk
assessments evaluated the same route of exposure (i.e., dermal contact with sediments), the exposure
assumptions are different to reflect the difference in activity patterns between residents and recreators
based on accessibility to  the river, frequency of contact, and age at time of exposure. In addition, at the
time of the Rogers Island risk assessment, the USEPA Dermal Workgroup (a  group  which includes
Regional and Headquarters USEPA staff) recommended a skin adherence factor of 1 mg/cm2 for adults
and children (based on  Duff and  Kissel, 1996, based on  a monolayer).   Subsequently, the Dermal
Workgroup's recommended skin adherence factor changed to 0.2 mg/cm2 for children and 0.3 mg/cm2 for
adults, which was  used in the Mid-Hudson River risk assessment (USEPA, 1999i, based on a review and
analysis of a number of recent soil adherence studies).

Response to HS-1.7

       The comment is  acknowledged. The Mid-Hudson HHRA (USEPA, 1999a) calculated increased
cancer risk  to an adult eating fish (RME) of 4 x 10"4.  However, for purposes of risk communication, the
risk was presented in the Executive Summary as its mathematical equivalent of four additional cancers in
10,000 exposed people. Note that based on the  Mid-Hudson HHRA revisions (Section in of this report,
Table 4-21-RME), the cancer risk  to an RME  individual (child, adolescent, then adult) eating fish is
estimated to be 7 x 10"4.

                                                                         TMAS/Gradient Corporation
                                            12

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Response to HL-1.1

       Copies of all USEPA reports relating to the Hudson River PCBs RI/FS, including all modeling
reports, are available for public review at the 16 information repositories.

Response to HP-1.1. HP-1.2. HP-1.4. HP-1.5. HP-1.6. HP-2.1. HP-2.2. HP-2.4

       These comments pertain to risk management decisions, which are outside the scope of the Mid-
Hudson HHRA. The role  of the baseline  risk assessment  is to evaluate  current and future  risks
associated with the site and inform decisions regarding remediation in the FS.   Remediation goals
(including the relevance of the FDA limit in setting remediation goals), remedial  alternatives, and the
timeframe for cleanup will be addressed as part of the upcoming FS and Proposed Plan.

Response to HP-3.2. HP-3.5. HP-3.9. HP-3.13

       The performance of community health-based epidemiological studies, as suggested in the
comment,  is beyond the scope of USEPA's Mid-Hudson HHRA, and is more appropriately addressed by
NYSDOH and ATSDR.  As indicated during USEPA's presentation of the Mid-Hudson HHRA on
January 11, 2000, USEPA is aware that NYSDOH is conducting a study of individuals living in Hudson
Falls, NY  (and Glens Falls, NY as a control) to understand the potential impact of PCBs on neurological
functions in adults.  The NYSDOH research project, "PCBs and Health: The  Hudson River Communities
Project," is anticipated to be completed in 2001.  Upon completion, USEPA will review the results of
these studies.

       In  its draft Toxicological Profile, ATSDR states that it is not known  whether PCBs cause cancer
in people, but that  PCBs  have been shown to cause cancer in animal studies (ATSDR,  1999).  Note,
however, that ATSDR's draft Toxicological Profile for PCBs is currently being revised based on external
comments  and the results of a peer review of the document. The USEPA and the International Agency
for Research on Cancer have classified PCBs as a probable human carcinogen.

Response to HP-3.3. HP-3.12

       The PCB concentrations have declined with time. The models used to derive the exposure point
concentrations for the Mid-Hudson HHRA predict a decline in future concentrations. Thus, the exposure
point concentrations used in the Mid-Hudson HHRA reflect this expected  decline over time and with
distance down river.

Response to HP-3.4. HP-3.6

       There are numerous fish consumption advisories currently in effect in New York State, including
a general,  state-wide advisory as well as advisories specific to certain water bodies. This fact does not
affect the  Mid-Hudson HHRA, because in performing a baseline  risk assessment of current and future
exposure (i.e., assuming no remediation or institutional controls), USEPA does not consider the effects of
fish consumption advisories.

Response to HP-3.7. HP-3.14

       The USEPA Office  of Research  and Development (ORD) supports research to improve risk
assessment and the New York State Department of Environmental Conservation monitors contaminant
                                                                        TMASICradient Corporation
                                            13

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levels in fish and provides data to the Department of Health (NYSDOH).

       The importance of public health education is acknowledged. However, the Mid-Hudson HHRA
was performed to evaluate health risks under baseline conditions (i.e., assuming no active remediation of
the PCB-contaminated sediments and no institutional controls, such as the fish consumption advisories
currently in place). Although USEPA believes that consumption advisories can be effective in limiting
exposure to PCBs in Hudson River fish, there  is no guarantee that all anglers  will abide by  the
consumption advisories. Several  studies provide evidence that a percentage of the angling community
may  not follow fish consumption advisories, and  may continue to consume fish from rivers  with fish
consumption advisories (Barclay, 1993; NYSDOH, 1999; Connelly etal., 1992; Connelly et al., 1996).

1.     OVERVIEW OF MID-HUDSON HHRA

       1.1    Introduction

       No significant comments were received on Section I.I.

       1.2    Site Background

Response to HF-1.1

       USEPA has previously responded to public  comment regarding its decision to quantify cancer
risks and non-cancer hazards to individuals in the Upper and Mid-Hudson River, but not to individuals in
the Lower Hudson River between Poughkeepsie, New York and the Battery in New York City (USEPA,
1999d, Responsiveness Summary for the HHRA Scope of Work,  p. 14).  USEPA's  approach  to assess
cancer risks  and non-cancer hazards only in the Upper and Mid-Hudson  River is protective of human
health (e.g., will not underestimate RME cancer risks and non-cancer hazards) because site-related risks
to individuals closer to the sources of PCBs (i.e., in the Upper and Mid-Hudson River) are expected to be
higher than the cancer risks and  non-cancer hazards to individuals farther away from the sources (i.e.,
south of Poughkeepsie), based on the higher concentrations of site-related PCBs found in fish, water and
sediments in the Upper and Mid-Hudson River compared to those in the Lower Hudson River.

Response to HG-1.5. HG-1.14

       USEPA has  previously  responded  to comments  regarding  the extent of the  site in  the
Responsiveness Summary  for the  HHRA  Scope  of Work (USEPA,  1999d,  pp.  14-15)  and  the
Responsiveness Summary for the Upper Hudson HHRA (USEPA, 2000a,  p. 15).  The listing of  the
Hudson River PCBs Site on the National Priorities List (NPL) is  not limited to the Upper  Hudson;  the
Lower Hudson clearly is within the "broad compass" of the NPL listing  because it is within  the areal
extent  of  contamination resulting from the discharge of PCBs to the Upper Hudson  River.   See
Washington  State Dept. of Transportation v. EPA.  917 F.2d  1309, 1311 (D.C. Cir.  1990).  See also
Eaele-Picher Industries v. EPA. 822 F.2d 132 (D.C. Cir. 1987).

       Moreover, USEPA has consistently defined the site to include the Lower Hudson River since at
least April 1984, when the Agency issued its FS for the site and before the site was listed on the NPL
(codified at 40 CFR Part 300, App. B).  In its September 25, 1984 Record of Decision (ROD), USEPA
defines the site by reference to three figures which, together, depict the site as the entire 200-mile stretch
of the River from Hudson Falls to the Battery in  New York City, plus the remnant deposits (USEPA,
1984).  In addition, during the Reassessment RI/FS, USEPA has consistently defined the site as including
the Upper and Lower River (e.g.. USEPA, 1991b).
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       USEPA disagrees with the commenter's suggestion that it would be inappropriate for USEPA to
consider  benefits to the Lower River that  may  accrue  from remediation  in  the  Upper  Hudson.
Throughout the Reassessment RI/FS, USEPA has maintained - and continues to maintain - that the
purposes of the Reassessment RI/FS include an evaluation of the impacts that PCB-contaminated Upper
River sediments have on the Site, including the Lower River, and an evaluation of remedial options for
the Upper River in light of those impacts, among other factors.  USEPA is  not at this time evaluating
remedial  options for the Lower River.

       1.3     General Risk Assessment Process

       No significant comments were received on Section 1.3.

       1.4     Discussion of 1991 Phase 1 Risk Assessment

       No significant comments were received on Section 1.4.

       1.5     Objectives of Phase 2 Risk Assessment

       No significant comments were received on Section 1.5.

2.     EXPOSURE ASSESSMENT

       2.1     Exposure Pathways

               2.1.1  Potential Exposure Media

              No significant comments were received on Section 2.1.1.

              2.1.2  Potential Receptors

Response to HS-1.5. HS-1.9

       Cancer  risks and non-cancer  hazards using child-specific  (ages  1-6)  values  for all input
parameters are presented  in the Risk Assessment Revisions (Section m of  this report and  associated
tables).   For example, the following exposure assumptions were made for  the RME young child: an
average daily fish ingestion rate of 10.6 g/day (based on a child meal size of 76 grams, or 2.7 ounces), the
high-end  PCB concentration  in fish (1.4  mg/kg), an exposure frequency of 365 days, an exposure
duration of 6 years (ages 1-6 years), and a body weight of 15 kg (or 33 pounds, the average body weight
for male and female children aged 1 to 6, USEPA, 1989a). The chronic (i.e., 7 years or more) Reference
Dose was used to be protective of children (USEPA, 1993). The resulting RME cancer risk for a child
ingesting fish was approximately 2 x 10"4 (2 additional cancers in 10,000 children exposed), compared to
the RME total cancer risk for adult, adolescent, and child of 7 x 10"* (7 additional cancers in 10,000
exposed individuals). The RME non-cancer hazard index for a child ingesting fish was approximately
49, compared to the RME adult non-cancer hazard index of 32 and the RME adolescent non-cancer
hazard index of 35. The Mid-Hudson HHRA is amended to reflect this additional information.

       Note that this assessment assumed that a young child meal portion is approximately 1/3 that of an
adult (227 grams for adults, 76 grams for children).  This assumed ratio (0.33) is only slightly less than
the 0.36 ratio recommended by the commenter. The assumed child portion size, 76  grams or 2.7 ounces,
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falls between the mean fish meal sizes reported by the USEPA for children less than five years old and
children aged 6 to 11 years old (67 grams [2.4 ounces] and 89 grams [3.1 ounces], respectively) (USEPA,
1997a).

              2.1.3  Potential Exposure Routes

Response to HS-1.1

       Consistent with the focus of the Reassessment RI/FS, the Mid-Hudson HHRA calculated cancer
risks and non-cancer hazards associated with exposure to PCBs in the sediments, water and fish in the
Mid-Hudson River.  As discussed in the Upper Hudson  HHRA (USEPA, 1999b, p. 8), USEPA
qualitatively assessed available data and literature regarding PCB uptake in forage crops and cow's milk,
and concluded that risk via  ingestion of foods other than Hudson River fish is likely to be minimal, and
the collection of additional PCB data from vegetables, meat, eggs, and milk is not warranted.  Therefore,
the Mid-Hudson HHRA does not quantify cancer risks and non-cancer hazards due to uptake of PCBs via
floodplain soils or the other residential  pathways identified (see, p. 6, Mid-Hudson HHRA, USEPA,
1999a).

       2.2 Quantification of Exposure

       No significant comments were received on Section 2.2.

       2.3 Exposure Point Concentrations

Response to HF-1.2. HF-1.3. HL-1.2. HL-1.3. HL-1.5. HG-1.3. HG-1.15

       These comments refer to the PCB modeling efforts for fish, water, and sediments.  The fate and
transport and bioaccumulation models are presented in the Revised Baseline Modeling Report (RBMR)
(USEPA, 2000b), and the ERA Addendum (USEPA,  1999c),  which contains a summary of the Farley
model results. Issues relating to these modeling efforts are addressed in the above referenced reports and
their Responsiveness Summaries (USEPA, 2000c; USEPA, 2000d).  In addition, the RBMR underwent
independent peer review and the majority of the reviewers  found  the report acceptable with  minor
revisions (ERG, 2000).

       USEPA reviewed the Farley model for use in the ERA Addendum (USEPA, 1999c). The data
set available to calibrate a PCB fate and transport model in the Lower Hudson is limited. However, as
discussed  in the  Responsiveness Summary for the ERA Addendum (USEPA, 2000d), other data and
analyses independently confirm the conclusions drawn from the Farley modeling analysis. For example,
the conclusion that the principal source of PCBs to the Lower Hudson is the Upper Hudson is directly
supported  by the high-resolution core analysis presented in the Data Evaluation and Interpretation Report
(USEPA,  1997c).  Similarly, the gradual decline in PCB concentration estimated by the model is
supported  by the analysis of the high-resolution cores presented in the Data Evaluation and Interpretation
Report (USEPA,  1997c). Additionally, earlier versions of the Farley model developed by Thomann and
others were peer reviewed  and published.   It  is USEPA's understanding that the authors of the most
recent version of the Farley  model will submit it for publication in a peer reviewed scientific journal.

       Cancer risks and non-cancer hazards to human  health for the Mid-Hudson  have  been revised
based on supplemental analyses of the fate  and transport and bioaccumulation models. These results for
the Mid-Hudson are presented in Section HI of this Responsiveness Summary.  In general, the overall
conclusions from the December 1999 Mid-Hudson HHRA (USEPA, 1999a) remain unchanged for this
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revised Mid-Hudson HHRA. The revised calculations for the Mid-Hudson HHRA show that cancer risks
and non-cancer health hazards to the RME individual associated with ingestion of PCBs in fish from the
Mid-Hudson River are above  USEPA levels of concern.  In addition, the revised  calculations indicate
that fish ingestion represents the primary way for people to be exposed to PCBs from the site, and that
cancer risks and non-cancer hazards from other exposure pathways are generally below USEPA's levels
of concern.

       Waiting  until after the peer review for the RBMR to use  the model  output would  have
unnecessarily delayed issuance of the risk assessments by about one year.  The Upper Hudson HHRA
was peer-reviewed in May 2000 and generally found to be acceptable with minor revisions. The results
of the various independent peer reviews are being considered by USEPA, and the Agency will respond to
the peer reviewers'  recommendations  in written Responsiveness Summaries.   USEPA's approach
accomplishes both the Agency's policy to use  sound, credible science in its decision-making and its
commitment to release a Proposed Plan identifying its preferred cleanup alternative in December 2000.

Response to HL-1.9

       This comment is based on a misinterpretation of the use of the modeled river data.  The modeled
river data cover the 90 miles of the Mid-Hudson River; the data for a single river mile were not used to
represent that range.  Although each reach of the river was identified by the mile marker at the upstream
end of the reach, USEPA used the average PCS  concentration for each reach.  The Mid-Hudson HHRA
assumed a uniform likelihood of fishing at any location within the Mid-Hudson River study area, which
is believed to  be a reasonable assumption in light  of the  lack of any information specific to fishing
practices in the area.  This comment is also addressed in the Responsiveness Summary for the ERA
Addendum (USEPA, 2000d).

              2.3.1  PCB Concentration in Fish

Response to HF-1.5. HS-1.8

       The 1991 New York Angler survey  (Connelly et al., 1992) reported fish  consumption for six
species that are potentially caught in the Mid-Hudson River: bass, bullhead, carp, catfish, eel, and perch
(Mid-Hudson HHRA, USEPA, 1999a, Table 2-5).   In the  ERA  Addendum (USEPA,  1999c), USEPA
forecast concentrations of PCBs in five  fish species commonly consumed  by humans:  brown bullhead,
largemouth bass, yellow perch, striped bass, and white perch. Other species known to exist in the Mid-
Hudson region (i.e., carp, catfish, and eel) were reported in the 1991 New York Angler Survey (Connelly
et al., 1992) and by Dr. Ronald Sloan of NYSDEC (R. Sloan, personal communication).  Because carp,
catfish, and eel were  not specifically modeled, they  were assigned the PCB concentration modeled for
brown bullhead, which also spends much of its time at the bottom of lakes, rivers, and streams.

       One commenter notes that PCB concentrations measured in 1992 in eel, carp/goldfish, and white
catfish (9.1, 9.2,  and 8.8 ppm, respectively)  are higher than in brown bullhead (3.1  ppm).  PCB
concentrations  (Tri+) for brown bullhead and white catfish from Release 4.1 of the Hudson database
were compared. The  differences between the PCB concentrations for brown bullhead and white catfish
ranged a factor of two to four apart; thus, using modeled PCB concentrations for brown bullhead would
underestimate PCB concentrations for carp, catfish, and eel.  However, given the relatively low intake
percentages for the carp, catfish, and eel (5.9%, 7.4%, and 2.5% of the total  fish intake, respectively), the
total cancer risks and  non-cancer hazards from ingesting fish would not be substantially underestimated
(see, Mid-Hudson HHRA, USEPA, 1999a, Table 2-7).

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Response to HG-1.10

       As discussed in the Mid-Hudson HHRA (USEPA,  1999a,  pp.  10), the Mid-Hudson species
preferences were based on  consideration of both the  1991 New York Angler survey (Connelly et al.,
1992) and the Hudson River angler surveys (Barclay, 1993; NYSDOH, 1999). There is some uncertainty
associated  with the  species preferences  used;  however, this  uncertainty  is unavoidable. Although
ascertaining species preference was not the primary purpose of these studies, there are no studies
available relevant to the Hudson River that were designed specifically to determine species preferences.
The results from the Hudson River angler surveys (Barclay, 1993; NYSDOH, 1999) are more difficult to
interpret  due to the fish consumption advisories in effect on the Hudson River, and because the studies
report only the amount of each species caught, rather than the amount of each species consumed.  The
adjustments made to the 1991 New York Angler survey (Connelly et al., 1992) data,  such as excluding
the "other" category, which may include fish species found in the Mid-Hudson,  excluding fish species
not found in the Mid-Hudson, and extrapolating the percent of all fish in flowing water bodies to percent
of Hudson species (discussed  in more detail in the Upper Hudson HHRA, USEPA,  1999b, Table 3-3)
were necessary so that the fish species percentages for the Mid-Hudson totaled 100%.

       Furthermore, even if  anglers were consuming a greater percentage of  striped bass or large-
mouthed  bass, and a smaller percentage of bottom feeders (brown bullhead, carp, catfish, and eel), the
total cancer risks and non-cancer hazards from ingesting fish calculated in the Mid-Hudson HHRA would
not be expected to change significantly.  The exposure point concentration values  for striped bass, large-
mouthed  bass, and brown bullhead  were all similar (RME EPC values were 1.2, 0.87, and 1.2 mg/kg,
respectively) (Mid-Hudson  HHRA  revisions, Table 2-8, in  Section m  of this  report).  Because the
exposure point concentration values for yellow and white perch were the lowest of the five modeled fish
species, increasing the preference for yellow or white perch could potentially lower the species-weighted
PCB exposure  point concentrations, and  the resulting  total  cancer risks and non-cancer hazards.
Although herring and American shad are present in the Mid-Hudson, they were not evaluated in the Mid-
Hudson HHRA because forecast concentrations were not available for herring or American shad.

Response to HL-1.8

       This comment is addressed  in the Responsiveness Summary  for the ERA Addendum (USEPA,
2000d).

Response to HL-1.10

       An RME value for  PCB concentration in fish was used in the calculation of the RME cancer
risks and  non-cancer  hazards.   This  value  was  calculated  by averaging  the  species-weighted
concentration distribution over the 95th percentile exposure duration estimate (i.e. 40 years).

Response to HP-3.8

       To clarify, in the Mid-Hudson HHRA, the models that were used to derive  concentrations of
PCBs in fish were calibrated using PCB concentrations measured in fish fillets, skin on. Therefore, the
modeled PCB concentrations represent the edible tissue, and not PCB concentrations in whole fish.

              2.3.2  PCB Concentration in Sediment

              No significant comments were received on Section 2.3.2
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              2.3.3  PCB Concentration in River Water

              No significant comments were received on Section 2.3.3

       2.4    Chemical Intake Algorithms

Response to HF-1.4. HS-1.4

       The start date for the  exposure of anglers used in both the Mid-Hudson and Upper Hudson
HHRAs  is  1999 (Mid-Hudson  HHRA,  USEPA,  1999a,  pp.  8-11;  see  also.  USEPA,  1999d,
Responsiveness Summary for the HHRASOW, pp. 28 and 29). This is consistent with the goals of the
Mid-Hudson HHRA  because the Mid-Hudson HHRA evaluates current and future risk, and 1999 is the
year in which the Mid-Hudson HHRA was completed.  Use of a start date before 1999 would not be
consistent with USEPA risk assessment guidance (USEPA, 19895). In addition, the expert panel that
reviewed the current PCB cancer slope factors did not support adjusting for internal dose to reflect
previous PCB exposure and current body burdens; this is because data are not available to determine the
appropriate dosimetric for PCB carcinogenicity based on existing PCB body burdens (USEPA, 1996b)
(see also. Responsiveness Summary for the HHRA Scope of Work, USEPA, 1999d, p. 28). Therefore,
although past exposures are a source of uncertainty, this issue is not addressed quantitatively in the Mid-
Hudson HHRA.

Response to HS-1.3. HS-1.11

       Use of a lifetime exposure duration (e.g., 70 years) in the point estimate calculations of cancer
risks and  non-cancer hazards  is inconsistent  with USEPA guidance (USEPA, 1989b) and  is more
representative of a "worst  case" exposure scenario  than an RME scenario.  The 40-year exposure
duration used for the RME scenario is based on a reasonable use of site-specific information.  For
comparison, the current USEPA default recommendation (i.e., in the absence of site-specific data) for the
exposure duration parameter for Superfund risk assessments is 30 years for the RME based on  national
mobility statistics for the general population (USEPA, 1989b; USEPA 1997a, as cited in Upper Hudson
HHRA, p. 57).

              2.4.1  Ingestion of Fish

Response to HG-1.8

       The 1991 New York Angler survey (Connelly et al., 1992) was used to derive the fish ingestion
rates for the point estimate calculations of cancer risks and non-cancer hazards. In the Upper Hudson
HHRA, USEPA compared the  central (or average)  and high-end fish ingestion rates used in the Mid-
Hudson and Upper Hudson HHRAs to the surveys identified in the comment, including the 1993 Maine
Angler survey (Ebert et al., 1993), the 1992 Lake Ontario diary study (Connelly et al., 1996), and other
surveys (see Upper Hudson HHRA, USEPA, 1999b, p. 44 and Table 3-2). The fish ingestion rates used
in the Mid-Hudson HHRA are within the range of ingestion rates found in these other surveys and the
ingestion rates recommended  in  the USEPA  Exposure Factors Handbook (USEPA, 1997a) (Upper
Hudson HHRA, USEPA,  1999b, p. 43).  The rationale for using the 1991 New York Angler survey data
rather than the 1993 Maine Angler  survey data is addressed in the Upper Hudson HHRA (USEPA,
1999b,  p. 42). The specific concerns about the 1991 New York Angler survey raised by the commenter,
such as the survey response rate, long-term recall  bias, and meal  size assumptions, are discussed in
Section 3.2.1 of the Upper Hudson HHRA (USEPA, 1999b).  Furthermore, the results of the sensitivity
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analysis for fish ingestion rate in the Upper Hudson HHRA indicate that adopting a lower fish ingestion
rate does not change the results significantly.

       The  1992 Lake Ontario Diary Study (Connelly et al.,  1996) was not used to develop a fish
ingestion rate distribution for the point estimate calculations, in part, because the survey results
documented  that the fish consumption advisories in  place at the time of the  survey  reduced fish
consumption by the participants (i.e, 32% indicated that they would eat more fish if there were no fish
consumption health advisories) (Upper Hudson HHRA, USEPA, 1999b, p. 39). Of the available studies
of sport fish ingestion, the 1991 New York Angler survey is considered the preferred study to represent
Mid-Hudson River anglers because, among other reasons, it was conducted in New York, included the
fish species of concern in the Hudson River, included water bodies with no fish consumption advisories,
and included a large sample size (Upper Hudson HHRA, USEPA, 1999b, p. 73).

Response to HG-1.9

       In the Upper Hudson HHRA, USEPA summarized laboratory studies of fish preparation and
cooking methods conducted to quantify the extent of PCB loss prior to consumption (Upper Hudson
HHRA, USEPA, 1999b, Table 3-5). Many of the fish species used in these studies are not found in the
Upper (or Mid-) Hudson River.  Moreover, the studies were conducted over a period of more than 20
years, and the results may not be comparable to one another due to developments in the sampling and
analytical methodologies.  In addition, total losses of PCBs during cooking can be affected by factors
other than cooking method, such as length of time the  fish is cooked, the temperature during cooking,
preparation techniques, the lipid content  of the  fish,  the fish species, the magnitude of the PCB
contamination in the raw fish, and the extent to which lipids separate during cooking (Upper Hudson
HHRA, USEPA, 1999b, pp. 48-49). For these reasons, USEPA determined that the available literature
was inadequate to develop a site-specific distribution of PCB losses during fish preparation and cooking.

Response to HP-1.3. HP-2.3

       Consistent with the NCP and  USEPA risk assessment guidance (USEPA,  1989B), the Mid-
Hudson HHRA evaluates both current and future cancer risks and non-cancer hazards in the absence of
any remedial action or institutional controls, such as the fish consumption advisories currently in place
(Mid-Hudson HHRA, USEPA, 1999a, p. ES-1).
Response to HP-3.1. HP-3.11

       As  stated in the Mid-Hudson HHRA, the RME fish ingestion rate used in the Mid-Hudson
HHRA was 31.9 g/day, which corresponds to approximately one half-pound fish meal per week.  This
value is based on the  90th percentile fish ingestion rate in the  1991 New York Angler survey (Mid-
Hudson HHRA, USEPA, 1999a, Table 2-19).  The RME exposure duration of 40 years is based on the
95* percentile of the fishing duration distribution, generated based on the 1991 New York Angler survey
and  1990 population mobility data from the U.S.  Bureau of Census (Mid-Hudson HHRA, USEPA,
1999a, Table 2-19). The goal of the selection of the fish ingestion rate is to represent a reasonable
maximum exposure for current and future exposures and be protective of human health (USEPA, 1989b,
1990, 1992). Using data from Connelly et al. (1992) survey that represents fish ingestion by high-end
anglers within New York State achieves this goal.
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              2.4.2  Ingestion of Sediment

              No significant comments were received on Section 2.4.2.

              2.4.3  Dermal Contact with Sediment

              No significant comments were received on Section 2.4.3.

              2.4.4  Dermal Contact with River Water

              No significant comments were received on Section 2.4.4.

              2.4.5  Ingestion of River Water

              No significant comments were received on Section 2.4.5.

3.     TOXICITY ASSESSMENT

Response to HG-1.6. HG-1.7. HG-1.19. HG-1.20

       Consistent with USEPA risk assessment policy and guidance (USEPA, 1996a, 1992), the Mid-
Hudson HHRA uses the current toxicity values in IRIS, the Agency's consensus database of toxicity
values.  USEPA's evaluations of cancer risks and non-cancer health effects of PCBs were externally
peer-reviewed and went through internal Agency consensus review before inclusion in IRIS. The IRIS
cancer slope  factors were  developed  during USEPA's 1996  reassessment  of PCB carcinogenicity
(USEPA, 1996b) and are based on a number of published studies that evaluate the carcinogenic potential
of PCBs in both humans and animals. USEPA is currently reassessing the non-cancer toxicity values for
PCBs and the overall weight of evidence for PCB health effects, as well as considering the significance
of recent human epidemiological studies of PCBs. The results of this Agency reassessment of non-cancer
toxicity values are expected in 2001.  Consistent with risk assessment policy and guidance,  USEPA
considered relevant new lexicological information prior to using the existing IRIS toxicity values in the
Mid-Hudson HHRA (USEPA, 1999h, Upper Hudson HHRA, USEPA, 1999b, Appendix C, pp. C-l to C-
6).

       USEPA used a  weight-of-evidence approach  to evaluate  PCBs (USEPA,  1996b, 1999f-h).
USEPA's  cancer and non-cancer toxicity  assessments for PCBs considered both human epidemiology
and animal carcinogenicity data, as  well as other  supporting studies (e.g., mutagenicity tests, metabolism
data, etc.), as described in the IRIS  Weight of Evidence classification (USEPA, 1996, 1999h). Based on
this information, USEPA concluded that the available evidence  from human studies is inadequate, but
suggests that exposure to PCBs can  cause cancer. The expert panel convened for the reassessment of the
PCB cancer slope factors (USEPA, 1996b) did not recommend that the epidemiological studies be used
to derive CSFs for PCBs, noting inadequacies with regard to limited cohort size, problems in exposure
assessments, lack of data on confounding factors, and the fact that occupational exposures may be to
different congener mixtures than those found in environmental exposures, as well as other limitations and
complications associated with  interpreting  data from  human  epidemiological  studies (see. USEPA,
1999h). A summary of the results of the peer review of the cancer reassessment for PCBs and the IRIS
chemical files for Aroclors 1254 and 1016 used in the non-cancer assessment are available on USEPA's
web site at www.epa.gov/iris/subst/0294.htm and  www.epa.gov/ncea/pcbs.htm.


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        Consistent with USEPA risk assessment policy and guidance (USEPA, 1992; 1996b), the Upper
 Hudson HHRA also contains a summary of the results of the Kimbrough et al. (1999a) study and the
 USEPA's preliminary analysis of the data and its effect on the characterization of the carcinogenicity of
 PCBs (see. Upper Hudson HHRA, USEPA, 1999b, pp C2-C3). USEPA has not developed a new CSF for
 PCBs based on the Kimbrough et al. (1999a) study or any of the other human epidemiological studies
 because of their inadequacies and limitations as described in the IRIS file. Complete details of USEPA's
 review and critique of the numerous human epidemiology studies for PCBs are presented in USEPA's
 IRIS file for PCBs and the USEPA  1996 PCB cancer reassessment document (USEPA, 1999h; USEPA,
 1996b).

 Response to HS-1.13

        In the Mid-Hudson HHRA, USEPA used the current toxicity values in IRIS. As mentioned in
 Chapter 3 of the Mid-Hudson HHRA (USEPA, 1999a,  p. 18), the Upper Hudson  HHRA provides  an
 overall discussion on the toxicity of PCBs and identifies some additional information available since
 USEPA last reassessed cancer toxicity and non-cancer toxicity. In particular, the Upper Hudson HHRA
 noted the two studies (i.e., Arnold et al., 1995; Rice, 1999) that were mentioned by the commenter (see.
 Upper Hudson HHRA, USEPA, 1999b, pp. 76-77 and C-4 to C-6).  The USEPA is currently reassessing
 the non-cancer toxicity values for PCBs on an Agency-wide basis, with the results of this reassessment
 expected in 2001.  This reassessment will evaluate the studies mentioned in the comment along with the
 other available human and animal studies, evaluate the appropriate application of uncertainty factors, and
 determine whether the RfDs require modification.

        3.1    Non-cancer Toxicity Values

 Response to HS-1.14

        As mentioned in Chapter 3 of the Mid-Hudson HHRA (USEPA, 1999a, p. 18), the critical
 studies, critical effects, and uncertainty factors for the  RfDs for Aroclor 1016 and Aroclor 1254 are
 discussed in the Upper Hudson HHRA (see, USEPA, 1999b, pp. 62 and C5-C6).

Response to HS-1.15

        The Mid-Hudson HHRA did not include a Toxicological Profile for PCBs, but referenced the
 Toxicological Profile in the Upper Hudson  HHRA Appendix C  (USEPA, 1999b).  This comment
 regarding information in the Toxicological Profile  in the  Upper Hudson HHRA (Appendix  C) was
 addressed in the Responsiveness Summary for the Upper Hudson HHRA (USEPA, 2000a).

        In the Upper  Hudson HHRA, USEPA used the current toxicity values in IRIS.  The Upper
 Hudson HHRA provides an overall discussion on the toxicity of PCBs and  identifies some additional
 information available  since USEPA last reassessed cancer toxicity  in 1996 and non-cancer toxicity in
 1992 and 1994 (USEPA, 1999f-h).  USEPA is currently reassessing the non-cancer toxicity values for
 PCBs on an Agency-wide basis, with completion  expected in 2001. PCB non-cancer toxicity and
 carcinogenicity is recognized as an  area of widespread research, and many articles  on PCB non-cancer
 toxicity and carcinogenicity have been published recently.  Nonetheless, it is beyond the scope of the
 HHRAs for the Hudson River PCBs site to present a detailed evaluation of  all the available scientific
 literature on PCBs, particularly in view of ongoing Agency-wide reassessment of the non-cancer toxicity
 values.  However, USEPA is continually reviewing and evaluating new studies and research as they are
 published. The comment regarding the Lanting/Patandin studies is acknowledged.

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Response to HG-1.11

       Consistent with the hierarchy of toxicity information recommended in USEPA risk assessment
guidance (USEPA, 1989b),  USEPA used the current toxicity values from IRIS in  the Mid-Hudson
HHRA. USEPA is currently reassessing the non-cancer toxicity values for PCBs on an Agency-wide
basis, with the results of this reassessment expected in 2001.  This reassessment will evaluate the studies
mentioned  in the comment along with the other available human  and animal studies, evaluate the
appropriate application of uncertainty factors, and determine whether the RfDs require modification.

       As  discussed  in the  Responsiveness Summary for the HHRA Scope of Work (USEPA, 1999d,
pp. 26-27),  the health effects in Rhesus monkeys (used as the basis for USEPA's RfD for Aroclor 1254)
are relevant to assessing human noncancer risks.  Today, similar tests to determine serum IgG and IgM
levels are widely used in hospitals and clinical laboratories to diagnose immune deficiencies in suspected
immune-compromised patients  (Bakerman, 1994, ABC's of  Interpretative Laboratory  Data, 3rd edition,
Interpretive Laboratory  Data, New York). Animal or  human IgG and IgM antibody responses to sheep
red blood  cells or  similar  multi-antigens  systems are  routinely and  widely used  in  defining
immunocompromised diseases.   In addition, the toxicology research community,  as evidenced by
presentations and audience attendance at immunotoxicology sessions of the annual Society of Toxicology
meetings, has expanded its presentations and acceptance of immunotoxicology papers that use similar
methods from a wide variety of animal research  studies (e.g., Proceedings of the Society of Toxicology
Meeting, New Orleans, LA, March, 1999).

       The fact that the dermal and ocular effects observed in Rhesus monkeys have not been observed
in humans may be due to the well-controlled dosing of the monkeys, whereas the exposure in the human
epidemic-logical studies is not well characterized.   With regard to metabolism  of PCBs in Rhesus
monkeys and humans, USEPA notes that slight differences in metabolic processes have been observed by
one research group, but that differences in the critical adverse effects  have not been demonstrated by
other research groups.

Response to HG-1.12

       USEPA did not conduct a Monte Carlo Analysis for the Mid-Hudson HHRA (see responses to
HG-1.4, HG-1.16).  Regardless, had a Monte Carlo analysis been performed, at present it is  USEPA
policy to perform a Monte Carlo analysis using distributions only for exposure parameters,  while using
IRIS values for toxicity parameters (USEPA, 1997b).  This approach is consistent with other risk
assessments performed  by USEPA for other sites as the Agency continues to evaluate  the science
associated with developing distributions for toxicity values.

       The USEPA RfD values were derived to be protective of human health. Uncertainties associated
with non-cancer toxicity values  were qualitatively addressed in the Upper Hudson HHRA in the Toxicity
Assessment (see. Upper Hudson HHRA, USEPA, 1999b, pp. 61-62 and 65-66), the uncertainty section of
the risk characterization (see. Upper Hudson HHRA, USEPA, 1999b, pp. 35 and 76-77), and Appendix
C: PCB Toxicological Profile (see. Upper Hudson  HHRA, USEPA, 1999b, p. C-5). Uncertainties in the
non-cancer toxicity values could result in an over- or under-estimation of non-cancer hazards.
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       3.2    PCB Cancer Toxicity

              Response to HS-1.12

       In the Mid-Hudson HHRA, USEPA selected cancer slope factors based on the environmental
medium being evaluated, which is consistent with IRIS and current USEPA guidance (USEPA, 1996b;
USEPA, 1999 f-h). The IRIS file recommends using congener analyses to identify PCB mixtures where
congeners with more than 4 chlorines comprise less than one-half percent of the total PCBs (which is not
applicable in the Upper or Mid-Hudson River) or to conduct a supplemental analysis of dioxin TEQs
(which was performed in the Upper Hudson HHRA) (see, USEPA, 1999b, pp. 69-70).

4.     RISK CHARACTERIZATION

Response to HS-1.10. HP-3.10

       The modeled PCB concentrations, by species and location, are shown in Figures 2-1 through 2-
10. Consistent with USEPA guidance, the Mid-Hudson HHRA calculated cancer risks and non-cancer
hazards using site-specific information rather than comparing the modeled future fish concentrations to
the U.S. Food and Drug Administration (FDA) tolerance level of 2 ppm PCB in fish and shellfish (edible
portion) shipped in interstate commerce.  A discussion of the FDA tolerance level and its limitations is
presented in Appendix C of the Upper Hudson HHRA (USEPA, 1999b, p. C-7).

       The FDA tolerance level for PCBs in fish was based on weighing the results of a risk assessment
against the magnitude of potential  food loss resulting from a lowered tolerance level.   The FDA risk
assessment was performed assuming that the tolerance level of 2 ppm would be the  maximum PCB
concentration encountered  by  a frequent  commercial fish consumer, and that PCB concentrations in
commercial fish consumed would be distributed below 2 ppm in a manner reflecting a mix of fish from
diverse sources. This methodology precludes application of the FDA tolerance level to the Mid-Hudson
HHRA for fish ingestion. The FDA specifically states that the tolerance level is intended to apply to fish
entering interstate commerce,  and  that this level may  not be protective for locally caught fish from
contaminated areas.  Note that the FS will  contain a discussion  and  determination of applicable or
relevant and appropriate requirements of federal and state environmental laws.

Response to HG-1.1

       The Mid-Hudson HHRA found cancer risks and non-cancer hazards for recreational (wading and
swimming) and residential  (consuming river water) exposure pathways to be below levels of concern.
However,  the cancer risks and non-cancer hazards presented for ingestion of fish, for both the central
tendency (average fish consumption rate) and the high-end  estimate, are above  USEPA's levels of
concern (see, Mid-Hudson HHRA revisions, Section ffl of this report).

       Consistent with the NCP (USEPA 1990) and USEPA policy and guidance (USEPA, 1989a,
1989b, 1991a, 1992, 1995, 1996a, and  1997a), the exposure parameters used in the Mid-Hudson HHRA
are appropriately  protective  of human  health and do  not reflect "a combination  of unrealistic
circumstances," as claimed by the commenter. Specifically, USEPA evaluated both high-end (RME) and
central tendency exposure (average) cancer risks and non-cancer hazards in the Mid-Hudson HHRA.
The RME is not a worst case scenario and  is  reasonable because it is a product  of factors, such as
concentrations (e.g., fish, sediment, and surface water) and exposure frequency and duration, that are an
appropriate mix of values that reflect averages and high-end distributions (USEPA,  1989a,  1989b,
1990b).
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       In the Mid-Hudson HHRA, it was not assumed, as claimed in the comment, that anglers ate the
same species of fish (eel and carp) from the same part of the river.  The cancer risks and non-cancer
hazard assessment for ingestion of fish, for the high-end estimate, assume consumption of a number of
different fish species (only 2.5% eel and 5.9% carp).  In addition, PCB concentrations were averaged
over all locations in the Mid-Hudson, assuming a uniform likelihood of fishing at any location within the
Mid-Hudson River (Mid-Hudson HHRA, p. 9).

       4.1     Non-cancer Hazard Indices

       No significant comments were received on Section 4.1.

       4.2     Cancer Risks

Response to HS-1.6

       The statements in the Mid-Hudson HHRA regarding the acceptable risk range are drawn from the
NCP  which  states, "For  known or  suspected carcinogens, acceptable  exposure levels are generally
concentration levels that represent an excess upper bound lifetime cancer risk to an individual of between
10"4 and 10"6 using information on the relationship between dose and response" (USEPA, 1990).

Response to HG-1.13

       USEPA performed a preliminary review of the Kimbrough et al. (1999a) study and identified
aspects of the study (discussed in the Upper Hudson HHRA, USEPA, 1999b, pp. C2-C3) that limit its
usefulness for Superfund risk assessments. The primary limitation,  which is shared by other similar
epidemiological studies, is that the degree of exposure is not well characterized. Other  scientists have
identified this and other  limitations of the Kimbrough et al. (1999a)  study (see.  Bove et al., 1999;
Frumkin and Orris, 1999, see also Kimbrough et al.,  1999b).

       Based on the  limitations of the Kimbrough et al. (1999a) study, USEPA expects that the study
will not  provide sufficient information to change  the Agency's conclusions regarding the weight of
evidence of the human PCB data or the health effects of PCBs in general. For these reasons, in the Mid-
Hudson HHRA, USEPA  used the IRIS cancer slope factors and did not attempt to develop new cancer
slope factors based on the Kimbrough et al. (1999a) study.
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Risk Assessment
    Revision

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 III.   RISK ASSESSMENT REVISIONS

 1. SUMMARY

       This section of the Responsiveness Summary presents the revised baseline Human Health
 Risk Assessment results for the Mid-Hudson River (Mid-Hudson HHRA). The revision reflects
 sediment, water column, and  bioaccumulation modeling  as summarized  in  the  Baseline
 Ecological  Risk Assessment for Future Risks in the Lower Hudson River (ERA Addendum,
 USEPA, 1999c) and the Responsiveness Summary for the ERA Addendum (USEPA, 2000d),
 which in turn result from the revised PCS boundary load into the Lower Hudson River that was
 presented in the Revised Baseline Modeling Report (RBMR) (USEPA, 2000b). This section also
 compares the revised cancer risks and non-cancer hazards and associated conclusions with those
 of the December 1999 Mid-Hudson HHRA.

       The overall conclusions from the December 1999 Mid-Hudson HHRA (USEPA,  1999a)
 remain unchanged.  The revised calculations for the Mid-Hudson HHRA show that cancer risks
 and non-cancer health hazards to the reasonably maximally  exposed (RME) and central tendency
 (CT) individuals associated with ingestion of PCBs in fish from the Mid-Hudson River are above
 USEPA levels of concern.  In addition, fish ingestion represents the primary pathway for PCB
 exposure and for potential  adverse health effects,  whereas the risks and hazards from other
 exposure pathways are below levels of USEPA concern.

       1.1    Introduction

       Part in of this Responsiveness Summary  summarizes  the  modifications made to  the
exposure parameter estimates and presents the results of the revised risk calculations for the Mid-
Hudson HHRA. All tables and figures contained in the December 1999 Mid-Hudson HHRA are
presented herein. Those tables and figures that were modified are  labeled "Revised," whereas
 those with no changes are labeled "Unchanged." To facilitate in the ease of comparing revised
 results  with the December  1999 Mid-Hudson HHRA results (USEPA,  1999a), all tables and
 figures have retained their number designations.

       1.2    Revisions to Exposure Parameter Estimates

       The only exposure parameter modifications made were to the fish, sediment, and river
water exposure  point concentrations (EPCs).   The revised EPCs were calculated  using  the
forecasts from the revised bioaccumulation and fate and transport models, as presented in the
ERA Addendum (USEPA,  1999c) and the Responsiveness Summary for the ERA Addendum
(USEPA, 2000d).  The revised model forecasts were based on revised PCB loads to the Lower
Hudson as summarized in the RBMR (USEPA, 2000b).

       In addition, to estimate  cancer risks and non-cancer hazards to children for the fish
ingestion pathway, USEPA has added separate calculations for a young child and an adolescent,
based on age-appropriate ingestion rates and body weights.
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              1.2.1  Fish

       Revised Tri+ PCB annual averages for brown bullhead, yellow perch, largemouth bass,
 striped bass, and white perch are summarized in the Responsiveness Summary for the ERA
 Addendum (USEPA, 2000d). Consistent with the December 1999 Mid-Hudson HHRA, EPCs
 were calculated for the adult angler by species-weighting and averaging the forecasted fish
 concentrations over river mile segment and exposure duration. A comparison of the revised fish
 EPCs to the December 1999 EPCs is shown in the box below.  In general, the revised forecast
 PCB concentrations in the largemouth bass,  striped bass, and  white  perch declined from  the
 earlier results, while the concentration in brown bullhead and yellow perch increased.  When
 averaged over the three locations, the RME concentration increase is approximately 1.5-fold for
 brown bullhead and 1.1-fold for yellow perch. The RME concentration for largemouth bass,
 striped bass, and white perch decreased by 5%, 14%, and 7%, respectively.  The species weighted
 RME (40-year) concentration hi fish increases from 0.8 mg/kg in the 1999 Mid-Hudson HHRA,
 to 1.0 mg/kg, approximately a 1.25-fold increase. A discussion of the reasons for the change in
 the forecasts is provided in  the Responsiveness Summary for the ERA  Addendum (USEPA,
 2000d).

             Comparison of 1999 and Revised PCB Concentration in Fish (mg/kg)
                   Reasonable Maximum Exposure (RME) Over 40 Years

Fish
Brown Bullhead
Yellow Perch
Largemouth Bass
Striped Bass
White Perch1
River Mile 152
1999
0.96
0.38
1.4
3.6
NA
Revised
1.4
0.45
1.0
2.6
NA
River Mile 113
1999
0.79
0.31
1.1
0.56
NA
Revised
1.2
0.33
0.90
0.47
NA
River Mile 90
1999
0.61
0.24
0.26
0.13
NA
Revised
0.89
0.25
0.68
0.35
NA
RME Average Over
3 Locations2
1999
0.79
0.31
0.92
1.4
0.61
Revised
1.2
0.34
0.87
1.2
0.57
   ' White Perch were modeled over the entire Mid-Hudson region in the Farley model; thus, concentrations were not
     predicted at specific River Miles.
   2 As summarized in Table 2-8.

             1.2.2   Sediment and River Water

       The Responsiveness Summary for the  ERA Addendum provides revised forecasts of
Total PCB  annual averages in sediment and river water for the Mid-Hudson River (USEPA,
2000d). As was the case for the Upper Hudson HHRA, the modeled sediment and river water
data assumed a constant upstream boundary condition of  10 ng/L.  PCB  concentrations in
sediment and river water were forecast through the year 2046. The EPCs were  calculated by
averaging the forecasted results over the appropriate exposure durations for adult, adolescent, and
child (i.e. for the cancer assessment: 22,  12, and 6 years, respectively;  and for the non-cancer
assessment: 7,7, and 6 years, respectively).

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       Revised sediment EPCs  were approximately 1.1-fold higher than the December 1999
EPCs.  Revised river water EPCs were approximately the same for central estimate EPCs,
whereas the corresponding revised RME values were approximately 1.1-fold lower than the 1999
results.

2.  RESULTS

       For known or suspected carcinogens, such as  PCBs, acceptable exposure levels  for
Superfund are generally concentration levels that represent an incremental upper bound lifetime
cancer risk to an RME individual of between 10"4 and 10~6 (USEPA, 1990).  Central tendency
cancer risks are provided to more fully describe the health  effects associated with average
exposure.

      For an individual consuming fish, the RME estimate of the increased risk of an individual
(as child, adolescent then adult) developing cancer averaged over a lifetime is about 7 x 10"4, or
seven additional cancers in 10,000 exposed people.  This risk is 700 times USEPA's goal of
protection and 7 times greater than the highest risk level generally allowed  under the federal
Superfund program.  The central tendency (average) estimate  of risk is  about 1 x 10"5, or one
additional cancer in 100,000 exposed people.

      For an adult consuming fish, the RME estimate of the increased risk of an individual
developing cancer averaged over a lifetime is about 3 x 10"4, or three additional cancers in 10,000
exposed people.  The central tendency (average) estimate of risk is about 6 x 10"6,  or  six
additional cancers in 1,000,000 exposed people.

      For an adolescent  consuming  fish,  the  RME  estimate  of the  increased risk of an
individual developing cancer averaged over a lifetime is about 2 x 10"4, or two additional cancers
in 10,000 exposed people.  The central tendency (average) estimate of risk is about 3 x 10"6, or
three additional cancers in 1,000,000 exposed people.

      For a child consuming fish, the RME cancer risk estimate is about 2 x lO^or 2 additional
cancers in 10,000 exposed children.   The central tendency (average) estimate of risk is about
5 x 10"6 or 5 additional cancers in 1,000,000 exposed children.

      Estimated cancer risks relating to PCS exposure in sediment and water while swimming
or wading, or from consumption of PCBs in drinking water by residents living near the river, are
lower than those for fish ingestion, falling generally at the low end, or below, the range of 10"4 to
10"6. A summary of the cancer risk calculations is  presented below.
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                                 Cancer Risk Summary
Pathway
Ingestionof Fish
Total*
Adult
Adolescent
Child
Swimming/Wading Exposure
to Sediment*
Swimming/Wading Exposure
to Water*
Consumption of Drinking
Water*
Central Tendency Risk
1 x 10'5 (1 in 100,000)
6 x 10'6 (6 in 1,000,000)
3 x 10'6 (3 in 1,000,000)
5 x 10'6 (5 in 1,000,000)
2 x 10'8 (2 in 100,000,000)
9 x 10'9 (9 in 1,000,000,000)
2 x 10* (2 in 100,000,000)
RMERisk
7 xlO4 (7 in 10,000)
3 x JO"4 (3 in 10,000)
2 x 10"4 (2 in 10,000)
2 x Iff* (2 in 10,000)
2 x 10'7 (2 in 10,000,000)
5 x 1Q-8 (5 in 100,000,000)
1 x 10'7 (1 in 10,000,000)
     Total risk for child (aged 1-6), adolescent (aged 7-18), and adult (over 18).

       The  evaluation of non-cancer health effects  involved  comparing  the  average  daily
exposure levels (dose) to determine whether the estimated exposures exceed the Reference Dose
(RfD).  The ratio of the site-specific calculated dose to the RfD for each exposure pathway is
summed to calculate the Hazard Index (HI) for the exposed individual. An HI of one (1) is the
reference level established by USEPA above which concerns about non-cancer health effects
must be evaluated.

       Adult ingestion of fish resulted in a Hazard Index (HI) of about 32 for  the RME exposure
and an HI of about 3 for the central tendency exposure.  Adolescent ingestion of fish resulted in
an HI of about 35 for the RME and an HI of about 4 for the central tendency exposure.  Child
ingestion of fish resulted in an HI about 49 for the RME exposure and an HI of about 5 for the
central tendency exposure.

       The total His for exposure to sediment and water are all below one.  A summary of the
estimate for non-cancer hazards is presented below.

                                Non-Cancer Hazard Summary
Pathway
Ingestion of Fish
Adult
Adolescent
Child
Exposure to Sediment*
Exposure to Water*
Consumption of Drinking
Water*
Centra] Tendency Non-Cancer
Hazard Index
3
4
5
0.002
0.005
0.01
RME Non-Cancer
Hazard Index
32
35
49
0.004
0.007
0.02
    * Values for child and adolescent, which are higher than adult for these pathways.
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       2.1   Comparison/Discussion

       This revised Mid-Hudson HHRA provides separate cancer risk estimates for children
(young  child aged  1-6 and adolescent  aged 7 to  18) based  on age-appropriate exposure
assumptions for ingestion rate and body weight. Previously, in the December 1999 Mid-Hudson
HHRA, USEPA approximated the risk to a young child based on a fish meal size of 1/3 the adult
portion.

       Compared to the RME cancer risk for the adult ingesting fish that was presented in the
1999 Mid-Hudson HHRA (4 x 10"4), the revised cancer risks for total RME  (child, adolescent,
then adult) ingesting fish, the pathway with the highest risks, increased approximately 1.75-fold,
to 7 x 10"4.  The  revised RME non-cancer hazard index for an  adult ingesting fish increased
approximately 1.1-fold, to 32 compared to 30 in the  1999 Mid-Hudson HHRA.  This modest
increase in the risk assessment results does not alter the overall conclusions for the Mid-Hudson
River.  That is, the revised results indicate that cancer risks and non-cancer health hazards to the
RME individual associated with ingestion of PCBs in fish from the Mid-Hudson River are above
USEPA levels of concern for both cancer risks and non-cancer health hazards.

      The calculations show that a child consuming fish from the Mid-Hudson River would be
exposed to PCBs  above USEPA's levels of  concern.  Eating one approximately 3  ounce fish
meal per  week (RME  exposure) would  increase  a child's risk of cancer  by 2 x  10"* (two
additional cancers in 10,000 exposed children), which is about 200 times greater than USEPA's
goal for protection.  The same ingestion  rate yields an HI for non-cancer health effects  of 49,
which is 49  times greater than USEPA's level of concern. A child eating one approximately 3
ounce fish meal every two months  (central tendency, or average exposure) would result in an
increased cancer risk of 5 x 10"6, which  is 5 times greater than  USEPA's goal for  protection.
This child's  fish ingestion rate would result in an HI of non-cancer health effects that is 5 times
greater than  USEPA's goal for protection. The risks and hazards for children exposed to PCBs
from other pathways (swimming, wading, and drinking river water) are below USEPA's levels of
concern.

      In summary, the revised Mid-Hudson  HHRA indicates that fish ingestion represents the
primary pathway for children, adolescents, and adults to be exposed to  PCBs and  experience
potential adverse health effects, whereas cancer risks and non-cancer hazards from exposure to
PCBs through other exposure pathways are below USEPA levels of concern.
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2F - Upper Hudson Human Health Risk Assessment, Hudson River PCBs Reassessment RI/FS.
Developed for the USEPA and U.S. Army Corps  of Engineers by  TAMS Consultants and
Gradient Corporation. USEPA, Region n, New York, New York. March.

U.S. Environmental Protection Agency (USEPA).  2000b.  Volume 2D - Revised Baseline
Modeling Report, Hudson River PCBs Reassessment RFFS. Developed for the USEPA and U.S.
Army Corps of Engineers by Limno-Tech, Inc., Menzie Cura & Associates, Inc. and Tetra-Tech,
Inc. USEPA, Region H, New York, New York.

U.S. Environmental Protection Agency (USEPA).  2000c.  Responsiveness Summary for the
Revised Baseline Modeling Report, Hudson River PCBs Reassessment RI/FS. Developed for the
USEPA and U.S. Army Corps of Engineers by Limno-Tech, Inc., Menzie Cura & Associates,
Inc. and Tetra-Tech, Inc. USEPA, Region n, New York, New York.

U.S. Environmental Protection Agency (USEPA).  2000d.  Responsiveness Summary for the
Baseline Ecological Risk Assessment for Future Risks in the Lower Hudson River, Hudson River
PCBs Reassessment RI/FS. Developed for the USEPA and U.S. Army Corps of Engineers by
Limno-Tech, Inc., Menzie Cura & Associates, Inc. and Tetra-Tech, Inc. USEPA, Region n, New
York, New York.
                                                                 TAMS/Gradicn: Corporation
                                       35

-------
THIS PAGE LEFT INTENTIONALLY BLANK.
                                       TMAS/Gradicnl Corporation
                 36

-------
                                                                                     TABLE 2-1 (Revised)
                                                                 SELECTION OF EXPOSURE PATHWAYS - Phase 2 Risk Assessment
                                                                                     MID-HUDSON RIVER
Scenario
Timeframe
Current/Future













Source
Medium
Fish

Sediment




River Water




Home-grown
Crops
Beet


Dairy Products


Exposure
Medium
Fish

Sediment




Drinking Water
River Water
Outdoor Air




Vegetables
Beet


Mfeeggs


Exposure
Point
Mid-Hudson Fish

Banks ol Mid-Hudson




Mid-Hudson River
Mid-Hudson River
(vradngfewlfnfning)
Mid Hudson River (River
and near vicinity)




Mid-Hudson vicinity
Mid-Hudson vicinity


Mid-Hudson vicinity


Receptor
Population
Angler

Recreate*




Resident
Recreator
Recreator


Resident


RosldBnt
Resident


Resident


Rscoplor
Age
Adult
Child
Adult
Adolescent

Child

Adult
Child
Adult
Child
Adult
Adolescent
Child
Adult
Adolescen
Child
Adult
Child
Adult
Adolescen
Chid
Adult
Adolescen
Child
Exposure
Route
Ingestlon
Ingestlon
Ingestlon
Ingestlon
Dermal
Ingesllon
Dermal
Ingesllon
Dermal
Ingestlon
Ingesllon
Ingestlon
Dermal
Dermal
Dermal
Inti&labon
Inhalation
Inhalation
Inhalation
Inhalation
Inhalotlon
Ingestlon
Ingesllon
Ingestlon
Ingesuon
Ingestlon
Ingesllon
Ingesllon
Ingestion
Ingestlon
On-Slle/
Ofl-ate
On-Site
On-Site
On-ate
On-Slte
On-Slle
On-Sile
On-Site
On-Slte
On-Site
On-Site
On-Sile
On-Sila
On-Site
On-Slte
On-Slte
On-Slte
On-Slte
On-Sile
On-Slte
On-Slle
On-Sile
On-Sile
On-Slte
On-Site
On-Slte
On-Slle
On-Slte
On-Site
On-Site
On-Slte
Type of
Analysis
Quant
Quant
Quant
Quant
Quant
Quant
Quant
Quanl
Quant
Quant
Quant
Quant
Quant
Quant
Quant
Qua!
dual
dual
Qual
Qua!
Qual
Qual
Qual
Qual
Qual
Qual
Dual
Qual
Qual
Qua!
Rationale lor Selection or Exclusion
of Exposure Pathway



Racrealors may Ingest or otherwise come hi contact with contaminated nver
sediment while engaging in activities along the nver




Considered In Phase I Risk Assessment and determined to have de mlnlmis
risk. Included lo address pubic concerns
Recreators may come In contact with contaminated river water while wading
or swimming
Considered In Phase 2 Upper Hudson River HHRA and determined to have
Insignificant risk. Concentrations In Upper Hudson River approximately lour
times higher man Mid-Hudson region, therefore, not evaluated lurther in Oils
HHRA.


Considered In Phase 2 Upper Hudson River HHRA and determined to have
insignificant risk. Concentrations In Upper Hudson River approximately four
limes higher then Mid-Hudson region, therefore, not evaluated further In this
HHRA


Llmitad data, studies show tow PCB uptake In forage crops Qualitatively
assessed In Upper Hudson River HHRA
Limited data, studies show non-detect PCB levels In cow's mdk In NY
Qualitatively assessed In Upper Hudson River HHRA.


Limited data, studies show non-detect PCB levels In cow's mOk n NY
Qualtattvely assessed In Upper Hudson River HHRA.


•Quanr = Quantitative risk analysis performed 'Qua!' = Qualitative analysis performed
                                                                                                                                                                                   TAMS/ Gradient Corporation

-------
                                                                                                TABLE 2-2 (Revised)
                                                                 OCCURRENCE. DISTRIBUTION AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN
                                                                                             MO-HUDSON RIVER - Fish



CAS
Number

1336-36-3
Scenario Tlmeframe Current/Future
Medium. Fish
Exposure Medium Fish
Exposure Point Mid-Hudson Fish

Chemical


PCBs (3)
(D
Minimum
Concentration

021

Mmunum
Qualifier

N/A



(1)
Maximum
Concentration

23

Manniurn
Qualifier

N/A
Urals


mg/kgwet
weight
Location
of Maximum
Concentration
N/A
Detection
Frequency

N/A
Range of
Detection
Limits
N/A
Concentration
Used lor
Screening
N/A

Background
Value

N/A

ScrGSfUllQ
Toxioly Value

N/A
Potential
ARAfVTBC
Value
N/A

Potential
ARAR/TBC
Source
N/A

COPC
Rag

Ves
(2)
Rationale for
Contaminant
Deletion
or Selection
FD.TX.ASL
(1)  Minimum/maximum modeled concentration between 1999-2046 (USEPA, 2000)
(2)  Rationale Codes   Selection Reason     Infrequent Detection but Associated Historically (HIST)
                                       Frequent Detection (FD)
                                       Toxoly Information Available (TX)
                                       Above Screening Levels (ASL)
                    Deletion Reason     Infrequent Detection (IFD)
                                       Background Levels (BKG)
                                       No Toxicrty Information (NTX)
                                       Essential Nulnenl (NUT)
                                       Below Screening Level (BSL)
(3)  Occurrence and distnbution ol PCBs In fish were modeled, not measured (USEPA, 2000)
Definitions:    N/A = Not Applicable
             SQL = Sample Ouantitation Limit
             COPC = Chemical of Potential Concern
             ARAfVTBC - Applicable or Ffelevant and Appropriate Requirement/To Be Considered
             MCL = Federal Maximum Contaminant Level
             SMCL = Secondary Maximum Contaminant Level
             J - Estimated Value
             C = Carcinogenic
             N = Non-Carcinogenic
                                                                                                                                                                                     TAMS/ GnJiau Corporation

-------
                                                                                                TABLE 2-3 (Revised)
                                                                OCCURRENCE. DISTRIBUTION AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN
                                                                                           MID-HUDSON RIVER - Sediment



CAS
Number

1336-36-3
Scenario Timeframe. Current/Future
Medium: Sediment
Exposure Medium. Sediment
exposure Point Banks ol Mid-Hudson

Chemical


PCBs (3)

(D
Minimum
Concentration

031
Minimum
Qualifier

N/A



0)
Maximum
Concentration

087

Maximum
Qualifier

N/A

Units


mg/kg

Location
o) Maximum
Concentration
N/A

Detection
Frequency

N/A

Range of
Detection
Limits
N/A

Concentration
Used (or
Screening
N/A
Background
Value

N/A

ScreBning
Torioty Value

N/A
Potential
ARAfVTBC
Value
N/A
Potontial
AHAFVTBC
Source
N/A
COPC
Hag

Yes
(2)
Ratlonalo for
Contaminant
Deletion
or Selection
FD.TX, ASL
(1)  Minimum/maximum segmenl-averaged modeled concentration between 1999-2046 (USEPA. 2000)
(2)  Rationale Codes  Selection Reason-     Infrequent Detection but Associated Historically (HIST)
                                        Frequent Detection (FD)
                                        Toxiaty Information Available (TX)
                                        Above Screening Levels (ASL)
                     Deletion Reason-     Infrequent Detection (IFD)
                                        Background Levels (BKG)
                                        NoToxrcity Information (NTX)
                                        Essential Nutrient (NUT)
                                        Below Screening Level (BSL)
(3)  Occurrence and distribution of PCBs in sediment were modeled, not measured (USEPA, 2000).
Definitions     N/A = Not Appfcable
             SOL = Sample Ouanlitation Limit
             COPC = Chemical of Potential Concern
             ARAH/TBC = Applicable or Relevant and Appropriate Requirement/To Be Considered
             MCL = Federal Maximum Contaminant Level
             SMCL = Secondary Maximum Contaminant Level
             J = Estimated Value
             C = Carcinogenic
             N = Non-Carcinogenic
                                                                                                                                                                                    TAMS/ Gradient Corporation

-------
                                                                                               TABLE 2-4 (Revised)
                                                               OCCURRENCE, DISTRIBUTION AND SELECTION OF CHEMICALS OF POTENTIAL CONCERN
                                                                                         MID-HUDSON RIVER - River Water



CAS
Number

1336-36-3
Scenario Timeframe Current/Future
Medium River Water
Exposure Medium: River Water
Exposure Point Mid-Hudson River

Chemical


PCBS (3)
(D
Minimum
Concentration

3.3E-06
Minimum
Qualifier

N/A



(1)
Maximum
Concentration

19E-05

Moximum
Qualifier

N/A
Units


mg/L
Location
ol Maximum
Concentialion
N/A

Detection
Frequency

N/A
Range of
Detection
Limits
N/A
Concentration
Used for
Screening
N/A
Background
Value

N/A

Screening
Tojddty Value

N/A

Potential
ARAFVTBC
Value
N/A

Potential
ARAR/TBC
Source
N/A
COPC
Flag

Yes
(2)
Rationale for
Contaminant
Deletion
or Selection
FD.TX.ASL
(1)  Minimum/maximum segment-averaged modeled concentration between 1999-2046 (USEPA, 2000).
(2)  Rationale Codes  Selection Reason     Infrequent Detection but Associated Historically (HIST)
                                       Frequent Detection (FD)
                                       Toxraty Information Available (TX)
                                       Above Screening Levels (ASL)
                     Deletion Reason.    Infrequent Detection (IFD)
                                       Background Levels (BKG)
                                       No Toxioty Information (NTX)
                                       Essential Nutrient (NUT)
                                       Below Screening Level (BSL)
(3)  Occurrence and distribution of PCBs tn nver water were modeled, not measured (USEPA, 2000)
Definitions:    N/A = Not Applicable
             SQL = Sample Quantitatlon Limit
             COPC = Chemical of Potential Concern
             ARAH/TBC = Applicable or Relevant and Appropriate Requirement/To Be Considered
             MCL = Federal Maximum Contaminant Level
             SMCL = Secondary Maximum Contaminant Level
             J = Estimated value
             C B Carcmogenic
             N = Non-Carcinogenic
                                                                                                                                                                                   TAMS/ Gradient Corporation

-------
                                              Table 2-5 (Unchanged)
                                    Summary of 1991 New York Angler Survey

Water Body Type/
Species Group
Flowing
Bass
Bullhead
Carp
Catfish
Eel
Perch
Subtotal
Salmon
Trout
Walleye
Other
Total All Fish
Not Flowing
Bass
Bullhead
Carp
Catfish
Eel
Perch
Subtotal
Salmon
Trout
Walleye
Other
Total All Fish
Not Reported
Bass
Bullhead
Carp
Catfish
Eel
Perch
Subtotal
Salmon
Trout
Walleye
Other
Total All Fish
Number
Reporting
Eating Fish

68
23
2
11
4
17

35
130
36
45


154
53
4
10
2
51

55
152
112
94


128
55
5
4
5
24

14
148
34
104


Total Total
Caught Eaten

1,842 584
1,092 558
[b] 90
158 113
38 38
833 139
3,963 1,522
559 193
3,099 1,230
333 134
2,871 1,025
10,825 4,104

3,370 1,032
1,200 634
7 29
46 46
2 3
2,289 816
6,914 2,560
538 480
2,428 1,400
2,292 1,054
5,976 2,125
18,148 7,619

4,006 1,110
2,374 1.099
16 11
40 17
9 13
338 222
6,783 2,472
139 120
2,836 1,319
389 206
7,731 2,559
17,878 6,676
Average
Number
Eaten"*1

8.6
24.3
45.0
10.3
9.5
8.2

5.5
9.5
3.7
22.8


6.7
12.0
7.3
4.6
1.5
16.0

8.7
9.2
9.4
22.6


8.7
20.0
2.2
4.3
2.6
9.3

8.6
8.9
6.1
24.6


Standard
Deviation1"

19.2
61.9
42.4
15.5
10.6
12.5

5.3
15.7
4.2
50.1


12.0
21.5
6.7
6.9
0.7
32.4

15.2
18.3
14.2
58.1


17.0
43.2
1.6
2.8
2.5
21.7

7.3
16.8
8.8
722

Maximum
Number
Eaten

145
300
75
50
25
51

25
133
20
200


100
100
14
20
2
200

80
150
75
403


100
225
5
7
7
100

20
157
40
630

Percent of
Hudson
Species

38.4%
36.7%
5.9%
7.4%
2.5%
9.1%
100%






40%
25%
1.1%
1.8%
0.1%
32%
100%






45%
44%
0.4%
0.7%
0.5%
9%
100%






Percent of
All Fish

14%
14%
2%
3%
0.9%
3%
37%
5%
30%
3%
25%
100%

14%
8%
0.4%
0.6%
0.04%
11%
34%
6%
18%
14%
28%
100%

17%
16%
0.2%
0.3%
0.2%
3%
37%
2%
20%
3%
38%
100%
Notes:

 '"' Mean and Standard Deviation are over number of anglers reporting they ate particular species.
 w Number caught not reported.

   Modeled PCB concentration estimates are available for species in Bold
   Source:  Connelly et al. (1992)
                                                                                         TAMS/ Gradient Corporation

-------
                                  Table 2-6 (Unchanged)
                             Mid-Hudson River Perch and Bass
Species
Perch
Bass
Species
Intake'
9%
38%
Mid-Hudson Species
White Perch
Yellow Perch
Largemouth Bass
Slnped Bass
Relative Percentage
Species Caught''
85%
15%
40%
60%
Relative Percentage
Species Intake
7.6%
1.4%
15%
23%
' From 1991 New York Angler Survey, see Table 2-5.
1 From 1991/92 and 1996 NYSDOH study of Hudson River anglers (NYSDOH. 1999).

-------
                                              Table 2-7 (Unchanged)
                                         Species-Group Intake Percentages
Group 1
Brown bullhead 36.7%
Carp 5.9%
Catfish 7.4%
Eel 2.5%
Spedes Group Totals 53%
Group 2
White Perch 7.6%
7.6%
GroupS
Yellow Perch 1 .4%
1.4%
Group 4
Largemouth Bass 15%
15%
GroupS
Striped Bass 23%
23%
Sources'
1991 New York Angler Survey (Connelly et al, 1992)
1991/92 and 1996 NYSDOH study of Hudson River anglers (NYSDOH, 1999).
                                                                                              TAMS/ Gradient Corporation

-------
                                                                                             TABLE 2-8 (Revised)
                                                                  MEDIUM-SPECIFIC MODELED EXPOSURE POINT CONCENTRATION SUMMARY
                                                                                          MID-HUDSON RIVER FISH





Chemical
of
Potential
Concern

PCBs

in Brawn Bullhead

in Yellow Perch

in Largemoutti Bass

in Striped Bass

in White Perch

Species-weighted lor adult exposure (1)

SoGciGs-wsiohlod lor odolGSCCnt oxposuro 0)

Species-weighted lor child exposure (1)


Species-weighted lor chronic exposure (2)
Scenario Timeframe. Current/Future
Medium Fish
Exposure Medium Fish
Exposure Point Mid-Hudson Fish

Units





nig/kg wet
weight
mg/kgwet
weight
mg/kgwet
weight
mg/kgwet
weight
mg/kgwet
weight
mg/kgwet
weight
mg/kgwet
weight
mg/kgwet
weight

mg/kgwet
weight

Arithmetic
Mean (3)





1 1

032

082

1 1

053

091

091

091


091

95% UCLot
Normal
Data




••

••

••

••

••

••

••

••




Maximum
Concentration
(3)




16

065

1 7

23

1 4

16

1.6

1 6


1.6
Maximum
Qualifier





N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A


N/A





EPC
Units





mg/kg wet weight

mg/kgwet weight

mg/kg wat weight

mg/kg wet weight

mg/kg wet weight

mg/kg wet weight

mg/kg wet weight

mg/kg wet weight


mg/kg wet weight

Reasonable Maxmum Exposure

Medium
EPC
Value


12

0.34

087

1.2

057

1.1

1 3

1.4


1.4
Medium
EPC
Statistic


Mean-N

Mean-N

Mean-N

Mean-N

Mean-N

Mean-N

Mean-N

Mean-N


Mean-N
Medium
EPC
Rationale

Averaged over RME
ED
Averaged over RME
ED
Averaged over RME
ED
Averaged over RME
ED
Averaged over RME
ED
Averaged over RME
ED
Averaged over RME
ED
Averaged over RME
ED

Averaged over RME
ED
Central Tendency

Medium
EPC
Value


1 4

0.49

1 3

1.7

0.97

1.4

1.5

1.5
dependent
on receptor
(4)
Medium
EPC
Statistic


Mean-N

Mean-N

Mean-N

Mean-N

Mean-N

Mean-N

Mean-N

Mean-N


Mean-N
Medium
EPC
Rationale

Averaged over CT
ED
Averaged over CT
ED
Averaged over CT
ED
Averaged over CT
ED
Averaged over CT
ED
Averaged over CT
ED
Averaged over CT
ED
Averaged over CT
ED

Averaged over CT
ED
Statistics Maximum Detected Value (Max); 95% UCL ot Normal Data (95% UCL-N). 95% UCL of Log-transformed Data (95% UCL-T). Mean ol Log-transformed Data (Mean-T);
            Mean ol Normal Data (Mean-N)
            Not applicable because fish data was modeled, not measured.
ED    =    Exposure Duration
CT    =    Central Tendency
(1)  PCB concentrations for each species were weighted based on species-group Intake percentages (Connelly et al., 1992: NYSDOH, 1999) and averaged over the central tendency adult, adolescent, and child
    exposure durations (6,3. and 3 years, respectively) to calculate the CT EPCs. and over the RME adulL adolescent, and child exposure durations (22,12, and 6 years, respectively) to calculate the RME EPCs for cancer risks.
(2)  PCB concentrations (or each species were weighted based on species-group intake percentages (Connelly et al.. 1992; NYSDOH. 1999) and averaged over 7 years to calculate the RME EPC for non-cancer hazards
(3)  Mean/maximum modeled concentration between 1999-2046 (USEPA, 2000).
(4)  CT EPC for chronic exposure is dependant on exposure duration for each receptor (1 4 mg/kg adult; 1.5 mg/kg adolescent/child).
                                                                                                                                                                               TAMS/ Gradient Corporation

-------
                                                                                TABLE 2-9 (Revised)
                                                       MEDIUM-SPECIFIC MODELED EXPOSURE POINT CONCENTRATION SUMMARY
                                                                           MID-HUDSON RIVER SEDIMENT
                 Scenano Timeframe- Current/Future
                 Medium-  Sediment
                 Exposure Medium. Sediment
                 Exposure Point- Banks of Mid-Hudson
Chemical
of
Potential
Concern

PCBs

Adull

Adolescent

Child
Units




mg/kg






Arithmetic
Mean
0)


04






95% UCLof
Normal
Data


• •






Maximum
Concentration

(1)

0.7






Maximum
Qualifier



N/A






EPC
Units



mg/kg






Reasonable Maximum Exposure (2)

Medium
EPC
Value


053

0.59

0.64
Medium
EPC
Statistic


Mean-N

Mean-N

Mean-N
Medium
EPC
Rationale

Averaged over RME
ED
Averaged over RME
ED
Averaged over RME
ED
Central Tendency (2)

Medium
EPC
Value


0.65

0.66

0.66
Medium
EPC
Statistic


Mean-N

Mean-N

Mean-N
Medium
EPC
Rationale

Averaged over CT
. ED
Averaged over CT
ED
Averaged over CT
ED
Statistics  Maximum Detected Value (Max). 95% UCL ol Normal Data (95% UCL-N), 95% UCL of Log-transformed Data (95% UCL-T); Mean of Log-transformed Data (Mean-T);
            Mean of Normal Data (Mean-N).
            Not applicable because sediment data was modeled, not measured
(1)         Mean/maximum of segment-averaged modeled concentration 1999-2046 (USEPA. 2000)
(2)         EPC values were averaged over 23 yrs RME and 5 yrs CT for adults. 12 yrs RME and 3 yrs CT for adolescents. 6 yrs RME and 3 yrs CT for children, for a total of 41 yrs RME and 11 yrs CT exposure.
                                                                                                                                                     TAMS/ Gradient Corporation

-------
                                                                               TABLE 2-10 (Revised)
                                                      MEDIUM-SPECIFIC MODELED EXPOSURE POINT CONCENTRATION SUMMARY
                                                                            MID-HUDSON RIVER WATER





Chemical
of
Potential
Concern

PCBs

Adult

Adolescent

Chile
Scenario Timelrame- Current/Future
Medium River Water
Exposure Medium- River Water
Exposure Point Mid-Hudson River

Units




mg/L







Arithmetic
Mean
(D


6 4E-06






95% UCLof
Normal
Data


-






Maximum
Concentration

(1)

19E-05











Maximum
Qualifier



N/A






EPC
Units



mg/L







Reasonable Maximum Exposure (2)

Medium
EPC
Value


8 8E-06

1 IE-OS

1 4E-05
Medium
EPC
Statistic


Mean-N

Mean-N

Mean-N
Medium
EPC
Rationale

Averaged over RME
ED
Averaged over RME
ED
Averaged over RME
ED

Central Tendency (2)

Medium
EPC
Value


1.5E-05

1.6E-05

1.6E-05
Medium
EPC
Statistic


Mean-N

Mean-N

Mean-N
Medium
EPC
Rationale

Averaged over CT
ED
Averaged over CT
ED
Averaged over CT
ED
Statistics. Maximum Detected Value (Max). 95% UCL of Normal Data (95% UCL-N). 95% UCL of Log-transformed Data (95% UCL-T). Mean of Log-transformed Data (Mean-T):
            Mean of Normal Data (Mean-N)
            Not applicable because river water data was modeled, not measured
(1)         Mean/maximum of segment-averaged modeled concentration 1999-2046 (USEPA. 2000)
(2)         EPC values were averaged over 23 yrs RME and 5 yrs CT for adults. 12 yrs RME and 3 yrs CT for adolescents; 6 yrs RME and 3 yrs CT for children; for a total of 41 yrs RME and 11 yrs CT exposure.
                                                                                                                                                     TAMS/ Gradient Corporation

-------
                                                         Table 2-11 (Unchanged)
                                       County-to-County In-Migration Data for Albany County, NY

No Move





Move In
Total From
Abroad


Age Group
5 lo 9
10tol4
IS to 19
20 to 24
25 lo 29
30 lo 34
35 to 44
45 to 54
55 to 64
65 to 74
75 to 84
85+






Total

Outside
Region"

Total from
Outside Region"
Domestic





Inside Region
Total


From
Albany Columbia Dutchess
8,638
10,128
11,284
8,012
5,515
8,196
24,243
20,091
20,764
19,380
10,929
3,670
9,002
6,482
9,642
19,788
18,568
17,658
20,419
7,999
4,837
4,189
2,914
1,746
228
226
236
428
640
558
407
277
97
78
22
0
8,774
6,256
9,406
19,360
17,928
17,100
20,012
7,722
4,740
4,111
2,892
1,746
2,318
1,607
4,983
11,201
6,882
5,691
6,094
2,234
1,271
928
653
367
6,456
4,649
4,423
8,159
11,046
11,409
13,918
5,488
3,469
3,183
2,239
1,379
5,795
4,253
3,713
6,188
9,111
10,256
12,533
4,866
3,099
2,867
1,984
1,227
42
28
45
83
143
86
149
36
34
34
16
13
14
21
133
367
94
37
53
27
48
32
0
0


Greene Rensselaer
63
36
64
311
221
149
160
72
62
34
23
22
536
304
428
995
1366
840
980
458
222
179
190
117

Ulster
6
7
40
215
111
41
43
29
4
37
26
0


2,546
1,833
5,219
11,629
7,522
6,249
6,501
2,511
1,368
1,006
675
367
Notes:
          a.     The Mid-Hudson Region consists of Albany, Columbia, Dutchess, Greene, Rensselaer, and Ulster Counties.

                Source: 1990 U.S. Census.
                                                                                                                     TAMS/ Gradient Corporation

-------
                                                        Table 2-12 (Unchanged)
                                     County-to-County In-Migration Data for Columbia County, NY

No Move





Move In
Total From
Abroad


Age Group
5 lo 9
10 to 14
IS to 19
20 to 24
25 to 29
30 to 34
35 to 44
45 to 54
55 to 64
65 to 74
75 to 84
85+






Total

Outside
Region"

Total from
Outside Region*
Domestic





Inside Region
Total


Columbia Albany
2,143
2,399
2,644
1,591
1.242
1,663
6,034
4,979
4.756
4,650
2,721
725
2,284
1,583
1,587
2,024
3,246
3,144
3,896
1,932
1,170
1,075
823
315
91
20
15
44
52
77
84
38
4
3
2
0
2,193
1,563
1,572
1,980
3.194
3,067
3,812
1,894
1,166
1,072
821
315
506
433
539
415
864
922
1,332
622
388
370
192
81
1,687
1,130
1,033
1,565
2,330
2,145
2,480
1,272
778
702
629
234
1,341
900
849
1,314
1,819
1,678
1,859
1,060
674
613
521
182
48
28
31
23
97
80
85
60
34
11
10
6
From




Dutchess Greene Rensselaer Ulster
165
103
44
86
228
217
165
80
25
30
30
5
47
35
48
8
38
48
103
25
19
11
8
15
77
34
41
118
122
91
230
24
16
29
51
17
9
30
20
16
26
31
38
23
10
8
9
9
597
453
554
459
916
999
1,416
660
392
373
194
81
Notes:
      a.        The Mid-Hudson Region consists of Albany, Columbia, Dutchess, Greene, Rensselaer, and Ulster Counties.

                Source: 1990 U.S. Census.
                                                                                                                   TAMS/ Gradient Corporation

-------
                                                         Table 2-13 (Unchanged)
                                      County-to-County In-Migration Data for Dutchess County, NY

No Move





Move In
Total From
Abroad


Age Group
5 to 9
10 to 14
15 to 19
20 to 24
25 to 29
30 to 34
35 to 44
45 to 54
55 to 64
65 to 74
75 to 84
85+



9,052
9,868
10,981
7,992
5,622
8,384
23,706
21,703
17,443
13,686
7.236
2,149



8,557
5,878
7,671
12,027
16,195
15,794
18,091
7,320
4,503
3,394
2,331
889



224
135
347
461
497
409
400
180
98
74
52
0
Total


8,333
5,743
7,324
11,566
15,698
15,385
17,691
7,140
4,405
3,320
2,279
889
Outside
Region"


3,749
2,249
4,313
6,472
7,645
7,156
7,774
2,865
1,885
1,496
984
379
Total from
Outside Region"
Domestic





Inside Region
Total

4,584
3,494
3,011
5,094
8,053
8,229
9,917
4,275
2,520
1,824
1,295
510

Dutchess
4,363
3,367
2,833
4,675
7,221
7,578
9,255
4,049
2,469
1,727
1,220
446

From


Albany Columbia Greene Rensselaer
0
16
24
30
166
144
41
8
0
0
10
0
72
33
40
61
82
90
136
32
9
20
33
0
0
0
9
25
12
2
8
15
5
0
0
0
0
0
25
31
46
13
22
4
2
0
0
0

Ulster
149
78
80
272
526
402
455
167
35
77
32
64


3,973
2,384
4,660
6,933
8,142
7,565
8,174
3,045
1,983
1,570
1,036
379
Notes:
       a.        The Mid-Hudson Region consists of Albany, Columbia. Dutchess, Greene, Rensselaer, and Ulster Counties.

                Source:  1990 U.S. Census.
                                                                                                                     TAMS/ Gradient Corporation

-------
                                                        Table 2-14 (Unchanged)
                                      County-to-County In-Migration Data for Greene County, NY

No Move
Move In
Total From
Abroad


Age Group
5 lo 9
10 to 14
15 to 19
20 to 24
25 to 29
30 to 34
35 to 44
45 to 54
55 to 64
65 to 74
75 to 84
85+



1,491
1,706
1,713
1,229
967
1,216
3,742
3,503
3,195
3,142
1,979
480



1,496
1,074
1.145
1,971
2,594
2,540
2,816
1,228
1,095
813
464
254



20
2
19
57
65
33
21
18
3
3
1
0
Total


1,476
1,072
1,126
1,914
2,529
2,507
2,795
1,210
1,092
810
463
254
Outside
Region"


593
383
495
991
1,165
992
1,109
500
518
356
148
127
Total from
Outside Region"
Domestic

Inside Region
Total

883
689
631
923
1,364
1,515
1,686
710
574
454
315
127
From
Greene
712
571
525
719
1111
1169
1328
503
498
370
279
120
Albany Columbia
120
79
27
81
79
171
137
104
25
43
24
7
1
0
19
31
21
49
53
15
7
17
10
0
Duchess Rensselaer
16
21
20
33
14
57
78
20
16
15
0
0
0
0
5
0
9
12
27
18
0
0
0
0
Ulster
34
18
35
59
130
57
63
50
28
9
2
0

613
385
514
1,048
1,230
1,025
1,130
518
521
359
149
127
Notes:
      a.        The Mid-Hudson Region consists of Albany, Columbia, Dutchess, Greene, Rensselaer, and Ulster Counties.

                Source: 1990 U.S. Census.
                                                                                                                    TAMS/ Gradient Corporation

-------
                                                       Table 2-15 (Unchanged)
                                    County-to-County In-Migration Data for Rensselaer County, NY

No Move





Total From
Abroad


Age Group
5 to 9
10 to 14
15 to 19
20 to 24
25 to 29
30 to 34
35 to 44
45 to 54
55 to 64
65 to 74
75 to 84
85+



5,577
6,155
6,820
4,911
3,763
5,236
14,632
10,930
11,355
10,010
5,613
1,522



4,769
3,608
5,126
8,940
8,867
7,976
9,049
3,214
2,125
1,712
1,146
520



80
73
213
436
435
221
130
40
46
5
7
0
Total


4,689
3,535
4,913
8,504
8,432
7,755
8,919
3,174
2,079
1,707
1,139
520
Outside
Region"


1,046
666
2,304
3,564
2,331
2,053
2,112
685
487
369
190
101
Move In
Total from
Outside Region"
Domestic
Inside Region
Total

3,643
2,869
2,609
4,940
6,101
5,702
6,807
2,489
1,592
1,338
949
419

Rensselaer
2,902
2,283
2,084
3,777
4,713
4,076
5,030
1,951
1,303
1,101
730
328

From




Albany Columbia Duchess Greene Ulster
656
438
368
776
1,211
1,419
1,503
495
264
216
205
75
64
58
46
175
113
139
170
39
10
9
0
9
0
21
33
157
40
42
11
0
2
4
0
0
4
13
47
26
0
14
39
0
0
0
5
0
17
56
31
29
24
12
54
4
13
8
9
7
1,126
739
2,517
4,000
2,766
2,274
2,242
725
533
374
197
101
Notes:
      a.        The Mid-Hudson Region consists of Albany, Columbia. Dutchess, Greene, Rensselaer, and Ulster Counties.

                Source: 1990 U.S. Census.
                                                                                                                  TAMS/ Gradient Corporation

-------
                                                         Table 2-16 (Unchanged)
                                       County-to-County In-Migration Data for Ulster County, NY

No Move
Move In
Total From
Abroad


Age Group
5 to 9
10lol4
15 to 19
20 to 24
25 to 29
30 to 34
35to44
45 to 54
55 to 64
65 to 74
75 to 84
85+






Total

Outside
Region8

Total from
Outside Region"
Domestic
Inside Region
Total
From
Ulster Albany Columbia
5,911
6,285
6,544
4,651
3,959
5,824
15,066
13,465
12,045
10,090
5,884
1,664
4,990
4,019
4,059
7,370
10,262
9,224
11,368
4,510
2,774
2,122
1,307
494
73
43
165
229
293
226
209
65
49
28
0
0
4,917
3,976
3,894
7,141
9,969
8,998
11,159
4,445
2,725
2,094
1,307
494
1.619
1,340
1,915
3,553
3,921
3,238
3,839
1,602
832
790
350
181
3,298
2,636
1,979
3,588
6,048
5,760
7,320
2,843
1,893
1,304
957
313
2,990
2,368
1,741
2,980
4.864
4,916
6,542
2,504
1,722
1,241
890
284
14
5
12
76
75
92
45
7
17
0
8
0
13
17
15
0
21
18
23
18
9
11
0
0
Duchess Greene Rensselaer
250
223
190
454
1004
663
629
272
122
37
54
29
31
19
9
68
65
56
66
31
23
15
5
0
0
4
12
10
19
15
15
11
0
0
0
0
1,692
1,383
2,080
3,782
4,214
3,464
4,048
1,667
881
818
350
181
Notes:
       a.        The Mid-Hudson Region consists of Albany, Columbia, Dutchess, Greene, Rensselaer, and Ulster Counties.

                Source: 1990 U.S. Census.
                                                                                                                    TAMS/ Gradient Corporation

-------
                                                        Table 2-17 (Unchanged)
                                 County-to-County In-Migration Data for the Mid-Hudson River Region




No Move



Move In
Total


From
Abroad



Total


Outside
Region"



Domestic



Total from
Outside Region"


Inside Region
Total
Age Group
5 lo 9
10 to 14
15 to 19
20 to 24
25 to 29
30 to 34
35 to 44
45 to 54
55 to 64
65 lo 74
75 to 84
85+
32,812
36.541
39,986
28,386
21,068
30,519
87,423
74,671
69,558
60,958
34,362
10,210
31,098
22,644
29,230
52,120
59,732
56,336
65,639
26,203
16,504
13,305
8,985
4,218
716
499
995
1,655
1,982
1.524
1,251
618
297
191
84
0
30.382
22,145
28,235
50.465
57,750
54.812
64,388
25,585
16,207
13.114
8,901
4,218
9,831
6,678
14,549
26.196
22,808
20,052
22,260
8,508
5,381
4,309
2,517
1,236
20,551
15,467
13,686
24,269
34,942
34,760
42,128
17,077
10,826
8,805
6,384
2,982


From
Albany Renssalaer Columbia
6,633
4,819
4,175
7,174
10,739
12,162
14,344
5,540
3,439
3,137
2,241
1,315
3,515
2,625
2,595
4,931
6,275
5,047
6,304
2,466
1,543
1,309
971
462
1,533
1,036
1,014
1,664
2.199
2.060
2,390
1,200
743
704
580
204

Dutchess
4,808
3,756
3,253
5,772
8,601
8,594
10,191
4,448
2,682
1,845
1,304
480

Greene
857
674
702
1,157
1,447
1,438
1,704
646
607
430
320
157

Ulster
3,205
2,557
1,947
3,571
5,681
5,459
7,195
2,777
1,812
1,380
968
364


10,547
7,177
15,544
27,851
24,790
21,576
23,511
9,126
5,678
4,500
2,601
1,236
Notes:
      a.       Tlie Mid-Hudson Region consists of Albany, Columbia, Dutchess. Greene, Rensselaer, and Ulster Counties.

               Source: 1990 U.S. Census.
                                                                                                                    TAMS/ Gradient Corporation

-------
                                                    Table 2-18 (Unchanged)
                               Computation of 1-Year Move Probabilities for the Mid-Hudson Region
Notes:
Age Group (k) In,,^,,,,/ Start,985^o,kb Start^gj.,^,' OutI9M.w>l[d Probability of Pfcj' Pkil Difference
Moving in a 5- „, „ .. . Mid-Hudson
B (Mid-Hudson) (UPIW Hudson)
year Period* vs- uPPer













a.
fc
c.
d.
e.
f-
8-

5 to 9 (1) 10,547 32,812 36,541 6,818 15.7%
10 to 14 (2) 7,177 36,541 39,986 3,732 8.5%
15 to 19 (3) 15,544 39,986 28,386 27,144 48.9%
20 to 24 (4) 27,851 28,386 21,068 35,169 62.5%
25 to 29 (5) 24,790 21,068 30,519 15,339 33.4%
30 to 34 (6) 21,576 30,519 43,712s 8,383 16.1%
35lo44 (7) 23,511 87,423 74,671 36,263 32.7%
45 to 54 (8) 9,126 74,671 69,558 14,239 17.0%
55 to 64 (9) 5,678 69,558 60,958 14,278 19.0%
65 to 74 (10) 4,500 60,958 34,362 31,096 47.5%
75 to 84 (11) 2,601 34,362 10,210 26.753 72.4%
85+ (12) 1,236 10,210 NAh 11,446
Taken from the column labeled, "Total from Outside Region" in Table 2-14.
The Mid-Hudson Region consists of Albany, Columbia, Dutchess, Greene, Rensselaer, and Ulster Counties.
Set equal to the value of Start i9gs-9o.k in the preceding row.
Out i9ss-90,k = (Start /agj.go.* - Start 1935-90.1+1 )+ In i9ss-90,k
Set equal to (Out i9K-9o.k ) /(Start 19^.90.* + In /9s5-».t ) •
Set equal to 1/5 x the probability of moving in a 5-year period.

3.1%
1.7%
9.8%
12.5%
6.7%
3.2%
6.5%
3.4%
3.8%
9.5%
14.5%
100%'







2.5%
1.6%
9.5%
11.8%
5.9%
3.5%
7.5%
2.2%
3.2%
9.5%
14.0%
100%'






Hudson
-0.6%
-0.1%
-0.3%
-0.7%
-0.8%
0.3%
1.0%
-1.2%
-0.6%
0.0%
-0.5%
0.0%






The value in this cell is 1/2 the value listed for Start igss-wj to make Start 1955.90.5 and Start 1935.90,7 comparable. The adjustment
addresses the fact that Age Group 7 represents 10 years (ages 35 to 44), whereas Age Group 6 represents 5 years (ages 30 to 34).
h.
Since Age Group 12 (ages 85+) is the last age group, there is no value for Stan ws-yo.u •



i. Assumes no exposure after age 85. This assumption has no effect on the estimated risk since it is assumed that individuals stop fishing by age 80.
                                                                                                            TAMS/ Gradient Corporation

-------
                                                                                         TABLE 2-198 (Revised)
                                                                            VALUES USED FOR DAILY INTAKE CALCULATIONS
                                                                                 MID-HUDSON RIVER FISH - Adult Angler
         Scenario Timeframe. Current/Future
         Medium  Fish
         Exposure Medium Fish
         Exposure Pant Mid-Hudson Fish
         Receptor Population. Angler
         Receptor Age-Adull	
Exposure Route
digestion













Parameter
Code
CH.-C
QurNC
IRbh

Loss
FS
EF
ED
ED
CF
BW

AT-C
AT-NC
Parameter Definition
PCB Concentration in Fish (Cancer)"
PCB Concentration in Fish (Non-cancer)"
Ingeslion Rale of Fish

Cooking Loss
Fraction from Source
Exposure Frequency
Exposure Duration (Cancer)
Exposure Duration (Noncancer)
Conversion Factor
Body Weight

Averaging Time (Cancer)
Averaging Time (Noncancer)
Urals
mg/kg wet weight
mg*g wet weight
grams/day

a/g
umlless
days/year
years
years
kg/g
kg

days
days
RME
Value
1.1
14
319

0
1
385
22
7
100E-03
70

25.550
2.555
RME
Rationale/
Reference
See Table 2-8
See Table 2-8
90th percentile value.
based on 1991 NY Angler
survey.
Assumes 100% PCBs
remains in fish
Assumes 100% fish
ingested is from Mid-
Hudson
Fish ingeslion rate already
averaged over one year.
denved from 95lh
percentile value, based on
1991 NY Angler and 1990
US Census data
see text
-
Mean adult body weight,
males and females
(USEPA. 1989b)
70-year lifetime exposure x
365 d/yr (USEPA, 19890)
ED (years) x 385 days/year
CT
Value
1.4
1.4
4.0

02
1
365
6
6
1.00E-03
70

25.550
2,190
CT
Rationale/
Reference
See Table 2-8
See Table 2-8
50th percentile value.
based on 1991 NY Angler
survey.
Assumes 20% PCBs in fish
is lost through cooking
Assumes 100% fish
Ingested is from Mid-
Hudson.
Fish ingestion rate already
averaged over one year
derived from 50th percentale
value, based on 1991 NY
Angler and 1990 US
Census data
derived from 50th percentile
value, based on 1991 NY
Angler and 1990 US
Census data.
-
Mean adult body weight.
males and females
(USEPA. 1989b).
70-year lifetime exposure x
365 d/yr (USEPA, 19890).
ED (years) x 365 days/year.
Intake Equation/
Model Name
Average Daily Intake (mo/kg-day) =
CH, x IRu, x (1 - Loss) X FSxEFx ED xCFxI/BWx I/AT












Speaes-weighled PCB concentration averaged over nver location
                                                                                                                                                                           TAMS/ Gradient Corporation

-------
                                                                                         TABLE 2-19b (Revised)
                                                                            VALUES USED FOR DAILV INTAKE CALCULATIONS
                                                                               MID-HUDSON RIVER FISH - Adolescent Angler
          Scenario Timelrame  Currant/Future
          Medium  Fish
          Exposure Medium Fisn
          Exposure Point Mid-Hudson Fish
          Receptor Population  Angler
          Receptor Age Adolescent	
Exposure Route
Ingestion

























Parameter
Code
c»-c
Cu-NC
IFW,

Loss

FS


EF

EO



ED



CF
BW


AT-C

AT-NC
Parameter Definition
PCS Concentration in Fish (Cancer)"
PCB Concentration in Fish (Non-cancer)"
Ingestion Rate of Fish

Cooking Loss

Fraction from Source


Exposure Frequency

Exposure Duration (Cancer)



Exposure Duration (Noncancer)



Conversion Factor
Body Weight


Averaging Time (Cancer)

Averaging Time (Noncancer)
Units
mg/kg wet weight
mg/kg wet weight
grams/day

9/9

unitless


days/year

years



years



WO
kg


days

days
RME
Value
1 3
1.4
213

0

1


365

12



7



100E-03
43


25.550

2,555
RME
Rationale/
Reference
See Table 2-8
See Table 2-8
2/3 of RME adult ingestion
rate.
Assumes 100% PCBs
remains in fish.
Assumes 100% fish
ingested is from Mid-
Hudsoa
Fish ingestion rate already
averaged over one year.
denved from 95th
percentile value, based on
1991 NY Angler and 1990
US Census data
see text



-
Mean adolescent body
weight, males and famales
(USEPA, 19690).
70-year lifetime exposure x
365 d/yr (USEPA. 1989b).
ED (years) x 365 days/year
CT
Value
1 5
1 5
27

0.2

1


365

3



3



100E-03
43


25.550

1,095
CT
Rationale/
Reference
Sea Table 2-8
See Table 2-8
2/3 of RME adidl ingestion
rate
Assumes 20% PCBs in fish
is lost through cooking
Assumes 100% fish
ingested is from Mid-
Hudson.
Fish ingestion rate already
averaged over one year
denved from 50th percentile
value, based on 1991 NY
Angler and 1990 US
Census data
denved from SOlh percentile
value, based on 1991 NY
Angler and 1990 US
Census data.
-
Mean adolescent body
weight, males and females
(USEPA. 19890).
70-yaai lifetime exposure x
365 d/yr (USEPA. 1989D)
ED (years) x 365 days/year.
Intake Equation/
Model Name
Average Daily Intake (mg/kg-day) =
CM x IRU x (1 - Loss) X FS x EF x ED x CF x 1/BW x 1/AT
























Species-weighted PCB concentration averaged over nver location
                                                                                                                                                                             TAMS/ Gradient Corporation

-------
                                                                                         TABLE 2-19C (Revised]
                                                                             VALUES USED FOR DAILY INTAKE CALCULATIONS
                                                                                  MID-HUDSON RIVER FISH • Chid Angler
         Scenario Timelrame  Current/Future
         Medium. Fish
         Exposure Medium Fish
         Exposure Point- Mid-Hudson Fish
         Receptor Population. Angler
         Receptor ABB Child	
Exposure Route
Ingestion







Parameter
Code
CM.
IRbh
Loss
FS
EF
ED
CF
BW
AT-C
AT-NC
Parameter Definition
PCB Concentration in Fish"
Ingeslion Rate ot Rsh
Cooking Loss
Fraction from Source
Exposure Frequency
Exposure Duration
Conversion Factor
Body Weight
Averaging Time (Cancer)
Averaging Time (Noncancei)
Units
mg/kg wet weight
grams/day
gig
unitless
days/year
years
Kg/g
kg
days
days
RME
Value
1.4
106
0
1
365
6
1.00E-03
15
25.550
2.190
RME
Rationale/
Reference
See Table 2-8
1/3 of RME adult ingeslion
rate.
Assumes 100% PCBs
remains in fish
Assumes 100% fish
ingested is from Mid-
Hudson
Fish mgestion rate already
averaged over one year.
derived from 95lh
percemile value, based on
1991 NY Angler and 1990
US Census data.
-
Mean child body weight
(USEPA. 1989b).
70-year lifetime exposure x
365 d/yr (USEPA. 1989b)
ED (years) x 365 days/year
CT
Value
15
13
02
1
365
3
1.00E-O3
15
25.550
1.095
CT
Rationale/
Reference
See Table 2-8
1/3 of CT adult mgestion
rale
Assumes 20% PCBs in fish
is lost through cooking.
Assumes 100% fish
ingested is from Mid-
Hudson.
Fish ingeslion rate already
averaged over one year
derived from 50th percentile
value, based on 1991 NY
Angler and 1990 US
Census data
-
Mean child body weight
(USEPA. 1989b).
70-year lifetime exposure x
365 dfyr (USEPA, 1989b)
ED (years) x 365 days/year
Intake Equation/
Model Name
Average Daily intake (mg/kg-day) =
CM X IRu, X (1 - LOSS) X FS X EF x ED X CF X 1/BW x I/AT






Species-weighted PCB concentration averaged over nver location for both cancer and non-cancer calculations.
                                                                                                                                                                              TAMS/ Gradual Corporation

-------
           TABLE 2-20 (Revised)
VALUES USED FOR DAILY INTAKE CALCULATIONS
 MO-HUDSON RIVER SEDIMENT • AduB Recrealor







Exposure Route


inpcsUon















Dennai






















Scanano Tmftarm Currant/Film
ytadlua SedJmert
Exposure Medium Sediment
ExposuePbss Banks of MM Hudson
toceplor Poputallon Recieator
Receptor Am Add



Coda

c_t_
IRaam

FS


EF
ED


CF
BW


AT-C
AT-NC
DA


AF



SA



EF
ED



CF
BW


AT-C

AT-NC
taMM*.


Chenacal Concamnilon in sadbneni
Ingesuon Rate of Sedmonl

Fraction from Source


Exposure Fiequency
Exposure Duration


Conversion Factor
Body Weight


AvaragBXj Time (Cancer)
Averaging Time (Hencsncer)
3ermal Absoiptian


Adherence Foctor



Surface Area



Exposure Frequency
Exposure Duration



Conversnn Factor
BodyWexjn


AverigngTuno(Carai)

Averaging Tima (Nonesncer)







Unas


morkg
rngUsy

uruiess


days/year
yean


kgAng
kg


days
days
unUless


mo/cm-



cmVevenl



evonUyesr
yean



ko/mg
kg


days

days

RME
Value

053
so

1


13
23


100E-O3
70



8.395
O63
014


03



6.073



13
23



100E-06
70


S5.550

8.395

RME
Rationale/
Reference
Sea Table 2-9
Mean adul son Ingesuon
rate (USEPA. 10971)
Assumes 100% uodimenl
exposure Is horn MM.
Hudson
1 dayrwoek, 3 monthsfyr
denved from 95th
duration h 5 MxWudson
Counties (see text)
-
Mean add body weight.
males and females
(USEPA. 19886)
TO-yov HfBtlmB exposure •
385 OVyr (USEPA. 19896)
ED (yean) x 385 days/year
See Table 2 9
Based on absorption ol
PCSe from eol In menkeye
(Wester. 1993)
50% value tot edul (reed
gatherer) hands, tower
legs, forearms, and face
(USEPA. 1999Q
Ave maMemele SOlh
peicertie tiaixls, towsr
tegs, foreanns, feel, and
face (USEPA, 19971)
1 day/week. 3 monhs/yr
derived t ran 951(1
percenmeotrealderce
duration bl 5 Upper Hudson
Counties (see text)
-
Maan adult body weight.
males and females
(USEPA. 18896)
70-yaar ifellnie exposure x
365 OVyl (USEPA, 19896)
ED (years) x 385 daysryaar
CT
Value

065
50

1


7
5


100E-08
70


25,550
1.825
085
014


03



6.073



7
5



1 ODE-OS
70


25.650

1.825

CT
FuutonaNy
Reference
See Table 2-9
Mean adul sofl hgmum
rate (USEPA. 1097Q
Assumes 100% sedrmert
exposures) from Mid-
Hudson
Approxtnslely SDK of RME
derived from soth pereentte
of residence duration ei 5
Mid-Hudson CaunBes (see
text)
_
Mean edul body weight.
mates and females
(USEPA, 1989B)
70-year netlrne exposure x
385 oVyr (USEPA. U89b)
ED (years) x 365 daya^ear
See Table 2-9 	
Based on absolution cf
PCDs faom sofl si monkaya
(Wester, 1883)
50% value tor add (read
galhorer) futnrm, tower
togs, foreanns. and face
(USEPA. 19990
Ave makVrernala SOlh
parcenula funds, tower
togs, forearms, feat, and
face (USEPA, 19B7T)
Apprax SOXolRME
derived tram SOth percenll<
of nskJanca duration bi 5
Upper Hudson Counties
(we lea)
_
Mean adul body weight.
males and females
(USEPA. 19896)
70-year Hfeume exposure x
365 OVyr (USEPA, 19896)
ED (years) x 365 days/year
Intake Equallonr
Model Name

Average Dasy Mate (mg/kfrday) .
C_»_ x IRMmM X FS x EF x ED x CF x 1/BW x WAT














A™™O. Deny Intake (mg«g-dsv) .
C_^_ x DA x AF x SA x EF x ED x CF x 1/BW x I/A!






















                                                                                                           TAMS/ Gradual Oapanam

-------
            TABLE 2-21 (Revised)
 VALUES USED FOR DALY INTAKE CALCULATIONS
MID-HUDSON RIVER SEDIMENT-





ixposine Rodi

Ifigesllon
















Dermal






















Scenario Tbnefrerne CuirenVFUun
Median: Sediment
Exposuf e Msduin. Sediment1
Exposure Povd Banks of Mid Hudson
Ffecetttr Roputaiton Reereaior
Receptor Aoe Adutasccirt


Parameter
Coda
C^_
in—

FS


EF
ED



CF
BW

AT-C

ATKC
C-*—
DA

AF



SA



EF
ED



CF
BW


AT-C

AT-NC

Pvameler DolnUon

Chemical Concentration h Sediment
IngoHin Rale at Sediment

Fraction Iram Sown


Enpoeure Frequency
Exposure Duration



Conversion Factor
Body Weight


A«ngn|,Tkn.(Q«V)
Averaging Time (Noncancoi)
Chemical Concentration In SodunBnl
^enienl Absorption

Adherence Factor



Surface Aioa



Eieposure Frequency
Exposure Duration



Conversion Factor
Body Weigh!


Averagbig Time (Caneer)

Averaging Tkne (Noncancer)





UnBa

mo/kp
mgMay

unlltosa


days/year
yean



kgftng
k8

(b«s
2-«
Mean «oi hgeellan nt«
(USEPA. 1997Q
AnumutoOKiadtnenl
exposure Is liom Upper
Hudson
3 daysnvaek. 3 morths/yr
derived from esih
parcenllB of nnUenca
duration In 5 M«)-Hudson
Counte(seeleM)
-
Mean edokncent body
weight, mafes and lamates
(USEPA. I989b)
70*year tUaHrne exposure x
365 cVyr (USEPA. 1989D)
ED (yean) x 36B dayiryaar
See Table 2-9
PCDsfiDineol (nmonkeyv
(Wolii.1993)
Mldpotu of adull and chDd
AF Hand), kmei legs.
forearms, and lace
(USEPA. 19991)
Ave male/female son
parental ega 12 hands.
bwsr leos, loraarrni. led.
and taca (USEPA. 19971)
3 oayinraek. 3 monuaVyr
derived Irerngsih
pncBfttRB of reBldeiica
dunllon In 5 MK^Hudnn
Counun(sMiM)
-
Mean adotoscenl body
vretght males and loraka
(USEPA. 19B9D)
70-yaar Hallme aiawsura x
365 oVy> (USEPA. 108*)
ED (years) « 365 deyiryear

CT
Value
066
60

1


20
3



1ODE-06
43

25.550

1.095
066


025



4.263



20
3



100E-06
43


25.550

1.095

CT
RallonaW
See Table 2-9
Mean •oUngeetlonrele
(USEPA, 19971)
Assumes too* sediment
esposue b (rein Upper
Hudson.
Approdnnlsly 50% ol RME
dorivaij (rom SOth parcarilh
ol resrisnce duration h 5
Mid-Hudson Coumee (see
led)
-
Mean adolescent body
wolgtil. rnaJofl And lomales
(USEPA. 1989b)
365 OVyr (USEPA. 10390)
ED (yean) < 3BS oaysfyear
See Table 2-9
PCBs from aoD In nwnksya
(Waster, 1993)
Midponl ol adull and cMd
AF Hands, lower togs.
forearms, and taca
(USEPA. 19991)
Ava mala/Iemale SOlh
parcenl>aage12 hands.
mrar lege, Mraerma. leal.
and bee (USEPA. 19971)
Approximately 50* ol RME
Damon Iron EOlh percental
ot rasidatice duraaon h S
Mid-Hudson Counties (see
lea)
-
Mean ado lucent body
werglt. males and lemales
(USEPA. 19890)
70-year Hetlmo expocure >
365 OVyi (USEPA. 19B9D)
ED (years) > 365 dayaryaar

Intake EqualkxV
Model Name
Avenge Daly Intake (mo*g-da/> .
CM«. « IR_An a FS x EF x ED * CF 1 1/BW I VAT















Average DaDy Intake (mQAg-day) •
SH^MM x DA x AF x SA x EF x ED x CF x 1/BW x 1/A1





















                                                                                                            TAMS/ Gradual Carpaatan

-------
           TABLE 2-22 [Revised)
VALUES USED FOR DAILY INTAKE CALCULATIONS
 MIOHUDSON RIVER SEDIMENT CtlM Recrealor







:xposura Route


Ingasllan

















Dermal























Scenario Tfcneframe CurrenvFuiure
itefflura. SaOlmeni
Exposure Medum. Salman
ixpasure Pot* Banks otMM-Huoson
^OCeplQf Population R0Gf 0310V
ttcepnrAga Chad

Parameter
Code

CMM
IH_M

FS


EF
ED



CF
BW


AT-C

AT-NC
C_»
DA


AF



SA




EF
ED



CF
BW


AT-C

AT-NC

Parameter Dehnnion


Chemical Concontralbn h Sedbnert
Inceston Rale of Ssosnsnl

Fraction Irom Sana


Exposure Frequency
Exposure Duration



Conversion Feclor
tkxty Weight


Averaging Time (Cancer)

IvengnQ Time (Noncancer)
Chemical Concentration In Sadlman
Dermal Absorption


Adherence Factor



Surface Area




Exposure Frequency
Exposin Duration



Conversion Factor
Body weigh.


Averagmg Time (Cancer)

Averaging Tlrno (Noncancor)







Unas


mo/kg
ran/day

artaat


(lays/year
years



kgfrng
kO


days

days
molcg
unman


mcycm-



cnrtevenl




ovaitvyur
years



kgrnig
kg


days

days

RME
Value

064
100

1


13
a



100E-08
IS


25.550

2.100
ffB
014


02



27D2




13
e



lOOE-oe
is


25.550

2.190

RME
Ranonalry
Ratacanea
SoeTeHe2-9
MaamMdaogmgaatm
rate (USEPA. 19970
Assumss 100% sadlmanl
eqiaaura la from Uppar
Hudson.
1 day/vMak. 3 rnofdhs/yr
derived from 9Slh
pBICflrflBOl fBSfctonCB
durallon In S MB- Hudson
CounUas(aaatexl)
-
Mean chDd body iragM.
malea and rernatoa
(USEPA. 18690)
70-year llelma exposure x
365dryr(USEPA.ie89b)
ED(yaan)>3S5dayaryasi
See Table 2-8
Basod on absorption of
PC8s from sou mmonkeye
(Waaei. 1983)
50% value lor children
(mola sol) hands, lower
laga. foraarrns. and taca
(USEPA, 10991)
GOIh percardDa ava for
mataAarnalachlldBgee
hands, lower leas.
forearms, feet, and lace
(USEPA. 19971)
1 dBy/Mraak. 3 mmltisjyi
derived from 95ili
percertleol residence
duration In 5 Mid Hudson
Counties (see text)
-
Mean chiH body wmgn.
males and females
(USEPA, 1989b)
70-year Hdme exposura x
365 OTyr (USEPA, 18396)
ED (years) 1 365 daysryoar

CT
Value

066
100

1


7
3



100E-OB
15


25,550

1.095
066
014


02



2.792




7
3



IOOE-OS
15


25,550

1.095

CT
RattonakV
Reference
SeeTaMe2-9
Mean cfiDd sol hoesUon
rale (USEPA. 1997Q
Assurnes 100% sodknenl
exposure Is from Upper
Hudson,
Appro. 50% of RME
derived from 60th percentlb
of reaktenca duration In 5
Mid-Hudson Counties (sea
text)
-
Mean CMH body might.
males and females
(USEPA. 1989D)
70-year uleuma exposure x
365 d/yr (USEPA. 19890)
ED Cyans) x 385 days/yaar
See Table 2-9
Rmttifl on absorption of
PCBa from eel In monkeys
(Waaar. 1993)
60% value for children
(moist sofQ hands, loweff
togs, lorearms. and face
(USEPA. 19991)
50th percenUe ava for
malefremalecrdUarjee
hands, lowef leos.
forearms, feel, and lace
(USEPA. 1997!)
ApprOLSMafRME
derived from SOIh peicertili
of resdence duration In S
MU Hudson Counties (sag
led)
-
Mean chdd body M»gM.
males and lomalos
(USEPA. 19896)
70-year Uellme exposure x
385 tfryr (USEPA. 18836)
ED (years) 1 3G5 daysryaar

Intake Equator*
Model Mama

Avenge Daly Intake (rngno>day) .
C_*_ » IR_h_ x FS X EF < ED I CF 1 1/BW x 1/A1
















Average Daiy Intake (rngflcg-day) .
C_«MxDA>AFxSA>EFiEDxCFx1/BWx1/An























                                                                                                            TAMS/ Gndimi Corporation

-------
                                                                            TABLE 2-23 (Revised)
                                                               VALUES USED FOR DAILY INTAKE CALCULATIONS
                                                                 MID-HUDSON RIVER WATER - Adult Recrealor
Scenario Timelrame  Current/Future
Medium   River Water
Exposure Medium River Water
Exposure Point. Mid-Hudson River
Receptor Population  Recreator
Receptor Age Adull	
Exposure Route
Dermal


















Parameter
Code
C..U,
Kp

SA

DE

EF
ED



CF
BW


AT-C

AT-NC
Parameter Definition
Chemical Concentration in River Water
Dermal Permeability Constant (for PCBs)

Surface Area

Dermal Exposure Time

Exposure Frequency
Exposure Duration



Conversion Factor
Body Weight


Averaging Time (Cancer)

Averaging Time (Noncancer)
Units
mg/L
cm/hour

cm>

hours/day

days/year
years



L/cnV
kg


days

days
RME
Value
88E-06
048

18.150

26

13
23



100E-03
70


25,550

8.395
RME
Rationale/
Reference
See Table 2-10
Hexachloroblphanyl
(USEPA. 19990
Full body contact (USEPA,
1997Q
National average for
swimming (USEPA. 1989b)
1 day/week, 3 months/yr
derived from 95ID percentile
of residence duration in 5
Mid-Hudson Counties (see
text)
-
Mean adult body weight.
males and females
(USEPA. 1989b)
70-year lifetime exposure x
365 d/yr (USEPA. 1989b).
ED (years) x 365 days/year
CT
Value
15E-05
0.4B

18.150

26

7
5



1.00E-03
70


25.550

1.825
CT
Rationale/
Reference
See Table 2-10
Hexachlorobiphenyl
(USEPA. 19990
Full body contact (USEPA.
19971)
National average for
swimming (USEPA, 1989b)
Approx 50% Of RME
derived from 50th percentile
of residence duration in 5
Mid-Hudson Counties (see
text)
-
Mean adult body weight,
males and females
(USEPA. 19890)
70-year lifetime exposure x
365 d/yr (USEPA. 1989b)
ED (years) x 365 days/year
Intake Equation/
Model Name
Average Daly Intake (mg/kg-day) =
CM. X KpxSAx DE X EFx ED xCF x 1/BW X 1/A1

















                                                                                                                                                          JAMS/ Gradient Corporation

-------
                                                                           TABLE 2-24 (Revised)
                                                              VALUES USED FOR DAILY INTAKE CALCULATIONS
                                                              MID-HUDSON RIVER WATER - Adolescent Recreator
Scenario Ttmeframe  Current/Future
Medium   River Water
Exposure Medium River Water
Exposure Point  Mid-Hudson River
Receptor Population  Recreator
Receptor Age- Adolescent	
Exposure Route
Dermal






Parameter
Code
C.M.
Kp
SA
DE
EF
ED
CF
BW
AT-C
AT-NC
Parameter Definition
Chemical Concentration in River Water
Dermal Permeability Constant (for PCBs)
Surface Area
Dermal Exposure Time
Exposure Frequency
Exposure Duration
Conversion Factor
Body Weight
Averaging Time (Cancer)
Averaging Time (Noncancer)
Units
mg/L
cm/hour
cm»
hours/day
days/year
years
Ucnf
kg
days
days
RME
Value
1 1E-05
048
13.100
26
39
12
100E-03
43
25.550
4.380
RME
Rationale/
Reference
See Table 2-10
Hexachloroblphenyl
(USEPA. 1999Q
Full body contact (USEPA.
19971)
National average for
swimming (USEPA. 1989b)
3 days/week. 3 months/yr
derived from 95th percentile
of residence duration In 5
Mid-Hudson Counties (sea
text)
-
Mean adolescent body
weight, males and females
(USEPA. 1989b)
70-year lifetime exposure x
365 d/yr (USEPA. 1989b)
ED (years) x 365 days/year
CT
Value
1.6E-05
0.48
13.100
26
20
3
1.00E-03
43
25.550
1.095
CT
Rationale/
Reference
See Table 2-10
Hexachloroblphenyl
(USEPA. 19990
Fun body contact (USEPA.
19970
National average for
swimming (USEPA. 1989b).
Approx. 50%ofRME
derived from 50th percentile
of residence duration In 5
Mid-Hudson Counties (see
text)
-
Mean adolescent body
weight, males and females
(USEPA. 1989b)
70-year lifetime exposure x
365 d/yr (USEPA, 1989b).
ED (years) x 365 days/year
Intake Equation/
Model Name
Average Dally Intake (mg/kg-day) =
CM. X Kp X SA X DE X EF X ED X CF x 1/BW X I/AT





                                                                                                                                                         TAMS/ Gradient Corporation

-------
                                                                            TABLE 2-25 (Revised)
                                                               VALUES USED FOR DAILY INTAKE CALCULATIONS
                                                                 MID-HUDSON RIVER WATER - Child Recreator
Scenario Timetrame  CurrenVFulure
Medium   River Water
Exposure Medium: River Water
Exposure Point: Mid-Hudson River
Receptor Population. Recreator
Receptor Age: Child	
Exposure Route
Dermal






Parameter
Code
C».
Kp
SA
DE
EF
ED
CF
BW
AT-C
AT-NC
Parameter Definition
Chemical Concentration In River water
Dermal Permeability Constant (lor PCBs)
Surface Area
Dermal Exposure Time
Exposure Frequency
Exposure Duration
Conversion Factor
Body Weight
Averaging Time (Cancer)
Averaging Time (Noncancer)
Units
mg/L
cm/hour
cm»
hours/day
days/year
years
Ltan»
kg
days
days
RME
Value
14E-05
0.48
6.880
26
13
6
100E-03
15
25.550
2.190
RME
Rationale/
Reference
See Table 2-10
Hexachlorobiphenyl
(USEPA. 19991)
FuD body contact (USEPA.
19970
National average for
swimming (USEPA. 19B9b)
1 day/week, 3 rnonths/yr
derived from 95th percentile
of residence duration In 5
Mid-Hudson Counties (see
text)
-
Mean child body weight.
males and females
(USEPA. 1989b)
70-year lifetime exposure x
365 d/yr (USEPA. 1989b).
ED (years) x 365 days/year.
CT
Value
1.6E-05
048
6.880
26
7
3
100E-03
15
25.550
1.095
CT
Rationale/
Reference
See Table 2-10
Hexachlorobiphenyl
(USEPA. 1999J)
Full body contact (USEPA.
1997Q
National average for
swimming (USEPA. 1989b)
Approx. 50% of RME
denved from 50th percentile
of residence duration In 5
Mid-Hudson Counties (see
text)
-
Mean child body weight.
males and females
(USEPA. 1989b)
70-year lifetime exposure x
365 d/yr (USEPA. 1989b)
ED (years) x 365 days/year
Intake Equation/
Model Name
Average Daily Intake (mg/kg-day) =
CM. X Kp X SA X DE X EF X ED X CF X 1/BW X I/AT





                                                                                                                                                          TAMS/ Gradient Corporation

-------
                                                                           TABLE 2-26 (Revised)
                                                              VALUES USED FOR DAILY INTAKE CALCULATIONS
                                                                  MID-HUDSON RIVER WATER - Adult Resident
Scenario Timeframe  Current/Future
Medium   River Water
Exposure Medium- River Water
Exposure Point' Mid-Hudson River
Fteceptor Population  Resident
Receptor Age Adult	
Exposure Route
Ingesuon














Parameter
Code
CM.
IR


EF
ED



BW


AT-O
t\t -\+
AT-NC
Parameter Definition
Chemical Concentration in River Water
Ingesuon Rate


Exposure Frequency
Exposure Duration



Body Weight


A nn vw* 1~ma /r>anAAr\
Averaging 1 Ima lk*3nCtjiJ
Averaging Time (Noncancer)
Units
mg/L
L/day


days/year
years



*9


daws
oays
days
RME
Value
8.8E-06
2.3


350
23



70


25t550

8.395
RME
Rationale/
Reference
See Table 2-10
90th percentile drinking
water Intake rate for adults
(USEPA, 1997c)
(USEPA. 1991b)
derived from 95th percentile
of residence duration In 5
Mid-Hudson Counties (see
text)
Mean adult body weight.
males and females
(USEPA. 19890)
70"VBBr litetims cxoosuro x
365 d/yr (USEPA. 1989b)
ED (years) x 365 days/year
CT
Value
1 5E-05
1.40


350
5



70


25.550

1.825
CT
Rationale/
Reference
See Table 2-10
Mean drinking water Intake
rate for adults (USEPA.
1997C)
(USEPA. 1991b)
derived from 50th percentile
of residence duration In 5
Mid-Hudson Counties (see
text)
Mean adult body weight.
males and females
(USEPA. 19890).
*7A-kHM» 1 (A! mn A .MX. M
/U~yB8i lliSUiTiO OXpOSUiB X
365 d/yr (USEPA. 1989b)
ED (years) x 365 days/year
Intake Equation/
Model Name
Average Dally Intake (mg/kg-day) =
Cm, X IR X EF x ED x 1/BW x 1/AT













                                                                                                                                                          TAMS/ Gradient Corporation

-------
                                                                            TABLE 2-27 (Revised)
                                                               VALUES USED FOR DAILY INTAKE CALCULATIONS
                                                               MID-HUDSON RIVER WATER - Adolescent Resident
Scenario Timeframe: Current/Future
Medium  River Water
Exposure Medium River Water
Exposure Point Mid-Hudson River
Fteceptor Population Resident
Receptor Age' Adolescent	
Exposure Route
Ingeslion




Parameter
Code
CM.
IR
EF
ED
BW
AT-C
AT-NC
Parameter Definition
Chemical Concentration In River Water
Ingestion Rate
Exposure Frequency
Exposure Duration
Body Weight
Averaging Time (Cancer)
Averaging Time (Noncancer)
Units
mg/L
L/day
days/year
years
kg
days
days
RME
Value
1.1E-05
23
350
12
43
25,550
4.380
RME
Rationale/
Reference
See Table 2-10
90th percentile drinking
water Intake rate tor adults
(USEPA, 1997c)
(USEPA. 19910)
derived from 95th percentile
of residence duration In 5
Mid-Hudson Counties (see
text)
Mean adolescent body
weight males and females
(USEPA. 1989D)
70-year lifetime exposure x
365 d/yr (USEPA, 1989U).
ED (years) x 365 days/year.
CT
Value
16E-05
140
350
3
43
25,550
1.095
CT
Rationale/
Reference
See Table 2-10
Mean drinking water intake
rate for adults (USEPA,
1997c)
(USEPA. 1991D)
derived from 50th percentile
of residence duration In 5
Mid-Hudson Counties (see
text)
Mean adolescent body
weight, males and females
(USEPA. 1989b).
70-year lifetime exposure x
365 OVyr (USEPA, 198915).
ED (years) x 365 days/year.
Intake Equation/
Model Name
Average Dairy Intake (mg/kg-day) =
CM. x IR x EF x ED x 1/BW x I/AT



                                                                                                                                                          TAMS/ Gradient Corporation

-------
                                                                            TABLE 2-28 (Revised)
                                                               VALUES USED FOR DAILY INTAKE CALCULATIONS
                                                                  MID-HUDSON RIVER WATER - Child Resident
Scenario Timelrame  Current/Future
Medium.  River Water
Exposure Medium River Water
Exposure Pont Mid-Hudson River
Receptor Population  Resident
Receptor Age  Child	
Exposure Route
digestion















Parameter
Code
c..,.
IR



EF
ED



BW


AT-C

AT-NC
Parameter Definition
Chemical Concentration in River Water
Ingestion Rate



Exposure Frequency
Exposure Duration



Body Weight


Averaging Time (Cancer)

Averaging Time (Noncancer)
Units
mg/L
L/day



days/year
years



kg


days

days
RME
Value
1.4E-05
1 5



350
6



15


25,550

2.190
RME
Rationale/
Reference
See Table 2- 10
90th percenlile drinking
water intake rate for
children, ages 3-5 (USEPA.
1997C)
(USEPA, 19915)
derived from 95th percenlile
of residence duration In 5
Mid-Hudson Counties (see
text)
Mean child body weight.
males and females
(USEPA, 1989b)
70-year lifetime exposure x
365 d/yr (USEPA. 1989b)
ED (years) x 365 days/year
CT
Value
1 6E-05
0.87



350
3



15


25.550

1.095
CT
Rationale/
Rsfsrenco
See Table 2-10
Mean drinking water Intake
rate for children, ages 3-5
(USEPA, 1997c)

(USEPA, 1991D)
derived from 50th percentile
of residence duration in 5
Mid-Hudson Counties (see
text)
Mean child body weight.
males and females
(USEPA, 1989b).
70-year lifetime exposure x
365 d/yr (USEPA. 1989b)
ED (years) x 365 days/year
Intake Equation/
Model Name
Average Dally Intake (mg/kg-day) =
CM. x IR x EF x ED x 1/BW x 1/AT














                                                                                                                                                           TAMS/ Gradient Corporation

-------
                                                                      TABLE 3-1 (Unchanged)
                                                           NON-CANCER TOXICITY DATA - ORAL/DERMAL
                                                                       MID-HUDSON RIVER
Chemical
of Potential
Concern
Aroclor 1254
Aroclor1016
Chronic/
Subchronic

Chronic
Oral RfD
Value

2 OE-05 (2)
7.0E-05 (3)
Oral RfD
Units

mg/kg-d
mg/kg-d
Oral to Dermal
Adjustment Factor

-
Adjusted
Dermal
RfD
••
Units


—
Primary
Target
Organ
LOAEL
NOAEL
Combined
Uncertainty/Modifying
Factors
300
100
Sources of RfD:
Target Organ

IRIS
IRIS
Dates of RfD:
Target Organ (1)
(MM/DD/YY)
6/1/97
6/1/97
N/A = Not Applicable
(1) IRIS value from most recent updated PCB file.
(2) Oral RfD for Aroclor 1254; there is no RfD available for total PCBs. PCBs in fish are considered to be most like Aroclor 1254.
(3) Oral RfD for Aroclor 1016. there is no RfD available for total PCBs. PCBs in sediment and water samples are considered to be most like Aroclor 1016.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                           TABLE 3-2 (Unchanged)
                                                                  CANCER TOXICITY DATA - ORAL/DERMAL
                                                                            MID-HUDSON RIVER
Chemical
of Potential
Concern
PCBs


Oral Cancer Slope Factor


1 (2)
2 (3)
03 (4)
0.4 (5)
Oral to Dermal
Adjustment
Factor
—
..
-
Adjusted Dermal
Cancer Slope Factor

-
—
--
Units


(mg/kg-d)"1
(mg/kg-d)"1
(mg/kg-d)1
(mg/kg-d) '
Weight of Evidence/
Cancer Guideline
Description
B2
B2
B2
B2
Source
Target Organ

IRIS
IRIS
IRIS
IRIS
Date(1)
(MM/DD/YY)

6/1/97
6/1/97
6/1/97
6/1/97
IRIS = Integrated Risk Information System
HEAST= Health Effects Assessment Summary Tables
                                                               EPA Group:
                                                                  A - Human carcinogen
                                                                  B1  - Probable human carcinogen - indicates that limited human data are available
                                                                  B2 - Probable human carcinogen - indicates sufficient evidence in animals and
                                                                       inadequate or no evidence in humans
                                                                  C - Possible human carcinogen
                                                                  D - Not classifiable as a human carcinogen
                                                                  E - Evidence of noncarcmogenicity
                                                               Weight of Evidence:
                                                                  Known/Likely
                                                                  Cannot be Determined
                                                                  Not Likely
(2) Central estimate slope factor for exposures to PCBs via ingestion of fish, ingesbon of sediments, and dermal contact (if dermal absorption fraction is applied) with sediments.
(3) Upper-bound slope factor for exposures to PCBs via ingestion of fish, ingestion of sediments, and dermal contact (if dermal absorption fraction is applied) with sediments.
(4) Central estimate slope factor for exposures to PCBs via ingestion and dermal contact (if no absorption factor is applied) with water soluble congeners in river water.
(5) Upper-bound slope factor for exposures to PCBs via ingestion and dermal contact (if no absorption factor is applied) with water soluble congeners in river water.
(1) IRIS value from most recent updated PCB Hie.
                                                                                                                                               TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-la-RME (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                            MID-HUDSON RIVER FISH - Adult Angler
             Scenario Timelrame. Current/Future
             Medium- Fish
             Exposure Medium. Fish
             Exposure Point. Mid-Hudson Rsh
             Receptor Population Angler
             Receptor Age  Adult	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs

Medium
EPC
Value

1.4
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1.4
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


6.4E-04
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


20E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Total Hazard Index Across All Exposure Routes/
Reference
Concentration
Units

N/A
Pathways
Hazard
Quotient


32
32
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation.
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-1a-CT (Revised)
                                                                         CALCULATION OF NON-CANCER HAZARDS
                                                                             CENTRAL TENDENCY EXPOSURE
                                                                           MID-HUDSON RIVER FISH - Adult Angler
             Scenario Timeframe  Current/Future
             Medium. Fish
             Exposure Medium  Fish
             Exposure Point.  Mid-Hudson Fish
             Receptor Population  Angler
             Receptor Age Adull	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.4
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

14
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


64E-05
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


2.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


3
3
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                            TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-1 b-RME (Revised)
                                                                           CALCULATION OF NON-CANCER HAZARDS
                                                                              REASONABLE MAXIMUM EXPOSURE
                                                                           MID-HUDSON RIVER FISH - Adolescent Angler
             Scenario Timeframe: Current/Future
             Medium- Fish
             Exposure Medium Fish
             Exposure Point. Mid-Hudson Fish
             Receptor Population Angler
             Receptor Age  Adolescent	
Exposure
Route


Ingesbon
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

14
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1.4
Route
EPC
Units

mg/kg wt weight
EPC
Selected
lor Hazard
Calculation (1)
M
Intake
(Non-Cancer)


69E-04
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


20E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


35
35
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                                TAMS/ Gradient Corporation

-------
                                                                                   TABLE 4-ib-CT (Revised)
                                                                           CALCULATION OF NON-CANCER HAZARDS
                                                                               CENTRAL TENDENCY EXPOSURE
                                                                          MID-HUDSON RIVER FISH - Adolescent Angler
             Scenario Timelrame  Current/Future
              Medium1 Fish
              Exposure Medium Fish
             Exposure Point  Mid-Hudson Fish
              Receptor Population  Angler
              Receptor Age  Adolescent	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

15
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1.5
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


7.5E-05
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


2.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


4
4
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation.
                                                                                                                                                                ~TMAS/Gradient Corporation

-------
                                                                                  TABLE 4-lc-RME (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                            MID-HUDSON RIVER FISH - Child Angler
             Scenario Timeframe  Current/Future
             Medium: Fish
             Exposure Medium. Fish
             Exposure Point  Mid-Hudson Fish
             Receptor Population  Angler
             Receptor Age Child	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

14
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1 4
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


99E-04
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


2.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Total Hazard Index Across All Exposure Routes/
Reference
Concentration
Units

N/A
Pathways
Hazard
Quotient


49
49 :-
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-lc-CT (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                              CENTRAL TENDENCY EXPOSURE
                                                                            MID-HUDSON RIVER FISH -Child Angler
             Scenario Timeframe  Current/Future
             Medium. Fish
             Exposure Medium- Fish
             Exposure Point  Mid-Hudson Fish
             Receptor Population. Angler
             Receptor Age. Child	
Exposure
Route


ngestion

Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1 5
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

15
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


10E-04
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


20E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Total Hazard Index Across All Exposure Routes/
Reference
Concentration
Units

N/A
Pathways
Hazard
Quotient


5
S
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation.
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-2-RME (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                        MID-HUDSON RIVER SEDIMENT- Adult Recreator
             Scenario Timelrame. Current/Future
             Medium Sediment
             Exposure Medium Sediment
             Exposure Point  Banks of Mid-Hudson
             Receptor Population Recreator
             Receptor Age- Adult	
Exposure
Route


Ingestion
Dermal
Chemical
of Potential
Concern

RGBs
PCBs
Medium
EPC
Value

0.53
0.53

Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

0.53
053
Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
lor Hazard
Calculation (1)
M
M
Intake
(Non-Cancer)


13E-OB
69E-08
Intake
(Non-Cancer)
Units

mg/kg-day
mg/kg-day
Reference
Dose


70E-05
70E-05
Reference
Dose Units


mg/kg-day
mg/kg-day
Reference
Concentration


N/A
N/A
Reference
Concentration
Units •

N/A
N/A
Total Hazard index Across Ail exposure Houtes/patnways
Hazard
Quotient


0.00019
0.0010
0.0012
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for haiard calculation.
                                                                                                                                                              TMAS/Gradient Corporation

-------
                                                                                  TABLE 4-2-CT (Revised)
                                                                         CALCULATION OF NON-CANCER HAZARDS
                                                                             CENTRAL TENDENCY EXPOSURE
                                                                        MID-HUDSON RIVER SEDIMENT- Adult Recreator
             Scenario Tmielrame. Current/Future
             Medium Sediment
             Exposure Medium: Sediment
             Exposure Point Banks of Mid-Hudson
             Receptor Population: Recreator
             Receptor Age. Adult	
Exposure
Route


Ingestion
Dermal
Chemical
ol Potential
Concern

PCBs
PCBs
Medium
EPC
Value

065
0.65
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

0.65
065
Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
lor Hazard
Calculation (1)
M
M
Intake
(Non-Cancer)


8.9E-09
4.5E-08
Intake
(Non-Cancer)
Units

mg/kg-day
mg/kg-day
Reference
Dose


7.0E-05
7.0E-05
Reference
Dose Units


mg/kg-day
mg/kg-day
Reference
Concentration


N/A
N/A
Total Hazard Index Across All Exposure Routes/
Reference
Concentration
Units

N/A
N/A
Pathways
Hazard
Quotient


0.00013
0.00065
0.00078
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                             TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-3-RME (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                      MID-HUDSON RIVER SEDIMENT- Adolescent Recreator
             Scenario Timelrame  Current/Future
             Medium- Sediment
             Exposure Medium  Sediment
             Exposure Point- Banks of Mid-Hudson
             Receptor Population  Recreator
             Receptor Age-  Adolescent	
Exposure
Route


Ingestion
Dermal

Chemical
ol Potential
Concern

PCBs
PCBs
Medium
EPC
Value

0.59
0.59
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

059
059
Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
for Hazard
Calculation (1)
M
M
Intake
(Non-Cancer)


73E-08
2.2E-07
Intake
(Non-Cancer)
Units

mg/kg-day
mg/kg-day
Reference
Dose


70E-05
70E-05
Reference
Dose Units


mg/kg-day
mg/kg-day
Reference
Concentration


N/A
N/A
Total Hazard Index Across All Exposure Routes/
Reference
Concentration
Units

N/A
N/A
Pathways
Hazard
Quotient


00010
00031
0.0042
(t)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation.
                                                                                                                                                              TMAS/Gradient Corporation

-------
                                                                                   TABLE 4-3-CT (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                              CENTRAL TENDENCY EXPOSURE
                                                                      MID-HUDSON RIVER SEDIMENT-Adolescent Recreate*
             Scenario Timelrame. Current/Future
             Medium Sediment
             Exposure Medium Sediment
             Exposure Point  Banks ol Mid-Hudson
             Receptor Population  Recreator
             Receptor Age Adolescent	
Exposure
Route


ngestion
Dermal

Chemical
of Potential
Concern

PCBs
PCBs
Medium
EPC
Value

066
066
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

066
0.66
Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
(or Hazard
Calculation (1)
M
M
Intake
(Non-Cancer)


4.2E-08
1.3E-07
Intake
(Non -Cancer)
Units

mg/kg-day
mg/kg-day
Reference
Dose


7.0E-05
7.0E-OS
Reference
Dose Units


mg/kg-day
mg/kg-day
Reference
Concentration


N/A
N/A
Reference
Concentration
Units

N/A
N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.00060
0.0018
0.0024
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                              TMAS/Gradient Corporation

-------
                                                                                  TABLE 4-4-RME (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                        MID-HUDSON RIVER SEDIMENT - Child Recreator
             Scenario Timelrame. Current/Future
             Medium. Sediment
             Exposure Medium- Sediment
             Exposure Point  Banks of Mid-Hudson
             Receptor Population- Recrealor
             Receptor Age- Child	
Exposure
Route


Ingestion
Dermal
Chemical
of Potential
Concern

PCBs
PCBs
Medium
EPC
Value

0.64
0.64
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

0.64
064
Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
for Hazard
Calculation (1)
M
M
Intake
(Non-Cancer)


1.5E-07
12E-07
Intake
(Non-Cancer)
Units

mg/kg-day
mg/kg-day
Reference
Dose


70E-05
70E-OS
Reference
Dose Units


mg/kg-day
mg/kg-day
Reference
Concentration


N/A
N/A
Total Hazard Index Across All Exposure Routes/
Reference
Concentration
Units

N/A
N/A
Pathways
Hazard
Quotient


0.0022
0.0017
0.0039
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-4-CT (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                              CENTRAL TENDENCY EXPOSURE
                                                                        MID-HUDSON RIVER SEDIMENT - Child Recreator
             Scenario Timelrame  Current/Future
             Medium Sediment
             Exposure Medium  Sediment
             Exposure Point  Banks of Mid-Hudson
             Receptor Population. Recreator
             Receptor Age  Child	
Exposure
Route


Ingestion
Dermal
Chemical
of Potential
Concern

PCBs
PCBs
Medium
EPC
Value

066
066
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

066
0.66
Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
for Hazard
Calculation (1)
M
M
Intake
(Non-Cancer)


84E-08
6.6E-08
Intake
(Non-Cancer)
Units

mg/kg-day
mg/kg-day
Reference
Dose


70E-05
7.0E-05
Reference
Dose Units


mg/kg-day
mg/kg-day
Reference
Concentration


N/A
N/A
Reference
Concentration
Units

N/A
N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.0012
0.0009
0.0021
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation.
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-5-RME (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                         MID-HUDSON RIVER WATER - Adult Recreator
             Scenario Timeframe. Current/Future
             Medium: River Water
             Exposure Medium. River Water
             Exposure Point. Mid-Hudson River
             Receptor Population  Recreator
             Receptor Age. Adult	
Exposure
Route


Dermal
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

8.8E-06

Medium
EPC
Units

mg/L
Route
EPC
Value

8.8E-06
Route
EPC
Units

mg/L
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


1.0E-07
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


7.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.0014
0.0014
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                   TABLE 4-5-CT (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                              CENTRAL TENDENCY EXPOSURE
                                                                         MID-HUDSON RIVER WATER • Adult Recrealor
             Scenario Timeframe  Current/Future
             Medium  River Water
             Exposure Medium  River Water
             Exposure Point  Mid-Hudson River
             Receptor Population  Recreator
             Receptor Age- Adult	
Exposure
Route


Dermal
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1 5E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.5E-05
Route
EPC
Units

mg/L
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


9.3E-08
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


70E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Total Hazard Index Across All Exposure Routes/
Reference
Concentratlor
Units

N/A
Pathways
Hazfird
Quotient


0.0013
0.0013
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-6-RME (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                       MID-HUDSON RIVER WATER - Adolescent Recreator
             Scenario Timeframe  Current/Future
             Medium River Water
             Exposure Medium River Water
             Exposure Poinf Mid-Hudson River
             Receptor Population- Recreator
             Receptor Age' Adolescent	
Exposure
Route


Dermal
Chemical
ol Potential
Concern

PCBs
Medium
EPC
Value

1.1E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

LIE-OS
Route
EPC
Units

mg/L
EPC
Selected
lor Hazard
Calculation (1)
M
Intake
(Non-Cancer)


45E-07
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


7.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Total Hazard Index Across All Exposure Routes/
Reference
Concentration
Units

N/A
Pathways
Hazard
Quotient


O.0064
0.0064
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                             TAMS/ Gradual Corporation

-------
                                                                                   TABLE 4-6-CT (Revised)
                                                                           CALCULATION OF NON-CANCER HAZARDS
                                                                               CENTRAL TENDENCY EXPOSURE
                                                                       MID-HUDSON RIVER WATER • Adolescent Recreator
             Scenario Timeframe  Current/Future
             Medium River Water
             Exposure Medium- River Water
             Exposure Point: Mid-Hudson River
             Receptor Population  Recreator
             Receptor Age  Adolescent	
Exposure
Route


dermal
Chemical
ol Potential
Concern

PCBs
Medium
EPC
Value

1 6E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1 6E-05
Route
EPC
Units

mg/L
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


33E-07
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


7.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.0048
00048
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                               "TMASI Gradient Corporation

-------
                                                                                  TABLE 4-7-RME (Revised)
                                                                           CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                          MID-HUDSON RIVER WATER - Child Recreator
             Scenario Timeframe: Current/Future
             Medium. River Water
             Exposure Medium. River Water
             Exposure Point  Mid-Hudson River
             Receptor Population: Recreator
             Receptor Age  Child	
Exposure
Route


Dermal
Chemical
of Potential
Concern

PCBs

Medium
EPC
Value

14E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.4E-05
Route
EPC
Units

mg/L
EPC
Selected
lor Hazard
Calculation (1)
M
Intake
(Non-Cancer)


29E-O7
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


70E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Total Hazard Index Across All Exposure Routes/
Reference
Concentration
Units

N/A
Pathways
Hazard
Quotient


00041
0.0041
(1)   Specify Medium-Specilic (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                               TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-7-CT (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                              CENTRAL TENDENCY EXPOSURE
                                                                         MID-HUDSON RIVER WATER - Child Recrealor
             Scenario Timeframe Current/Future
             Medium River Water
             Exposure Medium  River Water
             Exposure Point  Mid-Hudson River
             Receptor Population  Recrealor
             Receptor Age Child	
Exposure
Route


Dermal

Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

16E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.6E-05
Route
EPC
Units

mg/L
EPC
Selected
lor Hazard
Calculation (1)
M
Intake
(Non-Cancer)


1.8E-07
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


7.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentre tior
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.0025
00025
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-8-RME (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                          MID-HUDSON RIVER WATER - Adult Resident
             Scenario Timaframe  Current/Future
             Medium- River Water
             Exposure Medium River Water
             Exposure Point. Mid-Hudson River
             Receptor Population  Resident
             Receptor Age- Aduli	
Exposure
Route


ngestion

Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

8.8E-06
Medium
EPC
Units

mg/L
Route
EPC
Value

88E-06
Route
EPC
Units

mg/L
EPC
Selected
lor Hazard
Calculation (1)
M
Intake
(Non-Cancer)


28E-07
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


7.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.0040
0.0040
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation.
                                                                                                                                                              TAMS/Gradient Corporation

-------
                                                                                   TABLE 4-8-CT (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                              CENTRAL TENDENCY EXPOSURE
                                                                          MID-HUDSON RIVER WATER - Adult Resident
             Scenario Timaframe- Current/Future
             Medium: River Water
             Exposure Medium. River Water
             Exposure Point  Mid-Hudson River
             Receptor Population  Resident
             Receptor Age  Adult	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

15E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1 5E-05
Route
EPC
Units

mg/L
EPC
Selected
(or Hazard
Calculation (1)
M
Intake
(Non-Cancer)


2.9E-07
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


70E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.0041
00041
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-9-RME (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                             REASONABLE MAXIMUM EXPOSURE
                                                                       MID-HUDSON RIVER WATER - Adolescent Resident
             Scenario Timeframe:  Current/Future
             Medium River Water
             Exposure Medium- River Water
             Exposure Point  Mid-Hudson River
             Receptor Population: Resident
             Receptor Age- Adolescent	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.1E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1 IE-OS
Route
EPC
Units

mg/L
EPC
Selected
for Hazard
Calculation (t)
M
Intake
(Non-Cancer)


56E-07
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


7.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.0081
0.0081
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                             TAMS/ Gradient Corporation

-------
                                                                                   TABLE 4-9-CT (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                              CENTRAL TENDENCY EXPOSURE
                                                                       MID-HUDSON RIVER WATER - Adolescent Resident
             Scenario Timelrame  Current/Future
             Medium. River Water
             Exposure Medium River Water
             Exposure Point  Mid-Hudson River
             Receptor Population- Resident
             Receptor Age: Adolescent	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

RGBs
Medium
EPC
Value

16E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

16E-05
Route
EPC
Units

mg/L
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


5.0E-07
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


7.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.0071
0.0071
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                                  TABLE 4-10-RME (Revised)
                                                                           CALCULATION OF NON-CANCER HAZARDS
                                                                              REASONABLE MAXIMUM EXPOSURE
                                                                           MID-HUDSON RIVER WATER - Child Resident
              Scenario Timeframe  Current/Future
              Medium: River Water
              Exposure Medium River Water
              Exposure Point. Mid-Hudson River
              Receptor Population  Resident
              Receptor Age  Child	
Exposure
Route


Ingeslion

Chemical
o! Potential
Concern

PCBs
Medium
EPC
Value

14E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.4E-05
Route
EPC
Units

mg/L
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


13E-06
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


7.0E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0.019
0.019
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected lor hazard calculation
                                                                                                                                                               TAMS/ Gradient Corporation

-------
                                                                                   TABLE 4-10-CT (Revised)
                                                                          CALCULATION OF NON-CANCER HAZARDS
                                                                              CENTRAL TENDENCY EXPOSURE
                                                                          MID-HUDSON RIVER WATER - Child Resident
             Scenario Timelrame  Current/Future
             Medium- River Water
             Exposure Medium River Water
             Exposure Point  Mid-Hudson River
             Receptor Population  Resident
             Receptor Age. Child	
Exposure
Route


Ingeslion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.6E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1 6E-O5
Route
EPC
Units

mg/L
EPC
Selected
for Hazard
Calculation (1)
M
Intake
(Non-Cancer)


89E-07
Intake
(Non-Cancer)
Units

mg/kg-day
Reference
Dose


70E-05
Reference
Dose Units


mg/kg-day
Reference
Concentration


N/A
Reference
Concentration
Units

N/A
Total Hazard Index Across All Exposure Routes/Pathways
Hazard
Quotient


0013
0.013
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for hazard calculation
                                                                                                                                                               TAMS/ Gradient Corporation

-------
                                                                      TABLE 4-1 la-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                  REASONABLE MAXIMUM EXPOSURE
                                                                 MID-HUDSON RIVER FISH - Adult Angler
             Scenario Timeframe: Current/Future
             Medium: Fish
             Exposure Medium: Fish
             Exposure Point: Mid-Hudson Fish
             Receptor Population: Angler
             Receptor Age: Adult	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.1
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1.1
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


1.6E-04
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


2
Cancer Slope
Factor Units


(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


3.2E-04
3.2E-04
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-1 la-CT (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                   CENTRAL TENDENCY EXPOSURE
                                                                 MID-HUDSON RIVER FISH - Adult Angler
              Scenario Timeframe: Current/Future
              Medium. Fish
              Exposure Medium. Fish
              Exposure Point: Mid-Hudson Fish
              Receptor Population. Angler
              Receptor Age1 Adult	
Exposure
Route


Ingestion

Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.4
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1.4
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


5.5E-06
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


1
Cancer Slope
Factor Units


(mg/kg-day)-1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


5 5E-06
5.5E-06
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                         TAMS/ Gradient Corporation

-------
                                                                     TABLE 4-1 Ib-RME (Revised)
                                                                  CALCULATION OF CANCER RISKS
                                                                 REASONABLE MAXIMUM EXPOSURE
                                                              MID-HUDSON RIVER FISH - Adolescent Angler
             Scenario Timeframe: Current/Future
             Medium- Fish
             Exposure Medium: Fish
             Exposure Point. Mid-Hudson Fish
             Receptor Population: Angler
             Receptor Age: Adolescent	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.3
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1.3
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Risk
Calculation (1)
Intake
(Cancer)


M 1.1E-04
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


2
Cancer Slope
Factor Units


(mg/kg-day)'1
Cancer
Risk
~

2.2E-04
                                                                                                   i oiai riisK Across MM exposure nouies/r'ainways
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                       TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-11 b-CT (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                   CENTRAL TENDENCY EXPOSURE
                                                              MID-HUDSON RIVER RSH - Adolescent Angler
             Scenario Timeframe: Current/Future
             Medium. Fish
             Exposure Medium: Fish
             Exposure Point: Mid-Hudson Fish
             Receptor Population- Angler
             Receptor Age: Adolescent	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.5
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1 5
Route
EPC
Units

mg/kg wt weight
EPC
Selected
(or Risk
Calculation (1)
M
Intake
(Cancer)


3.2E-06
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


1
Cancer Slope
Factor Units


(mg/kg-day)''
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


3.2E-06
3.2E-06
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                      TABLE 4-1 ic-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                  REASONABLE MAXIMUM EXPOSURE
                                                                 MID-HUDSON RIVER FISH - Child Angler
             Scenario Timeframe: Current/Future
             Medium: Fish
             Exposure Medium: Fish
             Exposure Point: Mid-Hudson Fish
             Receptor Population: Angler
             Receptor Age: Child	
Exposure
Route


Ingeslion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.4
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1.4
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


8.5E-05
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


2
Cancer Slope
Factor Units


(mg/kg-day)"1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


1.7E-04
1 .7E-04
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                      TABLE 4-11c-CT (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                   CENTRAL TENDENCY EXPOSURE
                                                                 MID-HUDSON RIVER FISH - Child Angler
             Scenario Timeframe. Current/Future
             Medium- Fish
             Exposure Medium-  Fish
             Exposure Point- Mid-Hudson Fish
             Receptor Population: Angler
             Receptor Age: Child	
Exposure
Route


Ingestion

Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1 5
Medium
EPC
Units

mg/kg wt weight
Route
EPC
Value

1.5
Route
EPC
Units

mg/kg wt weight
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


4.5E-06
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


1
Cancer Slope
Factor Units


(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


4.5E-06
4.5E-06
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                      TABLE 4-12-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                 REASONABLE MAXIMUM EXPOSURE
                                                             MID-HUDSON RIVER SEDIMENT- Adult Recreator
             Scenario Timeframe: Current/Future
             Medium: Sediment
             Exposure Medium: Sediment
             Exposure Point- Banks of Mid-Hudson
             Receptor Population: Recreator
             Receptor Age: Adult	
Exposure
Route


Ingestion
Dermal

Chemical
of Potential
Concern

PCBs
PCBs

Medium
EPC
Value

0.53
0.53

Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

053
0.53
Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
for Risk
Calculation (1)
M
M
Intake
(Cancer)


4.4E-09
2.3E-08
Intake
(Cancer)
Units

mg/kg-day
mg/kg-day
Cancer Slope
Factor


2
2
Cancer Slope
Factor Units


(mg/kg-day)"1
(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk

-
8.9E-09
4.5E-08
5.4E-08
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                       TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-12-CT (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                   CENTRAL TENDENCY EXPOSURE
                                                             MID-HUDSON RIVER SEDIMENT- Adult Recreator
             Scenario Timeframe. Current/Future
             Medium: Sediment
             Exposure Medium  Sediment
             Exposure Point Banks of Mid-Hudson
             Receptor Population: Recreator
             Receptor Age: Adult	
Exposure
Route


Ingestion
Dermal
Chemical
of Potential
Concern

PCBs
PCBs
Medium
EPC
Value

0.65
0.65
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

065
0.65
Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
for Risk
Calculation (1)
M
M
Intake
(Cancer)


6.4E-10
3.2E-09
Intake
(Cancer)
Units

mg/kg-day
mg/kg-day
Cancer Slope
Factor


1
1
Cancer Slope
Factor Units


(mg/kg-day)'1
(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


6.4E-10
3.2E-09
3.9E-09
(1)   Specify Medium-Specilic (M) or Route-Specific (R) EPC selected for nsk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-13-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                  REASONABLE MAXIMUM EXPOSURE
                                                           MID-HUDSON RIVER SEDIMENT- Adolescent Recreate*
             Scenario Timeframe:  Current/Future
             Medium: Sediment
             Exposure Medium: Sediment
             Exposure Point:  Banks of Mid-Hudson
             Receptor Population:  Recreator
             Receptor Age: Adolescent	
Exposure
Route


Ingestion
Dermal
Chemical
of Potential
Concern

PCBs
PCBs
Medium
EPC
Value

059
0.59
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

0.59
0.59
Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
for Risk
Calculation (1)
M
M
Intake
(Cancer)


1.3E-OB
3.7E-08
Intake
(Cancer)
Units

mg/kg-day
mg/kg-day
Cancer Slope
Factor


2
2
Cancer Slope
Factor Units


(mg/kg-day)"1
(mg/kg-day)"'
Total Risk Across All Exposure Routes/Pathways
Cancer
••t
Risk


2.5E-08
7.5E-08
1 .OE-07
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-13-CT (Revised)
                                                                  CALCULATION OF CANCER RISKS
                                                                  CENTRAL TENDENCY EXPOSURE
                                                          MID-HUDSON RIVER SEDIMENT- Adolescent Recreator
             Scenario Timeframe. Current/Future
             Medium: Sediment
             Exposure Medium: Sediment
             Exposure Point. Banks ot Mid-Hudson
             Receptor Population: Recreator
             Receptor Age: Adolescent
Exposure
Route


Ingestion
Dermal
Chemical
of Potential
Concern

PCBs
PCBs
Medium
EPC
Value

066
066
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

0.66
0.66
Route
EPC
Units

mg/kg
mg/kg

EPC
Selected
for Risk
Calculation (1)
M
M
Intake
(Cancer)


1.8E-09
5.4E-09
Intake
(Cancer)
Units

mg/kg-day
mg/kg-day
Cancer Slope
Factor


1
1
Cancer Slope
Factor Units


(mg/kg-day)"1
(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


1.8E-09
5.4E-09
7.2E-09
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                       TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-14-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                  REASONABLE MAXIMUM EXPOSURE
                                                             MID-HUDSON RIVER SEDIMENT - Child Recreator
              Scenario Tlmeframa: Current/Future
              Medium: Sediment
              Exposure Medium: Sediment
              Exposure Point: Banks of Mid-Hudson
              Receptor Population. Recreator
              Receptor Age- Child	
Exposure
Route

Ingestion
Dermal
Chemical
of Potential
Concern

PCBs
PCBs

Medium
EPC
Value

064
0.64
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

0.64
0.64

Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
for Risk
Calculation (1)
M
M
Intake
(Cancer)

1.3E-08
1.0E-08
Intake
(Cancer)
Units

mg/kg-day
mg/kg-day
Cancer Slope
Factor

2
2
Cancer Slope
Factor Units

(mg/kg-day)'1
(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk
-
2 6E-08
2.0E-08
4.6E-08
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                       TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-14-CT (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                   CENTRAL TENDENCY EXPOSURE
                                                             MID-HUDSON RIVER SEDIMENT - Child Recreator
             Scenario Timeframa Current/Future
             Medium. Sediment
             Exposure Medium-  Sediment
             Exposure Point: Banks of Mid-Hudson
             Receptor Populaton. Recreator
             Receptor Age. Child	
Exposure
Route


Ingestion
Dermal
Chemical
of Potential
Concern

PCBs
PCBs
Medium
EPC
Value

0.66
0.66
Medium
EPC
Units

mg/kg
mg/kg
Route
EPC
Value

0.66
0.66

Route
EPC
Units

mg/kg
mg/kg
EPC
Selected
for Risk
Calculation (1)
M
M
Intake
(Cancer)


3.6E-09
2.8E-09
Intake
(Cancer)
Units

mg/kg-day
mg/kg-day
Cancer Slope
Factor


1
1
Cancer Slope
Factor Units


(mg/kg-day)'1
(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


3.6E-O9
2.8E-09
6.4E-09
(1)   Specify Medium-Specific (M) or Route-Specilic (R) EPC selected for risk calculation.
                                                                                                                                       TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-15-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                  REASONABLE MAXIMUM EXPOSURE
                                                               MID-HUDSON RIVER WATER - Adult Recreator
             Scenario Timeframe- Current/Future
             Medium- River Water
             Exposure Medium: River Water
             Exposure Point: Mid-Hudson River
             Receptor Population: Recreator
             Receptor Age1 Adult	
Exposure
Route


Dermal

Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

8.SE-06
Medium
EPC
Units

mg/L
Route
EPC
Value

8.BE-06

Route
EPC
Units

mg/L
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


3.3E-08
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.4
Cancer Slope
Factor Units


(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk '


1.3E-08
1.3E-08
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                        TABLE 4-15-CT (Revised)
                                                                    CALCULATION OF CANCER RISKS
                                                                    CENTRAL TENDENCY EXPOSURE
                                                               MID-HUDSON RIVER WATER - Adult Recreator
              Scenario Timeframe: Current/Future
              Medium. River Water
              Exposure Medium1 River Water
              Exposure Point:  Mid-Hudson River
              Receptor Population: Recreator
              Receptor Age: Adult	
Exposure
Route


Dermal
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1 5E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.5E-05

Route
EPC
Units

mg/L
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


6.6E-09
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.3
Cancer Slope
Factor Units


(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


2.0E-09
2.0E-09
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                         TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-16-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                  REASONABLE MAXIMUM EXPOSURE
                                                            MID-HUDSON RIVER WATER - Adolescent Recreator
             Scenario Timeframe- Current/Future
             Medium. River Water
             Exposure Medium:  River Water
             Exposure Point: Mid-Hudson River
             Receptor Population: Recreator
             Receptor Age: Adolescent
Exposure
Route


Dermal
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1 IE-OS

Medium
EPC
Units

mg/L

Route
EPC
Value

1. IE-OS

Route
EPC
Units

mg/L

EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


7.7E-08
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.4
Cancer Slope
Factor Units


(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk

1
3.1E-08
31E-OS
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-16-CT (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                   CENTRAL TENDENCY EXPOSURE
                                                            MID-HUDSON RIVER WATER - Adolescent Recreator
             Scenario Timeframe Current/Future
             Medium: River Water
             Exposure Medium  River Water
             Exposure Point: Mid-Hudson River
             Receptor Population: Recreator
             Receptor Age: Adolescent	
Exposure
Route


Dermal
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.6E-05

Medium
EPC
Units

mg/L
Route
EPC
Value

1.6E-05
Route
EPC
Units

mg/L
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


1.4E-08
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.3
Total Risk Across All Exposure Routes/
Cancer Slope
Factor Units


(mg/kg-day)-1
Pathways
Cancer
Risk


4.3E-09
4.3E-09
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation
                                                                                                                                        TAMS/ Gradual Corporation

-------
                                                                       TABLE 4-17-RME (Revised)
                                                                    CALCULATION OF CANCER RISKS
                                                                   REASONABLE MAXIMUM EXPOSURE
                                                               MID-HUDSON RIVER WATER - Child Recreator
              Scenario Timeframe: Current/Future
              Medium: River Water
              Exposure Medium: River Water
              Exposure Point: Mid-Hudson River
              Receptor Population: Recreator
              Receptor Age: Child
Exposure
Route


Dermal
Chemical
of Potental
Concern

PCBs
Medium
EPC
Value

1 4E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.4E-05

Route
EPC
Units

mg/L
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


24E-08
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.4
Cancer Slope
Factor Units


(mg/kg-day)-1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk

\
9.8E-09
9 8E-09
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-17-CT (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                   CENTRAL TENDENCY EXPOSURE
                                                              MID-HUDSON RIVER WATER - Child Recraator
             Scenario Timelrama. Current/Future
             Medium: River Water
             Exposure Medium:  River Water
             Exposure Point- Mid-Hudson River
             Receptor Population: Recreator
             Receptor Age: Child	
Exposure
Route


Dermal
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.6E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.6E-05

Route
EPC
Units

mg/L
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


7.5E-09
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.3
Cancer Slope
Factor Units


(mg/kg-day)1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


2.3E-09
2.3E-09
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                      TABLE 4-18-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                 REASONABLE MAXIMUM EXPOSURE
                                                              MID-HUDSON RIVER WATER - Adult Resident
             Scenario Timeframe: Current/Future
             Medium- River Water
             Exposure Medium:  River Water
             Exposure Point. Mid-Hudson River
             Receptor Population: Resident
             Receptor Age: Adult
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

8 8E-06
Medium
EPC
Units

mg/L

Route
EPC
Value

8.8E-06
Route
EPC
Units

mg/L
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


9.1E-08
intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.4
Cancer Slope
Factor Units


(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


3.6E-08
3.6E-08
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                      TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-18-CT (Revised)
                                                                  CALCULATION OF CANCER RISKS
                                                                  CENTRAL TENDENCY EXPOSURE
                                                              MID-HUDSON RIVER WATER - Adult Resident
             Scenario Timeframe. Current/Future
             Medium: River Water
             Exposure Medium River Water
             Exposure Point- Mid-Hudson River
             Receptor Population: Resident
             Receptor Age: Adult	
Exposure
Route


Ingestion

Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1 5E-05
Medium
EPC
Units

mg/L

Route
EPC
Value

15E-05
Route
EPC
Units

mg/L

EPC
Selected
for Risk
Calculation (1)
M

Intake
(Cancer)


2.1E-08
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.3
Cancer Slope
Factor Units


(mg/kg-day)*1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


6.2E-09
6.2E-09
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation
                                                                                                                                       TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-19-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                  REASONABLE MAXIMUM EXPOSURE
                                                            MID-HUDSON RIVER WATER - Adolescent Resident
             Scenario Timeframe: Current/Future
             Medium: River Water
             Exposure Medium- River Water
             Exposure Point: Mid-Hudson River
             Receptor Population: Resident
             Receptor Age: Adolescent
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1.1E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1. IE-OS

Route
EPC
Units

mg/L
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


9.7E-08
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.4
Cancer Slope
Factor Units


(mg/kg-day)"1
Total Risk Across All Exposure Routes/Pathways
Cancer
:•- Risk


3.9E-08
3.9E-08
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-19-CT (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                   CENTRAL TENDENCY EXPOSURE
                                                            MID-HUDSON RIVER WATER - Adolescent Resident
             Scenario Timeframe. Current/Future
             Medium: River Water
             Exposure Medium* River Water
             Exposure Point: Mid-Hudson River
             Receptor Population Resident
             Receptor Age. Adolescent	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs
Medium
EPC
Value

1 6E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.6E-05
Route
EPC
Units

mg/L
EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


2.1E-08
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.3
Cancer Slope
Factor Units


(mg/kg-day)"'
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


6.4E-09
6.4E-09
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for nsk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-20-RME (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                  REASONABLE MAXIMUM EXPOSURE
                                                               MID-HUDSON RIVER WATER - Child Resident
             Scenario Timeframe: Current/Future
             Medium: River Water
             Exposure Medium:  River Water
             Exposure Point: Mid-Hudson River
             Receptor Population: Resident
             Receptor Age: Child	
Exposure
Route


Ingestion
Chemical
of Potental
Concern

PCBs
Medium
EPC
Value

1.4E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.4E-05
Route
EPC
Units

mg/L
EPC
Selected
for Risk
Calculation (1)
M

Intake
(Cancer)


1.2E-07
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.4
Cancer Slope
Factor Units
-

{mg/kg-day)1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


4.6E-08
4.6E-08
(1)   Specify Medium-Specific (M) or Route-Specific (R) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
                                                                       TABLE 4-20-CT (Revised)
                                                                   CALCULATION OF CANCER RISKS
                                                                   CENTRAL TENDENCY EXPOSURE
                                                              MID-HUDSON RIVER WATER - Child Resident
             Scenario Timeframe. Current/Future
             Medium. River Water
             Exposure Medium: River Water
             Exposure Point: Mid-Hudson River
             Receptor Population: Resident
             Receptor Age: Child	
Exposure
Route


Ingestion
Chemical
of Potential
Concern

PCBs

Medium
EPC
Value
•
1 6E-05
Medium
EPC
Units

mg/L
Route
EPC
Value

1.6E-05
Route
EPC
Units

mg/L

EPC
Selected
for Risk
Calculation (1)
M
Intake
(Cancer)


3.8E-08
Intake
(Cancer)
Units

mg/kg-day
Cancer Slope
Factor


0.3
Cancer Slope
Factor Units


(mg/kg-day)'1
Total Risk Across All Exposure Routes/Pathways
Cancer
Risk


1.1E-08
1.1E-08
(1)   Specify Medium-Specific (M) or Route-Specific (H) EPC selected for risk calculation.
                                                                                                                                        TAMS/ Gradient Corporation

-------
enario Timeframe: Currant/Future
     r Population  Angler
   or Age- Adult
                                                                  TABLE 4-2U-RME (Revised)

                                                     SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs

                                                               REASONABLE MAXIMUM EXPOSURE

                                                                MID-HUDSON RIVER - Adult Angler

Medium
Fish
Exposure
Medium
Fish
Exposure
Point
Mid-Hudson Fish
Chemical
3CBs
Carcinogenic Risk
Ingesten
3.2E-04
Inhalation
_-
Dermal
-
Total Risk Across Fish
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
32E-04
32E-04
3.2E-04
Chemical
:>CBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
LOAEL
Ingesuon
32
Inhalation
—
Dermal
—
Total Hazard Index Across All Madia and All Exposure Routes



Exposure
Routes Total
32
32
h ll
                                                                                                                                                Total LOAEL HI = I
                                                                                                                                                                    32
                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                TABLE 4-21 a-CT (Revised)

                                                  SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs

                                                             CENTRAL TENDENCY EXPOSURE

                                                             MID-HUDSON RIVER - Adult Angler
irlo TImetrame Current/Future
   Population: Angler
   Age-  Adult	
Medium
-ish
Exposure
Medium
Fish
Exposure
Point
Mid-Hudson Fish

Chemical
PCBs
Carcinogenic Risk
Ingestnn
5.5E-O6
Inhalation
-
Dermal
-
Total Risk Across Fish
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
5.5E-06
5.5E-06
5.5E-06
Chemical

PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
LOAEL
Ingestton
3
Inhalation
-
Dermal
-
Total Hazard Index Across All Media and All Exposure Routes

Exposure
Routes Total
3
3
n==^=ii
                                                                                                                                             Total LOAEL HI:
                                                                                                                                          TAMS/ Gradient Corporation

-------
             TABLE 4-21D-RME (Revised)
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs
          REASONABLE MAXIMUM EXPOSURE
         MID-HUDSON RIVER - Adolescent Angler

Medium
Fish
Scenario Tlmaframe' Current/Future ll
Receptor Population: Angler II
Receptor Age: Adolescent ||
Exposure
Medium
Fish

Exposure
Point
Mid-Hudson Fish

Chemical
PCBs
Carcinogenic Risk
Ingesbon
2.2E-04
Inhalation
-
Dermal
-
Total Risk Across Fish
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
2.2E-04
2.2E-04
2.2E-O4
Chemical -

PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
LOAEL
IflQBStlOn
35
Inhalation
-
Dermal
—
Total Hazard Index Across All Media and All Exposure Routes

Exposure
Routes Total
35
35
h ll
                                                                                        Total LOAEL HI =
                                                                                                            35
                                                                                      TAMS/ Gradient Corporation

-------
                                                               TABLE 4-21D-CT (Revised)

                                                 SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs

                                                            CENTRAL TENDENCY EXPOSURE

                                                          MID-HUDSON RIVER - Adolescent Angler
Timeframe- Current/Future
Population. Angler
Age: Adolescent	
Medium
Fish
Exposure
Medium
Fish
Exposure
Point
Mid-Hudson Fish
Chemical
PCBs
Carcinogenic Risk
Ingcslion
32E-06
Inhalation
-
Dermal
-
Total Risk Across Fist
Total Risk Across All Media and AH Exposure Routes
Exposure
Routes Total
32E-06
32E-06
32E-06
Chemical

PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
LOAEL
Ingestion
4
Inhalation
-
Dermal
-
Total Hazard Index Across All Media and All Exposure Routes


Exposure
Routes Total
4
4
I===5I
                                                                                                                                              Total LOAEL HI =
                                                                                                                                            TAMS/ Gradient Corporation

-------
      > Thneframe: Current/Future
      r Population. Angler
Receptor Age. Child	
                                                                    TABLE 4-21C-RME (Revised)
                                                       SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs
                                                                 REASONABLE MAXIMUM EXPOSURE
                                                                  MID-HUDSON RIVER - Child Angler
Medium
Fish
Exposure
Medium
Fish
Exposure
Point
Mid-Hudson Fcsh
Chemical
PCBs
Carcinogenic Risk
digestion
17E-04
Inhalation
-
Dermal
-
Total Risk Across Fish
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
1.7E-04
1.7E-04
1.7E-04
Chemical
PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
LOAEL
Ingestlon
49
Inhalation
—
Dermal
—
Total Hazard Index Across All Media and All Exposure Routes


Exposure
Routes Total
49
49
li ll
                                                                                                                                                  Total LOAEL HI =
                                                                                                                                                                       49
                                                                                                                                                TAMS/ Gradient Corporation

-------
                                                                TABLE 4-21C-CT (Revised)

                                                 SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs

                                                             CENTRAL TENDENCY EXPOSURE

                                                             MID-HUDSON RIVER • Child Angler
> Timeframe  Current/Future
r Population  Angler
rAqe  Child	
Medium
Fish
Exposure
Medium
Fish
Exposure
Point
Mid-Hudson Fish
Chemical
RGBs
Carcinogenic Risk
InQBstion
45E-06
Inhalation
-
Dermal
-
Total Risk Across Fish
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
45E-06
4.5E-06
4.5E-06
Chemical
'CBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
LOAEL
Ingestlon
5
Inhalation
-
Dermal
-
Total Hazard Index Across All Media and All Exposure Routes


Exposure
Routes Total
5
5

                                                                                                                                              Total LOAEL HI = I
                                                                                                                                           TAMS/ Gradient Corporation

-------
             TABLE 4-21C-RME (Revised)
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs
          REASONABLE MAXIMUM EXPOSURE
           MID-HUDSON RIVER • Child Angler
llScenano Tlmeframe: Current/Future
((Receptor Population: Angler
[(Receptor Aqe Child
Medium
Fish
Exposure
Medium
Fish
Exposure
Point
Mid-Hudson Fish

Chemical
PCBs
Carcinogenic Risk
Ingestion
17E-04
Inhalation
-
Dermal
-
Total Risk Across Flsr
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
1.7E-04
17E-04
17E-04
Chemical

PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
LOAEL
Ingestion
49
Inhalation
—
Dermal
—
Total Hazard Index Across All Media and All Exposure Routes



Exposure
Routes Total
49
49
li ll
                                                                                        Total LOAEL HI = I
49
                                                                                      TAMS/ Gradient Corporation

-------
      > Timeframe  Current/Future
Receptor Population. Angler
Receptor Age  Child	
                                                                      TABLE 4-21C-CT (Revised)

                                                        SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs

                                                                   CENTRAL TENDENCY EXPOSURE

                                                                   MID-HUDSON RIVER • Child Angler
Medium
Fish
Exposure
Medium
Fish
Exposure
Point
Mid-Hudson Fish
Chemical
PCBs
Carcinogenic Risk
Ingeslion
45E-06
Inhalation
-
Dermal
-
Total Risk Across Fish
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
45E-06
45E-OS
4.5E-06
Chemical
PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
LOAEL
Ingesbon
5
Inhalation
-
Dermal
-
Total Hazard Index Across All Media and All Exposure Routes


Exposure
Routes Total
5
S
B===^=il
                                                                                                                                                     Total LOAEL HI =
                                                                                                                                                  TAMS/ Gradient Corporation

-------
              TABLE 4-23-RME (Revised)
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs
          REASONABLE MAXIMUM EXPOSURE
       MID-HUDSON RIVER - Adolescent Recreator
llScenarloTimeframe Current/Future
HReceplor Population Recreator
((Receptor Aqe. Adolescent
Medium
Sediment
River Water
Exposure
Medium
Sediment
River Water
Exposure
Point
Banks of Mid-Hudson
Mid-Hudson River

Chemical
PCBs
PCBs
Carcinogenic Risk
InQestion
2.5E-08
Inhalation
-
Dermal
7.5E-08
3.1E-08
Total Risk Across Sediment
Total Risk Across River Watei
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
1.0E-07
3.1E-O8
1.0E-07
31E-08
13E-07
Chemical
»CBs
PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
NOAEL
NOAEL
Ingestlon
00010
Inhalation
-
Dermal
00031
00064
Total Hazard Index Across All Media and All Exposure Routes


Total NOAEL HI =
Exposure
Routes Total
0.0042
0.0064
0.011
^^^^^^^^^^^^E^Sl
| 0.011 \\
b=^=^^^^^==l
                                                                                      TAMS/ Gradient Corporation

-------
                                                                  TABLE 4-23-CT (Revised)

                                                   SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs

                                                              CENTRAL TENDENCY EXPOSURE

                                                           MID-HUDSON RIVER - Adolescent Recreator
irio Timeframe: CurrentAFuture
 ir Population:  Recreator
 ir Age  Adolescent	
Medium
Sediment
River Water
Exposure
Medium
Sediment
River Water
Exposure
Point
Banks ol Mid-Hudson
Mid-Hudson River
Chemical
PCBs
PCBs
Carcinogenic Risk
Ingestnn
1 8E-09
Inhot&tion
~~
Dermal
54E-09
4.3E-09
Total Risk Across Sedimenl
Total Risk Across River Watei
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
72E-09
4.3E-09
7.2E-09
4.3E-09
1.1E-08
Chemical
=CBs
PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
NOAEL
NOAEL
Irtgastlon
000060
Inhalation
-
Dermal
0.0018
0.0048
Total Hazard Index Across All Media end All Exposure Routes
Exposure
Routes Total
00024
00048
0.0072
Total NOAEL HI = fl 00072 |
                                                                                                                                              TAMS/ Gradient Corporation

-------
                                                                    TABLE 4-24-RME (Revised)

                                                      SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs

                                                                REASONABLE MAXIMUM EXPOSURE

                                                                MID-HUDSON RIVER - Child Recreator
     Tlmeframe: Current/Future
    ir Population:  Recreator
captor Age. Child	
Medium
Sediment
River Water
Exposure
Medium
Sediment
River Water
Exposure
Point
Banks ol Mid-Hudson
Mid-Hudson River
Chemical
PCBs
PCBs
Carcinogenic Risk
Ingesuon
26E-08
Inhalstion
-
Dermal
20E-08
98E-09
Total Risk Across Sediment
Total Risk Across River Watei
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
46E-08
98E-09
4.6E-OS
9.8E-09
56E-08
Chemical

PCBs
PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
NOAEL
NOAEL
Ingestton
0.0022
Inhalation
-
Dermal
00017
00041
Total Hazard Index Across All Media and All Exposure Routes



Exposure
Routes Total
00039
0.0041
00079
Total NOAEL HI = || 0.0079 |
                                                                                                                                                  TAMS/ Gradient Corporation

-------
                                                                    TABLE 4-24-CT (Revised)

                                                     SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs

                                                                CENTRAL TENDENCY EXPOSURE

                                                               MID-HUDSON RIVER - Child Recreate*
inario Timeframe. Current/Future
    Population.  Recreator
    Aga.  Child	
Medium
Sediment
River Water
Exposure
Medium
Sediment
River Water
Exposure
Point
Banks of Mid-Hudson
Mid-Hudson River
Chemical
PCBs
PCBs
Carcinogenic Risk
Ingestion
36E-09
Inhalation
~~
Dermal
28E-09
2.3E-09
Total Risk Across Sediment
Total Risk Across River Water
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
64E-09
2.3E-09
6.4E-09
2.3E-09
8.7E-09
Chemical

>CBs
PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
NOAEL
NOAEL
Ingestion
00012
Inhalation
-
Dermal
0.0009
00025
Total Hazard Index Across All Media and All Exposure Routes


Exposure
Routes Total
00021
00025
0.0047
Total NOAEL HI = || 0.0047 |
                                                                                                                                               TAMS/ Gradient Corporation

-------
                                                                   TABLE 4-25-RME (Revised)
                                                     SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs
                                                               REASONABLE MAXIMUM EXPOSURE
                                                               MID-HUDSON RIVER - Adult Resident
     iTimeframe- Current/Future
eceptor Population  Resident
eceplorAge: Adult

Medium
River Water

Exposure
Medium
River Water
Exposure
Point
Mid-Hudson River

Chemical
PCBs
Carcinogenic Risk
Ingeslton
36E-08
Inhalation
-
Dermal
-
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
3.6E-08
36E-08
Chemical
PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
NOAEL
Ingestton
0.0040
Inhalation
—
Dermal
—
Total Hazard Index Across All Media and All Exposure Routes

Exposure
Routes Total
0.0040
0.0040
                                                                                                                                              TAMS/ Gradient Corporation

-------
              TABLE 4-25-CT (Revised)
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs
           CENTRAL TENDENCY EXPOSURE
          MID-HUDSON RIVER - Adult Resident

Medium
River Water
Scenario Timelrame: Current/Future II
Receptor Population: Resident II
Receptor Aqe. Adull l|
Exposure
Medium
River Water
Exposure
Point
Mid-Hudson River
Chemical
PCBs
Carcinogenic Risk
Ingestlon
Inhalation
6 2E-09 II
Dermal
-
Total Risk Across All Media and All Exposure Routes
Exposure
Routes Total
6.2E-09
6.2E-09
Chemical

PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
NOAEL
Ingestion
0.0041
Inhalation
—
Dermal
—
Total Hazard Index Across All Media and All Exposure Routes
Exposure
Routes Total
0.0041
0.0041
r * * —••' _ i
Total NOAEL HI = II 0.0041 |
                                                                                    TAMS/ Gradient Corporation

-------
             TABLE 4-26-RME (Revised)
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs
          REASONABLE MAXIMUM EXPOSURE
        MID-HUDSON RIVER -Adolescent Resident
(Scenario Ttmeframe. Current/Future
Receptor Population: Resident
IJReceptor Aqe Adolescent
Medium
River Water
Exposure
Medium
River Water
Exposure
Point
Mid-Hudson River

Chemical
PCBs
Carcinogenic Risk
Ingesuon
39E-08
Inhalation
-
Dermal
-
Exposure
Routes Total
3.9E-08
Total Risk Across All Media and All Exposure Routes || 3 9E-08
Chemical
PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
NOAEL
Ingostlon
00081
Inhalation
—
Dermal
—
Total Hazard Index Across All Media and All Exposure Routes

Exposure
Routes Total
00081

Total NOAEL HI = 0.0081 |
                                                                                     TAMS/ Gradient Corporation

-------
              TABLE 4-26-CT (Revised)
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs
           CENTRAL TENDENCY EXPOSURE
        MID-HUDSON RIVER - Adolescent Resident

Medium
liver Water
Scenario Timelrame. Current/Future I
Receptor Population: Resident II
Receptor Aqe Adolescent II
Exposure
Medium
River Water
Exposure
Point
Mid-Hudson River
Chemical
PCBs
Carcinogenic Risk
Ingestion
64E-09
Inhalation
-
Dermal
-
Total Risk Across All Madia and All Exposure Routes
Exposure
Routes Total
64E-09
6.4E-09
Chemical
PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
NOAEL
Ingestion
00071
Inhalation
—
Dermal
—
Total Hazard Index Across All Media end All Exposure Routes
Exposure
Routes Total
00071
00071
t^^^^SS^^^^^^SS*SS\
Total NOAEL HI = I) 00071 |
                                                                                       TAMS/ Gradient Corporation

-------
                                                              TABLE 4-27-RME (Revised)
                                                SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR COPCs
                                                          REASONABLE MAXIMUM EXPOSURE
                                                          MID-HUDSON RIVER - Child Resident
 Timeframe: Current/Future
 Population: Resident
irAge. Child	
Medium
River Water
Exposure
Medium
River Water
Exposure
Pant
Mid-Hudson River
Chemical
>CBs
Carcinogenic Risk
Ingastton
46E-08
Inhalation
-
Dermal
-
Total Risk Across All Media and All Exposure Routes


Exposure
Routes Total
46E-08
4.6E-08

Chemical

PCBs
Non-Carcinogenic Hazard Quotient
Primary
Target Organ
NOAEL
Ingeslton
0.019
Inhalation
—
Dermal
—
Total Hazard Index Across All Media and All Exposure Routes
Total NOAEL HI =

Exposure
Routes Total
0.019
0019
1 il
| 0.019 |
                                                                                                                                        TAMS/ Gradient Corporation

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   2.5
   2.0
!  1-5
   1.0 ••
o
o
   0.5
   0.0
                                                             Figure 2-1 (Revised)
                                               Average PCB Concentration in Brown Bullhead
                                                              Mid-Hudson River
                                                                                                       -River Miles 153.5-123.5
                                                                                                        (Farley Segments 1-3)

                                                                                                       -River Miles 123.5-93.5
                                                                                                        (Farley Segments 4-6)

                                                                                                       -River Miles 93.5 - 63.5 (Farley
                                                                                                        Segments 7-9)
1995        2000        2005        2010        2015
                                                                 2020        2025

                                                                       Year
2030        2035        2040        2045        2050
                                                                                                                         TAMS/ Gradient Corporation

-------
   0.9  -

   0.8

   0.7
£
&
I  0.6
   0.5
o
1
   0.4 +
   0.3
   0.2 --
   0.1
                                                                Figure 2-2 (Revised)
                                                    Average PCB Concentration in Yellow Perch
                                                                  Mid-Hudson River
              -River Miles 153.5 -123.5
               (Farley Segments 1-3)
              -River Miles 123.5 - 93.5
               (Farley Segments 4-6)
              -River Miles 93.5 - 63.5 (Farley
               Segments 7-9)
     1995        2000        2005        2010         2015        2020        2025
                                                                         Year
2030
2035
                        2040
                                    2045
                                    2050
                                                                                                                          TAMS/ Gradient Corporation

-------
  2.5
                                                            Figure 2-3 (Revised)
                                             Average PCB Concentration in Largemouth Bass
                                                             Mid-Hudson River
    2  •
   1.5
e,
c
o
    1 •
   0.5-
- River Miles 153.5 -123.5
 (Farley Segments 1-3)

-River Miles 123.5-93.5
 (Farley Segments 4-6)

-River Miles 93.5-63.5
 (Farley Segments 7-9)
     1995         2000        2005        2010         2015         2020        2025        2030        2035        2040        2045        2050

                                                                        Year
                                                                                                                       TAMS/ Gradient Corporation

-------
   6.00
   5.00 -
SjT 4.00
en
I
f 3.00
W

3
2.00
   1.00 --
   0.00
      1995
                                                             Figure 2-4 (Revised)
                                                 Average PCB Concentration in Striped Bass
                                                               Mid-Hudson River
                                                                                                          •River Miles 153.5-123.5
                                                                                                           (Farley Segments 1-3)

                                                                                                          -River Miles 123.5-93.5
                                                                                                           (Farley Segments 4-6)

                                                                                                          -River Miles 93.5-63.5
                                                                                                           (Farley Segments 7-9)
                  2000
                            2005
                                        2010
                                                    2015
                                                                 2020         2025

                                                                       Year
                                                                                           2030
2035        2040
                                                                                                                               2045
                                                                                                                                           2050
                                                                                                                         TAMS/ Gradient Corporation

-------
   1.6
   1.4
   1.2 •
I

i
f 0.8
c
o
c
o
o
   0.6
   0.4
   0.2
   0.0
     1990
                           2000
                                                           Figure 2-5 (Revised)
                                               Average PCB Concentration in White Perch
                                                            Mid-Hudson River
                                                                                                  •River Miles 153.5 - 73.5 (Farley
                                                                                                   Segments 1-8)
                                                 2010
2020
Year
2030
                     2040
                                                                                                                                      2050
                                                                                                                     TAMS/ Gradient Corporation

-------
                                                          Figure 2-6 (Revised)
                                   Average PCB Concentration by Species (averaged over location)
                                                           Mid-Hudson River
2.50
2.00  •
                                        -Brown Bullhead
                                        -Yellow Perch
                                        -Largemouth Bass
                                        - Striped Bass
                                        -White Perch
1.50 -•
1.00
0.50 - -
0.00
                                                                                                                -t-
   1990
                         2000
                                               2010
2020
Year
                                                                                          2030
                                                                                                               2040
                                                                                                                                    2050
                                                                                                                   JAMS/ Gradient Corporation

-------
   1.0
   0.9-
   0.8
   0.7
a
o
   0.5
O  0.'
0.4
   0.3
   0.2-•
   0.1
0.0
  1990
                                                              Figure 2-7 (Revised)
                                                Average Total PCB Concentration in Sediment
                                                               Mid-Hudson River
                                                                                                        • River Miles 153.5 - 143.5
                                                                                                        (Farley Segment 1)

                                                                                                        -River Miles 73.5-63.5
                                                                                                        (Farley Segment 9)

                                                                                                        •Overall Average, River
                                                                                                        Miles 153.5-63.5 (Farley
                                                                                                        Segments 1-9)
                            2000
                                                  2010
                                                                      2020
                                                                      Year
2030
                                                                                                                    2040
                                                                                                                                           2050
                                                                                                                          TAMS/ Gradient Corporation

-------
  0.04
  0.03-
   0.03
   0.02
§
  0.02
   0.01 -
   0.01
   0.00
                                                             Figure 2-8 (Revised)
                                              Average Total PCB Concentration in River Water
                                                              Mid-Hudson River
                                  -River Miles 153.5-143.5
                                   (Farley Segment 1)

                                  -River Miles73.5-63.5
                                   (Farley Segment 9)

                                  -Overall Average, River
                                   Miles 153 5 - 63.5 (Farley
                                   Segments 1-9)	
      1990
                            2000
                                                  2010
2020

Year
2030
2040
                                          2050
                                                                                                                         TAMS/ Gradient Corporation

-------
Comments

-------
Federal

-------
                                          National oceanic ana Aimospnenu
                                          Admlnlstratlon
                                          National Ocean Service
                                          Otfica of Response and Restoration
                                          Coastal Protection and Restoration Division
                                          290 Broadway. Rm 1831
                                          New York, New York 10007              TXT?  1
                                           January 28,2000
Alison Hess
U.S. EPA                      _. . .
Emergency and Remedial Response Division
Sediment Projects/Caribbean Team
290 Broadway
New York, NY  10007
uearsuiauu.
Summary
  umm
                                                                            d
                              ?^^^ tendency (50th percentilOand high end










 bioaccumulation (FISHRAND) model).







 acceptable levels.

-------
NOAA commenis on December 1999 Hudson River Mid-Hudson Human Healih Risk Assessment   (1/28/00)
 wo£ we^p^formed during the RR1/FS. Neither the August 1999 baseline HHRA
for the Upper Hudson River nor the December 1999

The baseline HHRA for the Mid-Hudson River represents the second [component ofi die : human
Srisk assessment for the Hudson River Superfund site  The nsk ^essment w^ not be
comolete until there is an evaluation of the human health nsk for the entire site, including the
ffi Son River between Poughkeepsie and the Battery, the southern site boundary  The   HF-1.1
MdJbdKB HHRA concludes that ingestion offish is the pnmiKy pathway for humans to be
emdttPCBs and that risk for cancer and noncancer health effects exceed EPA s goals of
«£*£ The decision to limit determination of human health risk to the Upper and Mid-
                                                         uman health i nsks
«*   The decson to mt  etermn
Kn to the exclusion of the Lower Hudson means that potential human health i nsks
Ssociated with the consumption of PCB-contaminated fishery resources and the potential
effect of remedial decisions will not be fully evaluated.
                                           9, 1/28/00) on the fate and transport and
                                           ingefforL Tliese comments should be
 m«™pTfhnned This represents major uncertainty in the exposure assessment for the nsK
 LsePsS^cTSie7S sediment, water and fish tissue PCB concentrations forested by
 SSds^ used to predict future risk. The implications of the uncertainty resuming from
 Se ^oddSp^ S risk Sment should be addressed within the mid-Hudson HHRA since
 Xe SSeled sediment and water concentrations drive the fish ? xppsujc.concentranons that «n
 Se^d^veStot^miblic. NTofeovffrresults of supplemental work on ^te^d
 ^s^S?Scumulationmodekv^berek^^
 3 to^S how the data from these supplemental analyses will bem'arporated into the
 models and how they might affect the predictions in the Mid-Hudson HHRA.
   g
 assuinption that no exposure occurred prior to that date, could underestimate nsk.
 Sin<
               r\
 NOAA Coastal Resource Coordinator
        - "Cam catfish  and eel were assigned the same PCB concentration as brown
        " NYSD!C fish^tions include sizable samples of carp, American eel and I white   HF-1.5
        Data fOTcarp, catfish and eel should have been examined for comparability pnor to
 assigning brown bullhead concentrations to these three fish species.


 Thank you for your continual efforts in keeping NOAA apprised of the progress at this site.
 Please SntaS 5tt 01 2) 637-3259 or Jay Field at 206-526-6404 should you have any
 questions or would like further assistance.

-------
NOAA comments on December 1999 Hudson River Mid-Hudson Human Health Risk Assessment   (1/28/00)
or    MindyPensak,DESA/HWSB
      Marian Olsen, ERRD/PSB
      Gina Ferreira, ERRD/PSB
      Robert Hargrove, DEPP/SPMM
      Charles Merckel, USFWS
      Kathryn Jahn, USFWS
      William Ports, NYSDEC
      Ron Sloan, NYSDEC
      Sharon Shutler, NOAA

-------
State

-------
02/84/2000   15:02    518-457-7925
                                                 tNUJN BUKtt
                                                                                    I-HV3C.  Uf.
                                                                                       ixMLCc
New York State Department of Environmental Conservation
Division of Environmental Remediation
Bureau bf Central Remedial Action, Room 228                                  T-rr>i •*
SOVVblf Road, Albany, NewYork 12233-7010                                    HS-1
Phone: (518) 457-1741  • FAX: (518) 457-7925
Website:'www.dec.state.ny.us
                                             February 4,2000
      Allison A. Hess
      Project Manager
      U.S. Environmental Protection Agency
      Region 2
      290 Broadway, 19th Floor
      New York, New York 10007-1866
      Dear Ms. Hess:
                              Re: Hudson River PCB Reassessment RI/FS
                                  Site No. 5-46-031
             Enclosed are comments prepared by the New York State Department of Health on the Phase 2
      Report - Further Site Characterization and Analysis, Volume 2F - A Human Health Risk Assessment for
      the Mid-Hudson River, Hudson River PCBs Reassessment RI/FS, dated December 1999.

             If you have any questions regarding the comments please contact this office at 518-457-5637.

                                            Sincerely,
                                            William T. Ports P£.
                                            Project Manager
                                            Bureau of Central Remedial Action
                                            Division of Environmental Remediation
      cc:    John Davis, NYSDOL
            Robert Montione, NYSDOH
            Jay Fields, NOAA
            Lisa Rosman, NOAA
            Anne Secord, USF&WD
                                                                                   SBSfUSSSS

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                    STATE OF NEW  YORK

                    DEPARTMENT OF HEALTH

                    Fbnlgan Square. 547 River Street. Troy, New Yoft 12180-2216

AntoniaC.Noveno,M.D.,M.P.H.                                         Dennis P. Whalen
 Com/russtonar                                                      Executive Deputy Commissioner


                                        January 28,2000

      Mr. William Ports
      Bureau of Environmental Remediation
      New York State Department of Environmental Conservation
      50 Wolf Road
      Albany, NY 12233

                                        Re:   Human Health Risk Assessment
                                             Mid-Hudson River PCBs
                                             Saratoga County
                                             Site #546031

      Dear Mr. Ports:

           We have reviewed the United States Environmental Protection Agency's (US EPA)
      December 1999 "Phase 2 Report • Review Copy, Further Site Characterization and Analysis,
      Volume 2 F - A Human Health Risk Assessment for the Mid- Hudson River, Hudson River
      PCBs Reassessment RI/FS." This human health risk assessment (HHRA) is specific for
      exposure to PCBs in the mid-Hudson River which extends from the Federal Dam at Troy, New
      York to just south of Poughkeepsie, New York. It is a companion to EPA's August 1999 HHRA
      fox exposure to PCBs in the upper Hudson. Both of the assessments are based on the same
      methodology and tenacity evaluation, although more detail and discussion is found in the August
      1999 HHRA. For these reasons, almost all of our September 7,1999 comments on the upper
      Hudson HHRA apply to the mid-Hudson HHRA.

           We agree with the overall conclusion of the assessment that the highest estimated human
      health risk due to PCBs hi the mid- Hudson River is from fish ingestion and that other routes of
      exposure are of less risk.  However, as described below, we have a number of technical
      comments and concerns that should be addressed before finalising the assessment


      GENERAL COMMENTS

      1. The assessment does not include a quantitative evaluation of many possible residential          HQ i i
      exposure pathways. These pathways include soil and sediment ingestion, dermal contact with        &  '
      sediments and river water, incidental ingestion of rivej water, homegrown vegetable ingestion
      and the ingestion of beef and dairy products produced at current or future farms along the
      floodplam. While the environmental data needed to evaluate these pathways may be limited at

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02/84/2000  13:0^     3.1 o-qo/-/3^o               CM-UN
     this time, to the extent feasible, a quantitative evaluation of all relevant young child and adult
     residential exposure pathways is needed to characterize the possible risks to residents.

     2. New York State Department of Health (NYS DOH) staff has compared elements of the
     assessments prepared by US EPA's consultants for the Hudson River and Rogers Island sites.
     There are numerous differences in the approaches used in the risk assessments (e.g., different    jj§_ j 7
     receptors/pathways evaluated, differences in certain exposure parameter values, differences in
     the toxicological parameters). US EPA should use similar approaches in the Hudson River and
     Rogers Island risk assessments unless there are valid technical reasons for not doing so.
       i
     3. In a May 20,1998 letter from Robert Montione to William Ports of the NYS Department of
     Environmental Conservation, NYS DOH staff provided comments on the US EPA Scope of
     Work for the Hudson River HHRA. Two comments not addressed in the mid-Hudson HHRA    HS-1.3
     are: 1) The point estimates for high-end risk should include lifetime Hudson River fish
     consumption (comment 3) and 2) The HHRA should address ihe effects of j>ast exposures on      TT^  ,  ,
     current and future health risks (comment 4).

     Addressing these issues would provide valuable information to risk managers.


     EXECUTIVE SUMMARY

     1. Page ES-3 — The statement that for the fish ingestion pathway, "Both cancer and non-cancer
    health hazards to an adult angler and a child were calculated" is incorrect Such calculations
    only appear in the Executive Summary, The child receptor for the fish ingestion pathway must   HS-1.5
    be incorporated into Chapter 2 - Exposure Assessment and Chapter 4 - Risk Characterization.
    Furthermore, the risks to children from fish ingestion (pages ES-4 and ES-5) are calculated by
    simply dividing the adult cancer risk or hazard index by 3, based on the assumptionjhata-ehilers-
    meal size is approximately 1/3 of an adult's meal size (no reference provide^HiiscalciilatiQn
    finis to account for differences in body weight that would result in higher estimates of daily
    exposure for children than adults. The approach taken to calculate the child's cancer risk is also
    flawed because cancer risk estimates are based on 12 years exposure (central tendency) and 40
    yean exposure (RME), while a person has a child's body weight and meal size for only a
    fraction of these time periods.  Due to the shorter duration of exposure assumed for
    noncarcinogenic risk (e.g., the assessment assumed that chronic exposures are those which      (
    exceed 7 years), the assessment should evaluate exposures and noncarcinogenic risk for at least
    the high-end child fish consumer. See our comments on Chapter 2 - Exposure Assessment for
    additional infonnatioa

    2, Page ES-4 and Chapter 4 (page 26) - Statements about an acceptable risk range for
    carcinogens are misleading to the reader and should either be deleted from the risk assessment
    document or revised to reflect the NCP and EPA risk management policy. Cancer risks of 1.0 E-
    6 or less are usually considered insignificant and not a public health concern. Cancer risks
    greater than 1.0 E-4, on the other hand, typically will trigger actions to lower exposures.  When     HS-1.6
    cancer  risk estimates are between 1.0 E-6 and 1.0 E-4, a risk management decision must be made
   on a case-by-case basis whether or not to pursue risk reduction measures.  The NCP and EPA

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   lUUb  ID.Oi
  state (e.g., US EPA, 1991, Risk Assessment Guidance for Superfund: Volume 1 - Human Health
  Evaluation Manual (Part B, Development of Risk-based Preliminary Remediation Goals), Office
  of Emergency and Remedial Response, p. 18) the preference for managing risks at the more
  protective end of the risk range, other things being equal. Preferably, statements about
  acceptable risk should be deleted from the risk assessment document If, on the other hand, US
  EPA determines that such a discussion should be included, then the contractor must provide an
  accurate and balanced discussion of the risk management process to avoid the perception that as
  long as the risks fell in the 1.0 E-6 to 1.0 E-4 range, they are a priori deemed acceptable.

  3. .Page ES-6 (second bullet) - Hie HHRA calculates increased cancer risks to individual
  receptors. Thus, it is recommended that the first sentence be changed to  "Under the RME      HS-1.7
  scenario for eating fish, the calculated increased risk is approximately 4 in 10,000".


  CHAPTER 2 - EXPOSURE ASSESSMENT

  1. .The PCB Concentration Weighted by Species-Consumption Fractions section on page 10 and
 Table 2-7 describe how the assessment classified eight species offish consumed by Mid-Hudson
 River anglers into five groups. For Group 1, the assessment uses PCB levels in brown bullhead
 to represent PCBs in carp, catfish and eel "because, like bullhead, they tend to spend much of
 their time at the bottom of lakes, rivers, and streams."  This is inappropriate because brown       HS-1.8
 bullhead generally have lower PCB levels than American eel, carp or white catfish; for example,
  1992 collections of brown bullhead, American eel and carp/goldfish at Albany/Troy and white
 catfish at  Catskill had average PCB levels of 3.1,9.1,9.2 and 8.8 ppm, respectively.

 2. As discussed in our comments on the Executive Summary, PCB exposures and
 noncarcinogenic risks from fish consumption should be assessed for at least the high-end child
 fish consumer. Although most angler surveys do not provide direct measures, fish consumption
 rates for children can be estimated by applying child/adult fish consumption rate data from other
 sources to findings from the angler studies of interest For example, data on meal sizes from Pao
 et al. (1975, page 264-265) indicate that the average fish meal size for a 1-2 year old child is 68
 grams and the average fish meal for a 19-34 year-old male is 191 grams; thus, the child/adult      trc   Q
 meal ratio is 68/191 = 0.36. If you assume the child eats Hudson River fish whenever the parent     ^"^
 does, the child fish consumption rate could be assumed to be equal to the adult consumption rate
 multiplied by 0.36.

 3. In order to expedite the Feasibility-Study, the risk characterization Chapter (Chapter 4) should
 include a comparison of the modeled fish concentration over time for the different sections of the  HS-1.10
 Mid- Hudson to the FDA  tolerance level of 2 ppm, which is an Applicable Relevant and
 Appropriate Requirement (ARAR).

4. The assessment assumes that the high-end fish consumer eats Hudson River fish for 40 years,
based on census data regarding local residence duration and survey data on how long an       ' HS-1.11
individual  fishes. There are two flaws in this approach:

•  .If the conditional probability of moving out of the area is lower for individuals who have

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02/04/200B
                                                  LNUJIN
                                                                                     rwuc  oo
        already lived in the area for a long period of time, it is possible that US EPA will have
        underestimated the fraction of the population whose residence times are very long.

     •  The assessment assumes that only anglers consume Hudson River fish, so that individuals are
        only exposed during the part of their lives when they are fishing. This assumption is faulty
       . because angling is often a family tradition where the catch is shared by the extended family,
        and it is likely that Hudson River fish are included in family meals. Thus, individuals may
       . eat Hudson River fish for their entire lives even if they themselves do not fish or they fish for
        just a portion of their life.

       •   Based on the likelihood that some avid anglers/fish consumers will reside near and eat
     Hudson River fish for their lifetimes, we believe the point estimates of high-end risk should
     assume lifetime consumption of Hudson River fish.
    CHAPTER 3 - TOXICITY ASSESSMENT

    1. As in the HHRA for the upper Hudson, the assessment for the mid-Hudson maintains an
    artificial dichotomy between the toxicity values for the cancer and non-cancer effects of PCBs.
    For example:

    •  The toxicity values used to evaluate the cancer and non-cancer human health risks of the
       same exposure (water ingestion, sediment ingestion, dermal contact with sediment, dermal
       contact with water) are based on different Aroclor(s). The dichotomy is not supportable and
       should be reconciled.

Exposure Route
water ingestion
fish ingestion
sediment ingestion
°
dermal contact with sediment
dermal contact with water
Aroclor on Which the Toxfchy Value is Based
Cancer Slope Factor
1242
1254/1260
1254/1260
1254/1260
1242
Reference Dose
1016
1254
1016
1016
1016
   2. On page 23, it is explained that the RfD for Aroclor 1016 (and not Aroclor 1254) was used to
   evaluate the non-cancer risks from PCBs in sediments because the congener profile in the
   sediments more closely resembles Aroclor 1016 than Aroclor 1254. It also is explained that the
   RfD for Aroclor 1254 (and not Aroclor 1016) was used to evaluate the non-cancer risks from
   PCBs in fish because the congener profile in fish more closely resembles Aroclor 1254 than
   Aroclor 1016.  We agree with these choices and the scientific reasoning supporting the
   selections. We suggest, however, that the same scientific reasoning be applied to the selection of
HS-1.12

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02/04/2000   15: 02
       I
     cancer slope factors (CSFs) to evaluate the cancer risks of exposure to sediments and water. We
     recommend that the cancer risk assessment for these media follow the advice given in the IRIS
     datafile for PCBs in Section II.B.4. Discussion of Confidence (Carcinogenicity, oral exposures):
     "When available, congener information is an important tool to define a potency estimate that was
     based on exposure pathway.* The consideration of dioxin-like PCBs in the assessment of the
     cancer risks from fish exposures in the upper Hudson HHRA is consistent with this advice. If
     the CSFs used to assess sediment and water exposures do not change, then the uncertainty
     associated with using CSFs for Aroclor mixtures that may not adequately match the
     environments! mixtures found in sediments and water should be discussed in the Chapter on Risk
     Characterization.
     CHAPTER 4 - RISK CHARACTERIZATION

     I. 'As in the upper Hudson HHRA, the discussion (pages 25-27) does not fully characterize the
     uncertainties in the toxicity assessment Three major areas could be more fully discussed

     • ; The discussion does not fully characterize the uncertainty that arises when estimate^ hwpan
        PCB exposures are compared to the non-cancer results of animal studies published after the
       • completion of the IRIS RfDs.

     •  The study by Arnold et al. (1995) on reproductive effects seen in rhesus monkeys should be
       : more fully discussed.  Arnold et al. (1995) reported that statistical analysis of the conception
       '.. rates showed that they were significantly lower in those females ingesting 20,40, or 80 ug
       , Aroclor 1254/kg/d«y (P-values of 0.007,0.043, and 0.003, respectively), and approached
       i significance (P  < 0.059) in those females ingesting 5 ug Aroclor 1254/kg/day. Moreover, the
        study also showed that infants of monkeys ingesting 5 ug Aroclor 1254/kg/day showed
       : clinical signs of toxicity during nursing. These effects included inflammation and/or
       ! enlargement of tarsal glands, nail bed prominence, elevated nails, nails folding on
       . themselves, and gum recession. These findings, especially the potential effects on
       • reproductive success, should be discussed before concluding that the IRIS RfD for Aroclor
       : 1254 is considered to be "health protective." The RfD was derived using, among other
       . factors, a reduced uncertainty factor of 3 because the changes observed in the adult monkeys
        were not considered to be of marked severity, The new data suggest that the margin of
       ' protection afforded by the IRIS RfD may not be adequate.

    •  -Tlie aversgrtally ctese-fof an-adulfliigh-end angler is 0.6 ug/kg/day. The LOEL used to
        derive the Aroclor RfD is 5 ug/kg/day. Thus, the adult angler's dose is only about 8 times
       . lower than the animal LOEL. The perception of risk at this dose differs with the nature of
       the end-points observed at the LOEL. Concern increases with the severity of the observed
       1 effects.  The discussion on pages 76-77 of the upper Hudson HHRA implies that the only
       effects seen at the LOEL were mild dermal and immunological effects in the aduhs. It does
       not fully address the  potential that more severe effects (failure to conceive, developmental
       toxicity) may also occur at the same LOEL.

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  •  Recent studies on rhesus monkeys show long-term behavioral effects in young animals dosed
     with 7.5 ug/kg/day of Arodor 1254 from birth to 20 weeks of age (Rice, 1999a). This dose
     was chosen because it represented a breast milk dose considered "safe" by Health Canada.
     Moreover, it lead to blood and fat levels in the monkeys that were within the range of levels
     seen in the human population. The doses ingested by child anglers, who may consume PCB
     contaminated fish, should be compared to this LOEL to obtain information on potential risks
     of neurobehavioral effects. As stated elsewhere, an evaluation of the non-cancer risks offish
    ' consumption by children could be included in the assessment.

  • ' There is a large body of information on the potential reproductive and developmental effects
     of consuming sport-fish containing PCBs and other contaminants (see attached
    i bibliography). Estimated fish consumption rates and PCB intakes from Hudson River fish
    , could be compared to fish consumption rates and expected PCB intakes (when available)
     associated with effects in cohort studies in New York State, Michigan, Wisconsin, Sweden,
     and Quebec. Such an analysis could provide valuable human data to support/contradict the
    . statement (page 76 in the upper Hudson HHRA) that the IRIS RfD is considered to be
     "health protective."

  •  ; As stated earlier, the uncertainty associated with using CSFs for Aroclor mixtures that may
    ; not adequately match environmental mixtures found in sediments and air should be
    discussed.

 2. A comparative summary of the information (critical studies, critical effects, and uncertainty     H^
 factors) for the Aroclors 1016 and 1254 would provide useful information for the reader and risk
 manager..


 APPENDIX C - TOXICITY PROFILE (UPPER HUDSON HHRA)

 [The comments below were provided on the Upper Hudson HHRA and should be
 considered when finalizing the mid-Hudson HHRA]

 1.  The profile is not an up-to-date review of PCB toxicity because it limits itself largely to
 material contained in the IRIS datafiles for PCBs, Aroclor 1016, and Aroclor 1254. Since the
 IRtS files were completed, new information has been published, and important studies on the
 oncogenic, reproductive, and developmental toxicity of PCBs could be incorporated into the text.
 This is not a request to make the section longer, but to re-fbcwfthe section on important studies
 that are critical to understanding the potential public health risks of environmental exposures.
 Several suggestions follow:

 •   The section on the carcinogenic potential in humans could include a discussion of the
   •potential links between PCBs and specific cancer types (i.e., melanoma, non-Hodgkin's
   'lymphoma, and breast cancer) (see attached bibliography).

•   The discussion on PCBs and breast cancer in the  Summary of Non-Cancer Effects in Humans
    (page C=4) should be placed in the section on the carcinogenic potential in humans.

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 •  i Hie discussion on potential effects associated with background exposure to PCBs, including
    PCBs in fish, could be more fully developed. This is a major area of uncertainty. The
    summary statements on studies Lanting/Patandin (Dutch studies) should be compared with
    animal studies and other human studies. The discussion could include the findings of cohort
    studies in New York State, Michigan (infant and adult studies), Sweden, and Quebec on the
    possible development, reproductive, and neurotoxic effects associated with the consumption
    offish containing PCBs and other contaminants (see attached bibliography).

 •  The studies by Lanting/Patandin assessed the non-cancer effects of background exposures to
    PCBs, A recent publication indicates that only a small percentage of a child's daily exposure
    is from fish (Patandin et al., 1999a).  Thus, they are not, as indicted on page C-4, studies of
    children consuming PCBs in fish.

 •  _ The discussion of non-cancer effects does not include all of the recent studies on
    reproductive and developmental effects seen in low-dosed animals, Several studies
    published after the IRIS RfDs for Aroclors 1016 and 12S4 were derived could be identified
    and briefly discussed (see attached bibliography). These include studies (e.g., Arnold et al.,
    1995; Rice, 1999a) on the reproductive, developmental, and neurobehavioral effects of fowl
    level Aroclor 1254 exposures in rhesus monkeys.

    I hope that our comments and suggestions will assist EPA in finalizing the HHRA. If you
 have any questions please call me at (518) 402-7870.
                                    Sincerely,
                                    Robert J. Montione, Public Health Specialist m
                                    Bureau of Environmental Exposure Investigation
cc: Mr. Tramontane
    Dr. Kim
    Dr. Carlson/ Dr. Wilson
   -Br. Hom/Dr.-Grey
    Mr. Fear GFDO
    Mr.DaiglcDEC
   'Mr. Steenberge DEC Reg. 5
    Mr.UlrichATSDR
Z:\BTSA\DOCUMENIMMUhud.dee

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 BIBLIOGRAPHY ON EXPOSURE ASSESSMENT

 Pao, E.M., Fleming, K.H., Guenthei, P.M. and Mickel, S.J.  1975. Foods Commonly Eaten by
       Individuals; Amount Per Day and Per Eating Occasion. United States Department of
       Agriculture. Home Economics Research Report Number 44. Hyattsville, MD.

 BIBLIOGRAPHY ON PCS TOXICITY

 Reproductive/Developmental Toiicitv m Rhesus Monkevs

 Arnold, DX., F. Bryce, P.F. McGuire, R, Stapley, J.R. Tanner, E. Wrenshall, J. Mes, S. Femie,
       H. Tryphonas, S. Hayward, and S. Malcolm. 1995. lexicological consequences of
       Aroclor 1254 ingestion by female rhesus (Macaca mulattat monkeys. Part 2.
       Reproduction and infent findings. Food Chem. Toxicol. 33:457-474.

 Arnold, D.L., E.A. Nera, R. Stapley, G. Tolnai, P. Claman, S. Hayward, H. Tryphonas, and F.
       Bryce, 1996. Prevalence of endometriosis in rhesus (Macaca mulatta) monkeys
       ingesting PCBs (Aroclor 1254): Review and evaluation. Fund. Appl. Toxicol. 3J.: 42-55.

 Arnold, D.L., E.A. Nera, R. Stapley, F. Bryce, S. Femie,  G. Tolnai, D. Miller, S. Hayward, J.S.
       Campbell, and I. Greer.  1997. Toxicologies! consequences of Aroclor 1254 ingestion by
       female rhesus (Macaca mulattal monkeys and their nursing infants. Part 3: Post-
       reproduction and pathological findings. Food Chem. ToxicoL 15:1191-1207.

 Rice, D.C. 1997. Effect of postnatal exposure to a PCB mixture in monkeys on multiple fixed
       interval-fixed ratio performance. Neurotoxicol. Teratol. 19:429-434

 Rice, D.C. 1998. Effects of postnatal exposure of monkeys to a PCB mixture on spatial
       discrimination reversal and DRL performance. Neurotoxicol. Teratol. 2fi:391-400

 Rice, D.C. 1999a.  Behavioral impairment produced by low-level postnatal PCB exposure in
       monkeys. Environ. Res. Sec. A.  jjfl: S113-S121.

Rice, D.C. 1999b.  Effect of exposure to 3^',4,4',5-pentachlorobiphenyl (PCB 126) throughout
       gestation and lactation on development and spatial delayed alternation performance in
       rats. Neurotoxicol. Teratol.  21:59-69.

Rice, D.C., and S. Hayward. 1997.  Effects of postnatal exposure to a PCB mixture in monkeys
       on nonspatial discrimination reversal and delayed alternation performance.
      Neurotoxicology.  18:479-494.

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 Rice, D.C., and S. Hayward.  1999. Effects of postnatal exposure of monkeys to a PCB mixture
       on concurrent random interval-random interval and progressive ratio performance.
       NeurotoxicolTeratol. 21:47-58

 Human Carcinogcnicitv

 Bahn, A.K., I. Rosenwaike, N. Herrmann, P. Grover, J. Stellman, and K. O'Leary. 1976.
       Melanoma after exposure to PCBs. NEJM. 295:450.

 Bahn, AJC., P. Grover, I. Rosenwaike, K. O'Leary, and J. Stellman. 1977.  Melanoma after
       exposure to PCBs. NEJM. 226:108.

 Bertazzi,PA,L.Riboldi,A.Pesatori,LRadice,andC.Zocchetti. 1987.  Cancer mortality of
       capacitor manufacturing workers. Am. J. Indust Med. H: 165-176.

 Brown, D., and M Jones.  1981. Mortality and industrial hygiene study of workers exposed to
   ;    polychlorinatedbiphenyls.  Arch. Environ. Health. 36:120-129.

 Brown, D. 1987. Mortality of workers exposed to polychlorinatedbiphenyls- An update Arch
       Environ, Health. 42:333-339.

 Gustavsson, P., C. Hogstedt, and C. Rappe. 1986. Short-term mortality and cancer incidence in
       capacitor iriairuracturing workers exposed to polychlorinated biphenyls (PCBs). Am  J
       Indust Med. 12:341-344.

 Gustavsson, P., and C. Hogstedt. 1997. A cohort of Swedish capacitor manufecturing workers
       exposed to polychlorinated biphenyls (PCBs). Am. J. IndusL Med.  22:234-239.

 Hardell, L, B. van Bavel, G. Lindstrom, M. Fredrikson, H. Hagberg, G. Liljegren, M.
       Nordstrom, and B. Johansson. 1996. Higher concentration of specific polychlorinated
       biphenyl congeners in adipose tissue fiom non-Hodgkin's lymphoma patients compared
       with controls without a malignant disease. Internal. J. Oncol. §: 603-608.

 Hardell, L, G. Liljegren, G. Lindstrom, B. van Bavel, M. Fredrikson, and H. Hagberg. 1997.
      Polychlorinated biphenyls, chlordanes, and the etiology of non-Hodgkin's lymphoma
       [letter). Epidemiology. 8:689.

 HardelLL,G. Lindstrom, B. van BaveLM. Fredrikson, and G. Liljegren.  1998.  Some aspects of
      the etiology of Non-Hodgkin's lymphoma. Environ. Health Perspect 106fSm»12V
      679-681.                                                    —* ^p  ''

Kimbrough,R.D.,M.LDoemland,andMi.LeVois. 1999. Mortality in male and female
      capacitor workers exposed to polychlorinated biphenyls.  JOEM, 41:161-171.

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 Lawrence, C.  1977. PCBs and melanoma. NEJM. 226: 108.

 Lopmis, D., S.R. Browing, A.P. Schenck, E. Gregory, and D.A. Savitz. 1997.  Cancer mortality
       among electric utility workers exposed to polychlorinated biphenyls. Occup. Environ.
       Med. 54: 720-728.

 Rothman, N., K.P. Cantor, A. Blair, D. Bush, J.W. Brock, K. Helzlsouer, S.R Zahm, L.L.
       Needham, G.R. Pearson, R.N Hoover, G.W. Comstock, and P.T. Strickland. 1997. A
       nested case-control study of non-Hodgkin lymphoma and serum organochlorine residues
       Lancet 350: 240-244.

 Sinks, T.,  G. Steele, A3. Smith, K. Watkins, and R.A. Shults. 1992. Mortality among workers
       exposed to polychlorinated biphenyls. Am. 1 Epidemiol. 136: 389-398.
        Developmental/Reproductive Studies

 New York State Angler Cohort

 Buck, G.M., L.E Sever, P. Mendola, M. Zielezny, and IE. Vena. 1997.  Consumption of
       contaminated sport fish from Lake Ontario and time to pregnancy. New York State
       Angler Cohort. Am. J. Epidemiol. 146: 949-954.

 Buck, G.M., P. Mendola, J.E. Vena, L.E. Sever, P. Kostyniak, H. Greizerstein, J. Olson, and FJD.
   i    Stephen. 1999. Paternal Lake Ontario fish consumption and risk of conception delay,
       New York State Angler Cohort  Environ. Res. Sec. A. £0: S13-S18.

 Mendola, P., G.M. Buck, JJE. Vena, M. Zielezny, and LJE. Sever.  1995.  Consumption of PCB-
       contaminated sport fish and risk of spontaneous fetal death.  Environ. Health Persp.  103-
       498-502.

Mendola, P., G.M. Buck, L.E. Sever, M. Zielezny, and IE. Vena. 1997. Consumption of PCB-
       contaminated freshwater fish and shortened menstrual cycle length, Am. J. Epidemiol.
           955-960.
OswegoTNY Newborn and Infant Development Project

Lonky, E., J. Reihman, T. Darvill, J. Mather, Sr., and H. Daly.  1996. Neonatal behavioral
      assessment scale performance in humans influenced by maternal consumption of
      environmentally contaminated Lake Ontario fish. J. Great Lakes Res. 22: 198-212.

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82/04/2000  15:02     518-457-7925                ENCON BCRA                         PAGE  13
     Michigan Fisheaten Family Health Project


     Courval, J.M., J.V. DeHoog, A.D. Stein, EM. Tay, J. He, H.E.B. Humphrey, and N. Paneth.
           1999. Sport-caught fish consumption and conception delay in licensed Michigan anglers.
           Environ. Res. Sec. A. 8fi: S183-S188.
     A.D. Stein, E. Tay, and J.M. Courval.  1999. Absence of nonresponse bias in a study of sport-
           caught Great Lakes fish consumption and conception failure. Environ.  Res. Sec A
           8fl: 287-293.

     Michigan Fisheatcr Cohort


     Schantz, S X., J.C. Gardiner, D.M. Gasior, AM. Sweeny, H.E.B. Humphrey, and RJ.
           McCaffrey. 1999. Motor function in aging Great Lakes fisheaters. Environ. Res Sec A.
           80: S46-SS6.

     Qujebec Studies


     Dewailly, E., S. Bruneau, P. Ayotte, C. Laliberte, S. Gingras, D. Belanger, and L. Perron.  1993.
           Health status of limit newboms prenatally exposed to oiganochlorines.  Chemosphere
           27_:359-366.


     Mergler, D., S. Belanger, F. Larribe, M. Panisset, R. Bowlei, M. Baldwin, JJLebel, and K.
           Hudnell. 1998. Preliminary evidence of neurotoxicity associated with eating fish from
           the Upper St. Lawrence River Lakes. Neurotoxiciry. J2:691-702.

     Swedish Fish Eaten

     Asplund, L, B-G. Svensson, A. Nilsson, U. Eriksson, B. Jansson. S. Jensen, U. Wideqvist, and S.
           Skerrving.  1994.  Polychlorinated biphenyls, l,l,l-trichlor-2^-bis(p-chlorophenyl)
           ethane (p.p'-DDT) and l,l-dichloro-2,2-bis (p
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02/04/2000  15:02     518-457-7925                ENCON BCRA                          PAGE  14
     Svensson,B-G.,A.Nikson,E.Jonsson,A. Schutz, B. Akesson, and L. Hagmar. 1995. Fish
           consumption and exposure to persistent organochlorine compounds, mercury, selenium
           and meuylamines among Swedish fishermen.  Scand. J. Work Environ. Health. 21:96-
           105.

     Dutch FCB/PCDD Project

     Huisman, M, C. Koopman-Esseboom, V. Fidler, M. Hadders-Algra, C.G. van der Paauw,
           L.G.M.T. Tuinstra, N. Weisglas-Kuperus, P.J.J. Sauer, B.C.L. Touwen, and E.R.
           Boersma.  1995. Perinatal exposure to polychlorinated biphenyls and dioxins and its
           effect on neonatal neurological development Early Hum. Dev. 4J,: 111-127.

     HuLsman, M., C. Koopman-Esseboom, C J. Lanting, C.G. van der Paauw, L.G. Tuinstra, V.
           Fidler, N. Weisglas-Kuperus, P.J. Sauer, E.R. Boersma, and B.C. Touwen.  1995.
           Neurological condition in 18-month-old children peiinatally exposed to polychlorinated
           biphenyls and dioxins.  Early Hum. Dev. 4£ 165-176.

     Koopman-Esseboom, C., D.C. Morse, N. Weisglas-Kuperus, I.J. Lutkeschipholt, C.G. Van der
           Paauw, L.G.MT Tuinstra, A. Brouwer, and P.J.J. Sauer.  1994. Effects of dioxins and
           polychlorinated biphenyls on thyroid hormone status of pregnant women and their
           infants.  Pediatr. Res. £6:468-473.

     Koopman-Esseboom, C., N. Weisglas-Kuperus, M.A.J. de Ridder, C.G. Van der Paauw,
           L.G.M.T. Tuinstra, and P.J.J. Sauer. 1996. Effects of polychlorinated biphenyl/dioxin
           exposure and feeding type on infants' mental and psychomotor development. Pediatrics.
       ;    22= 700-706.

     C.I. Lanting, S. Patandin, V. Fidler, N. Weisglas-Kuperus, P.J. Sauer, E.R. Boersma, and B.C.
           Touwen. 1998. Neurological condition in 42-month-old children in relation to pre- and
           postnatal exposure to polychlorinated biphenyls and dioxins. Early Hum. Dev. 50:283-
           292.

    Patandin, S., C. Koopman-Esseboom, MA de Ridder, N. Weisglas-Kuperus, and PJ. Sauer.
           1998. Effects of environmental exposure to polychlorinated biphenyls and dioxins on
           birth size and growth in Dutch children. Pediatr. Res. 44j 538-545.

    Patandin, S., P.C. Dagnelie, P.G.H. Mulder, E. Op de Coul, J.E. van der Veen,  N. Weisglas-
           Kuperus, and PJ. Sauer. 1999a. Dietary exposure to polychlorinated biphenyls and
           dioxins from infancy until adulthood: A comparison between breast-feeding, toddler, and
           long-term exposure. Environ. Health Perspect  107:45-51.

    Patandin, S., C.I. Lanting, P.G. Mulder, E.R. Boersma, PJ. Sauer, and N. Weisglas-Kuperus.

                                              5

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02/04/2008  15:02    518-457-7925                ENCON BCRA                         PAGE  15
           1999.  Effects of environmental exposure to polychlorinated biphenyls and dioxins on
           cognitive abilities in Dutch children at 42 months of age. J. Pediatr. 134; 33m

    Sauer, P J., M. Huisman, C. Koopman-Esseboom, D.C. Morse, A.E Smits-van Prooje, KJ. van
           de Berg, L.G.M.T. Tuinstra, C.G. van der Paauw, E.R. Boersma, N. Wtisglas-Kuperus,
           J.H.C.M. Lammers, B.M Kulig, and A. Brouwer. 1994.  Effects of polychlorinated
           biphenyls (PCBs) and dioxins on growth and development  Hum. Exp. Toxicol. 13- 900-
           906.

    Wcisglas-Kuperus, N., T.CJ. Sas, C. Koopman-Esseboom, C.W. van der Zwan, M.A.J. de
           Ridder, A. Beishufeen, H. Hooijkaas, and PJ.J. Sauer. 1995. Immunologic effects of
           background prenatal and postnatal exposure to dioxins and polychlorinated biphenyls in
           Dutch infints. Pediatr. Res. 38:404-410.

    German Studies

    Winneke, G., A. Bucholski, B. Heinzow, U. Kramer, E. Schmidt, J. Walkowiak, JA \vlener,
       .   andRJ. Steingruber. 1998. Developmental neurotoxicity of polychlorinated biphenyls
          (PCBs): Cognitive and psychomotor functions in 7-month old children.  Toxicol Lett
           102-103:423-428.

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Local

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                                                                        HL-1

                                   SARATOGA COUNTY

                     ENVIRONMENTAL MANAGEMENT  COUNCIL
                     PETER BALET                                 GEORGE HODGSON
                       CHAIRMAN                                        DIRECTOR
                                            January 26,2000

Alison A. Hess, CPG
USEPA,Region2
290 Broadway, 19th Floor
New York, N.Y. 10007-1866

Dear Ms. Hess:

      Enclosed you  will find the Saratoga  County Environmental  Management  Council's
(SCEMC's) comments on the Baseline Ecological Risk Assessment For Future Risks in the
Lower Hudson  River and the Human Health Risk Assessment for the Mid-Hudson River
prepared by the Council's chief technical advisor, David Adams.

      Many of the SCEMC's previous comments on the Hudson River Reassessment's Phase 2
Human Health Risk and Ecological Risk Assessment Reports transmitted to you on September 2,
1999  apply to these reports as well. The Council believes these latest Ecological and  Human
Health  Assessments  also  reflect  an  unrealistic   and  excessive   degree  of "scientific"
over-conservatism in calculating the human health and ecological risks.

      In the  enclosed comments, David Adams makes a number of appropriate and what we
feel  are  valid observations relating to  the unavailability and inconsistencies  of  important
modeling information  not being provided to the public for its  review prior to its being used by
EPA in  these  reports.  The unavailability of EPA's revised baseline modeling information and
EPA's lack of agency/peer review of the Farley model are important areas of methodological
concern  as these tools are crucial  in determining the magnitude of the Reassessment's risk
assessments.  The SCEMC requests,  at this time, a copy of EPA's revised modeling information
for our review and  comment.  This information should also be provided to all Reassessment
public information repositories.

      Once again,  it  becomes apparent that EPA  has not developed an adequate overall
methodological framework for the Reassessment when it relies on a model (Farley's) to assess
mid and lower river risks which requires PCB monitoring information on a homolog basis rather
than a congener basis which was the type of data collected during the Reassessment monitoring
period.  This lack of adequate pre-project planning now requires the need for data conversion
which introduces yet "another undefined level of uncertainty  into the  calculated risks". The
Council also feels it is  inappropriate to utilize a limited number of striped bass samples to draw
what we believe to be erroneous  conclusions in  regarding  PCB  concentrations found in
largemouth bass populations.  Again, the need for additional PCB Homolog sampling for

   SO WEST HIGH STREET              BALLSTON SPA. N.Y.  12020              (518)684-4778

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representative  fish species found in the  mid and lower Hudson  River should have been
anticipated and is indicative of the poor methodological planning inherent throughout EPA's
Hudson River PCB Reassessment process.
                                           Sincerely
                                           Peter M. Balet
                                           Chairman
 cc:"   Doug Tomchuk, USEPA, Region 2
       SCEMC Members
       Darryl Decker, Chr., Government Liaison Committee, CIP
       The Honorable John Sweeney
       JohnWanska,USGAO
       Dr. George Putman, Scientific & Technical Committee, CIP
       William Ports, NYSDEC
       Ned Sullivan, Scenic Hudson

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                                      SARATOGA  COUNTY

                         ENVIRONMENTAL MANAGEMENT  COUNCIL
                         PETER BALET                               GEORGE HODGSON
                           CHAIRMAN                                     DIRECTOR
                         COMMENTS ON PHASE 2 - VOLUME 2E
             A BASELINE ECOLOGICAL RISK ASSESSMENT FOR FUTURE RISKS
                             IN THE LOWER HUDSON RIVER
                                 AND ON VOLUME 2F
           A HUMAN HEALTH RISK ASSESSMENT FOR THE MID-HUDSON RIVER
                       HUDSON RIVER PCB'S REASSESSMENT Rl/FS
                                   DECEMBER, 1999

Prepared By:   David D.  Adams,  Member,  Saratoga  County  EMC  and  Government   Liaison
              Committee, January 2, 2000

General Comments                                                                HL-1.1

1.  Both of these risk assessments and the revised EPA FISHRAND Model for the Upper Hudson River
    are based on the revised EPA PCB Fate  and Transport Model and the Farley, et. al. Model for the
    Lower Hudson  River.  Reports  describing these models and the model results  were  not  made
    available by EPA with the risk assessment reports.  It is improper for EPA to present reports to the
    public for  review and comments when information vital to the review is not available to the general
    public.  Before presenting these reports,  EPA should have made the revised EPA model reports and
    the Farley, et. al. Model report available in the designated PCB Reassessment repositories  for review
    along with the risk assessment reports.  I  was able to obtain a copy of the Farley, et.  al. Model
    report through the courtesy of Alison Hess of EPA. Results of my review of the Farley Model are
    presented  as appropriate  in the comments on  the Risk Assessment Reports.   My review was
    constrained,  however, by  not having  the model revisions made after March,  1999.   EPA  Is
    requested to forward information on these revisions.  I  still await the revised  EPA model reports
    which have not yet been issued.
                                                                                HL-1.2
2.   In EPA's public presentation of the Risk Assessment Reports, EPA stated that EPA does not plan to
    review the Farley Model.  The reason given was that the  Reassessment and subsequent remediation
    decision being done by EPA is for the Upper Hudson only. The logic of this position is difficult to
    understand.  If the risk assessments of the  Mid and Lower Hudson are of no significance  to EPA's
    study of the Upper Hudson, then why were the  risk assessments  done?  If the results of the risk
    assessments may have bearing on EPA's decision about remedial action  in the Upper Hudson, then
    EPA owes the public the assurance that the risk assessments have been done on a sound basis.  This
    assurance requires EPA's review of the Farley Model and also review by an appropriate independent
    review panel. EPA Is requested to respond  as to the use of these risk assessments and based on that
    response, as to whether the Farley Model will be reviewed.  While overall the Farley Model appears
        SO WEST HIOH STREET           BALLSTON SPA.tN V  12020              15181884-4778

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    to be a good and credible model, the following are some of my questions/concerns that arose from
    my review of the report by Farley, et. al. which illustrate why review of the Farley Model is needed:
    a.   The very sharp  concentration  gradient shown  in Fig.  1-1  for  di PCB's between  RM159 and
        RM144 is suspect as  it is not  clear what could cause such  a  gradient.   Also, there is no
        explanation for the second bar graph at RM159.  If this bar graph is selected, the sharp gradient
        for di disappears.  Is it possible there is something wrong with the data presented in the first bar
        graph?
    b.  In  many  places, values of parameters are stated  or  assumed  with  little  or  no justification.
        Examples are the sediment thicknesses assigned to each model segment (p.  19); the use of the
        1989 Mohawk River and Upper Hudson River  flows as a constant yearly flow repeated annually
        throughout the PCB simulations  (P. 24);  sedimentation rates, suspended solids concentrations,
        settling velocity, suspended sediment loads from the Upper Hudson and Mohawk River during
        high  and low  flow  periods,  sediment loads  from the Lower  Hudson Watershed and  their
        distribution in the model  segments (P. 26); production rate of solids by  phytoplankton, the
        stoichlometric conversion factor, the decomposition percentage for phytoplankton, and average-
        annual sedimentation rates (P. 27); fraction of organic carbon in sediments  (P. 30); the values
        for aDQC (P. 56); use of Mohawk River PCB concentrations  for Passaic, Hackensack, and Puritan
        Rivers (P. 40).
    c.   The  specification  rather  than  modeling of  hydrodynamic,  organic  carbon,  and  sediment
        transport (P. 18).
    d.  The lack of data to support model calculated values  (see  P. 28 K Fig. 2-5  where data are
        lacking above RM25 for low flow and RM12 for high flow and P. 55 s Fig.  3-1 where data are
        lacking below RM80).
    e.   The assignment  of PCB initial  conditions  for sediments for model segments missing  sediment
        cores. Based on the distribution of cores, it appears only 6 or 7 segments out of 26 segments in
        the model have core data (PP. 41 S 45).
    f.   There seems to be a very large number of parameter adjustments required to calibrate the bio-
        accumulation model (P. 54).
    g.   The rather poor fit in several instances of the data to the model calculations for PCB homologue
        concentrations in surface sediments (P.  59  fie Fig. 3-5).
    h.  The apparent over prediction of total PCB's in perch (P. 75 at  Fig. 3-14).
                                                                                     HL-1.3
3.  EPA also stated in  its public presentation that the only PCB  source considered to  the Lower Hudson
    was the PCB's coming over  the Troy Dam.  While I could not find an explicit statement in the model
    discussion in the Ecological Risk Assessment Report to  this effect, the presentation in the Report
    appears to be based on the Upper Hudson as the only source to the Lower Hudson.  Farley, et. ai.
    state on P. 41  of  their report that while the  Upper Hudson dominated the loading to the Lower
    Hudson in the early  1990's, the Upper Hudson loads continued to decrease in the  1990's and by
    1997 are estimated  to be  slightly less than one-half of the total PCB load to the Lower  Hudson.
    EPA is requested to justify assuming all the PCB loading comes from the Upper Hudson in view of
    the position stated by Farley,  et. al.  As a minimum, EPA should provide values for the risks
    assuming that the Upper Hudson load is eliminated and 50% of  the PCB load to the Lower Hudson
    remains Into the future as no action to remove these  loads appear to be underway. These risk values
    would put into proper perspective the possible contribution of PCB loads from the Upper Hudson to
    risks in the Lower Hudson.

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                                                                    HL-1.4
4  Much of the information in (he December, 1999 reports regarding such items as exposure and
   wScto as essment is a copy of similar information in the August, 1 999 Risk Assessment Report, for
    S  toe Hud on.  Comments were previously submitted on these sections for the Upper Hudson
   •  A. £r«ora Countv EMC's letter to EPA of September 2, 1999 as corrected by the EMC letter
   of  SSST, W?  Therefore, the earlier comments will not  be repeated here but will be
   referenced as appropriate.                                              HL ^ _

5  The need to convert EPA model Upper Hudson PCB inputs to the Farley Model from tri + congeners
   of  the EPA model to the homologue distribution of the Farley Model, as discussed In App. A of Uie
   E oloeicai Rkk Assessment, Is another example of the lack of planning which has plagued EPA's
   l^^n*i«S beginning. The need for evaluation of the Lower Hudson should have been
    een af *e s un o "die study and plans made to obtain data and a model which would fit together
   without the Mripubttons of App.A which Introduce another undefined level of uncertainty Into the
   akulated ! rlE  Comments on At procedure EPA used to make the extrapolation are given later in
   comments on Appendix A.

Vol. 2E Baseline Ecological Risk Assessment Comments

CTrinn 3 1 1 1- P 15"  Please Identify the "few changes" needed to make the Farley Model usable by
IS  Ato "EPA Deques edu> provide an evaluation of the potential effects of starting the model over
afer" e^h 15 year Increment with  possibly imprecise Initial conditions. Is there the possibility of
increasing error In the future predictions?

Section 3 1 1 2- P 1 6*1 7: The treatment of PCB body burdens for striped bass throughout this report
!nH £p romDarison Human Health  Risk Assessment Report is puzzling and a  major source of concern.
The £curt£ string on P  16 focuses on predicting striped bass body burdens In Region 1 because the
Farley  Model on?y prXed striped bass body burdens as far as Region 2. This focus on striped bass In
      1 condnues Sroughout both Reports as calculated striped bass body burdens are «»/ Wif*
       52  dRMH 3 whereas calculations are made for other fish species at RM9C > an RM50 also.
         ssKisasasasjpsarAS
         Reelon 1  It must be that some striped bass appear In Region 1 as EPA on P. 16 discusses
         52 and RM  H However nowhere In the EPA reports are the data for striped bass shown
            SrirJ^"-&-^--1
                    EPA Is also requested to furnish Information on the number and age
model results to the data for striped bass as was done for other species of fish.

The EPA focus on RM152 and RM1 13 for striped bass Is a major concern because of die sign ^nce of
Xd ba« to the rS assessments.  In the Human Health Risk Assessment Report, Tables 2-6 and 2 7
 £w tha  s^ped b ss  re the second largest species eaten by anglers.  The concentration of PCB s In

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striped bass are the highest of any of the fish species ranging up to twice the PCB concentration in brown
bullheads which represent the major fraction of fish consumed (52% per Table 2-7 of Vol. 2F).  Thus,
the product of the percent species in the diet times the PCB  concentration  makes striped bass as
significant as brown bullhead in contributing to the human health risk from eating fish.

The situation for avian and mammal populations is less clear.  While many include fish in their diet, in
most  cases, but not all, the fish seem to be smaller than striped bass.  Because EPA does not provide
definitive  information,  either in the August,  1999 or December, 1999 reports, it is not possible to
determine the fraction of the avian and mammal receptors diet that is assumed  to come from striped
oass but it is likely striped bass contribute In EPA's analysis to at least some of the avian and mammal
receptors.

Because of the ma|or significance of striped bass to the risk assessments, it Is very important that proper
selection be made of the modeled PCB  concentrations In striped bass to be used In the risk assessments.
The trend for  PCB concentration with decreasing river  mile  shows   declining   concentrations  with
decreasing river mile until New York City Is reached  Review of Figure 3-18 ^ laj-gemouth bass from
Vol  2E (the  species  EPA  uses to estimate striped bass PCB concentrations at RM150 and RM113)
indicates  his decline Is not linear but rather decreases from RM113 to RM90  and finally has a much
more gradual  decline from RM90 to RM50.  This trend Is Important because of how EPA Calculates the
future yearly  PCB concentrations  In each  fish species  used In the human health risk assessment.  While
no"Lted, (see comments on Sect. 2.3.1, P. 9 of Vol. 2F) It appears this average Is calculated assuming
a   InSr variation with  distance.   This  assumption  would  overestimate the PCB concentration  In
 argemouth bass and therefore  striped bass. Use of a technique such as graphical Integration would *em
 o be a more  appropriate way  to calculate the average concentration for these species  It Is also of note
te EPA pJdte curves vs. time for all fish species at each river mile ^cept for striped bass. ElAh
reauested to  provide  the curve for striped bass.  But of  more consequence Is  the fact that EPA has
 hosen to use «riped  bass concentrations only at RM152 K 113 In both the  ecological and human
heaT* r°k assessments, while using concentrations at RM152, RM113, RM90 and RM50 for a  other
 pedes ta £ ecolotfcal risk assessment and RM152, RM113,  and RM90 hi die human healtil M
assessment.  This is done, despite the fact that Farley, et. al. do not even consider striped bass In thb
 egion  (Region 1) and the likely sharp drop-off In  PCB concentration In striped bass from RM152  to
RM90.

The
               EPA has taken for striped  bass is  certainly overly conservative and  likely Incorrect In
              contribution of striped bass to the risk assessments. EPA should recalculate the.risks ustag
 a mo e accurate approach.  It Is recommended that EPA use striped bass concentrations at RM90 In die
 human heaWi risk assessment, and that the ecological risk to striped bass be evaluated at RM90 and
 RM50 as was done for other flsh species.  Whether the lack of striped bass PCB concentrations for these
 ^n^ftotoM* risk to other species at these locations Is  unclear because EPA has not
 UMtel™™ of striked bass In the diets of receptors. In recalculating the PCB ™£*™*
 rtrined bass  EPA should also define and account for any size restrictions New York Imposes on catching
 fnJDetain^n'g striped bass.  Size Is related to age and Is Important because PCB concentration In striped
 bass dec eases wfth age due to the migratory nature  of striped bass as discussed In  the Farley, et al.
 rpnort on P  781 and shown by Figs. 3-16 through 3-19 of the report  It Is my understanding that NYS
 ^TJto*- «S taT»«* IB" or greater. Fish  of this size would be expected to be older than 0-
 ^%££^rt**»* PCB concentrations. The excess conservatism in the BU.calcuUdon
 of PCB fontntTatioS  n striped bass is illustrated by comparing Table 3-18 of EPA's Vol. 2E with Fig.

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 3-16 of the Farley report. Table 3-13 shows median values for the years from 1993 to 1997 of 36 to
 24 at RM152 and 5 to 3.5 for RM1.13.  For fish born in 1987, Fig. 3-16 gives a mean of about 3 For
 Food  Region  2.   Fig. 3-19 shows dau  points ranging from 1 to 2 (one year about 5) over this time
 period for fish 6  to 17-years-old.

 The use of largemouth bass, which are a non-migratory fish as a surrogate for striped bass, a migratory
 fish, Is In Itself questionable.  More uncertainty In the calculation for striped  bass arises from the large
 difference between the ratios  of striped bass to largemouth bass PCB concentrations at RM152 (2.5)
 and RM113 (-52) (see P.I 7).  EPA Is requested to provide an explanation for this difference as there Is
 no apparent reason for it.  What are the ratios for RM90 and RM50? It Is also of Interest that the ratios
 (and also those for White Perch) have dropped considerably In recent years. Shouldn't any ratio, If used
 to calculate striped bass concentrations, be based on the more recent data for future predictions?

 Going  back to P.  16, EPA Is requested to explain why the F1SHRAND Model  was  used for  all  fish
 species except striped bass as  again the reasons are not apparent.  Would using FISH RAND for striped
 bass eliminate or reduce some of the concerns discussed above?  Also,  Farley, eL al. make a distinction
 between ages  of striped bass (2-6 yrs. and 6-16 yrs.). Does EPA modeling do  this?  If not, why not?

 Section 3.1.1.3; PP.17K18:   Why Is there no discussion of the second part of Table  3-3, the period
 from 4/91  to 2/96? Table 3-3 does not seem to agree with Fig. 3-2.  Table 3-3 shows more penta
 coming from HUDTOX but Fig. 3-2 shows the opposite.  Also,  Table 3-3 shows a delta of-18 kg for
 hexa but Fig. 3-2 shows a delta of about -52 kg.  Please explain these differences.  It would be helpful If
 EPA would stick to one set of units as less arithmetic would be required.

 Section 3.1.1.4;P.20: The comparison of measured striped bass body burdens to modeled values In
 Fig. 3-9 Is  for Region 2  only, whereas EPA uses only modeled values In Region 1 In Its health risk
 assessment. EPA Is requested to show a plot  of the EPA model results vs. data for Region 1  (RMI52 ff
 RM 113) so the proper comparison can be made.

 Section 3.1.1.5;P.21:  Referring to Fig. 3-10,  would It  make more sense to  plot  the  average  of
 F1SHRAND values In Region I  to compare to the Farley Model as It uses averages for Region  1?

 Section 3.1.1.6;P.21:  EPA Is requested to  supply a comparison similar to Fig. 3-12 for striped bass.
 Why are striped bass often omitted from  data comparisons?

 Section 3.1.2.2;P.23: Please explain what all the "x's represent on Figs. 3-16 s 3-17.  It Is also noted
 Fig. 3-17 shows results only for Region 2 despite the title on the figure.

 Section 3.1.2.3;P.24: Comparing Fig. 3-16 to Fig.  3-19, It appears  the average value for Region 1
 from Fig. 3-19 Is about 50% higher for the year 2020 than the value from Fig. 3-16, but for Region 2
 It appears Fig.  3-16 gfves a somewhat higher value.  Please explain why this changeover should occur.
 Would using the Farley Model  throughout give more Internally consistent results and thus be preferred
 over FISHRAND? Again, why  Is there no forecast for striped bass?

 Section  3.2, P.25:  The selection of a river mile towards the upper end of each range to represent the
range Is another example of the excessive conservatism In the EPA assessments. Given the known drop

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off of PCB body burden with decreasing river mile, using the body burden at the selected river miles
instead of an appropriate average over the river mile segment introduces unnecessary extra conservatism.

Section 3.2.4;P.26:  The use of brown bullhead  results to represent short-nosed sturgeon makes the risk
assessment for the sturgeon very uncertain and  of dubious value because of the unknown uncertainty.
Also the need to  extrapolate the fish PCB concentration data from standard fillets basis to whole body
wet weight basis  produces more uncertainty of unknown magnitude into  the  risk assessment, again
decreasing the value of the calculated risks.

Section 3.3;PP.27-30:  These sections are very similar to those In the August, 1999  Risk Assessment
Reports. The comments previously submitted on these items apply to this report as well and will not be
repeated here.

Section 4; PP.31-36: These sections are very similar to those In  the August,  1999  Risk Assessment
Reports. The comments previously submitted on these Items apply to this report as well and will not be
repeated here.  Additional comments come from PP. B-10 8 B-l 1  of Appendix B. The presentation In
Section B.2.3.1 on P. B-10 answers the question asked In  the EMC's comments to the August, 1999
Risk Assessment Reports as to the amount of chlorine in chlophen compared to PCB's.  However, no
Information is given  to justify  that the behavior In fish of the  chlorine In chlophen duplicates  that of
PCB's.   Page B-11  says  "Hatchabillty was  significantly reduced  In  fish with an  average total PCB
concentration of  170 mg/kg...."  I  thought  Bengtsson's testing was done with chlophen A50 end not
PCB's.   This sentence should  be corrected  to  state what was actually tested.   The discussion here
introduces another factor  of about  10 conservatism In the results by not using the  170 mg/kg  and
15mg/kg data from Bentgsson study but rather the 15 mg/kg and 1.6  mg/kg data.  This further adds to
the total excessive conservatism in the EPA risk assessments (also applies to other fish species In Section
B.2.3  of Appendix B).  Does  this new conservatism  mean that EPA  now considers the ecological risk
evaluation of these fish species In the August,  1999 risk assessment  to be wrong?

Section  5.;P.37-55:   Comments previously made  on the August  1999 ERA regarding  the  over
conservatism  In EPA's risk characterization apply  to the report as well and will not be repeated here.

Section  5.2.1.9;P.43:  As previously  questioned,  EPA  Is requested to explain  why  EPA  reports
Measurement Endpolnts for striped bass only for RM152 and 113 and why these river miles should be
considered at all for striped bass.

Section 5.2.4.1 ;P.45s46: In  view of the unquantifled uncertainty In the calculation of body burdens In
the shortnosed sturgeon and the positive statements about the health of the shortnosed sturgeon in the
last paragraph on  this page, why does  EPA  Insist on putting forth a  negative risk evaluation for  the
shortnosed sturgeon? This  question also applies to white perch as the discussion on P. 46 again Indicates
a healthy situation and the discussion at the end of the  paragraph represents speculation based on only
extremely conservative calculations and Is  inconsistent with the facts  shown by the field studies.

Section 5.4.3;P.50,Section 5.5.3.1;PP.53ez54,Sectlon 5.3.3.1;PP.47S48A:  EPA  Is  requested  to
provide information on what trends were seen in the Christmas bird counts.  This Information would be
helpful In assessing what Is happening to the health of birds In the region.

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       7 3 1-P 57-  The discussion in this paragraph leads to the conclusion that not enough
       -7;^1';-^;  '"' a'5eCpCB,s in the Hudson to have an impact on the raccoon population so
                                 risk to those few raccoons that might be affected?
      A 7-P A-2- It is not clear what is meant by the phrase "duplicate samples are equivalent."
     is rne^fpCB da "from the duplicate samples are exactly equal? If not the case, why weren't
the duplicate GE samples averaged as were the EPA duplicates.

      A ™ A 3-  EPA is requested to provide some discussion of what factors could effect the
Factor 2 and the second step to Factor I .  Is this correct.






sxzz. fxxxisx str.ir™-jss.-. sr- »
based on 1 999 data?
Secdon A.3;P>-4=  See comment above on A-3 ami Fig. A-l ^A-S questioning nMV of factors gtven
In Table A-2.  Also, why should these factors suy constant for 40 years?

rer4p^^^
the post 1 990 releases are not of concern.
Vol. 2F - Human Health Risk Augment Comment!                            HL-1.6
Section 2-PP.5-2 1 : Comments previously submitted on Section 2 of the August, 1 999 Risk Assessment
apply to tMs report as well and will not be repeated here.                          HL-1.7
.^n 3-PP 23H24-  Comments previously submitted on the August 1 999 risk assessment regarding
^«nce'S vtto aTcanc/r art*'** « *« «pon and will not be repeated here.^ ^ g

more appropriate way to average values than straight linear averages.

-------
                                                                                   HL-1.10
Section 2.4.1 ;P. 14: Please confirm that it is the RME value of PCB concentration in the fish that Is used
in the cancer risk assessment.                                                          HL-111

Section 4; PP.25-27:  Comments previously submitted on the August, 1999 risk  assessment regarding
the over conservatism on EPA's risk characterization apply to this report as well, and will not be repeated
here.

-------
Public Interest

-------
SCENIC
HUDSON
'Proieaing tfie I/ofay's "Environment, Town By Tovm
                INC.
            Sent by Facsimile
                                                        January 28, 2000
            Alison A. Hess, C.PG.
            USEPA Region 2
            290 Broadway - 19* Floor
            New York. NY 10007-1866

            RE. Hudson River HHRA/ERA Addendum Comments

                   The findings of the Human Health Risk Assessment for the Mid-Hudson
            River and the Ecological Risk Assessment Addendum: future risks in the lower
            Hudson River continue to underscore the need for an aggressive PCB cleanup of the
           upper Hudson River. With human health risks and ecological risks exceeding
 H P-1.1 acceptable levels into the foreseeable future, for 200 miles of the Hudson River, it
           becomes even more critical than ever that the EPA move forward with a cleanup
           decision as soon as possible.

                  The EPA has pledged to develop and release a plan by the end of this year
           that will serve as the basis of a cleanup decision.  In light of die most recent findings,
           this process must continue to move forward and no additional delays will be
 HP 1 7accc*)taole- Any requests for additional study or  "sidc-by-sidc" peer review should
 rir'1 -z in no way impede the Reassessment schedule.  The EPA should move forward with
           peer review of EPA documents and EPA documents only, despite pressure for "side-
           by-side" peer review and work towards a cleanup of Hudson River PCBs.

                  Due to the limited effectiveness of the fish consumption advisories and the
           continued need for more education about the PCB contamination of fish in the
           Hudson River, the EPA should continue to assess the nsks in the Hudson assuming
           thai such advisories do  not exist.  Angler surveys have indicated that th» inaj/^ of
           anglers cat their catch or give it to family members. In its 1996 survey, the New
           York State Department of Health found that "two-thirds of anglers fishing between
           Catskill and the Tappan Zee Bridge continued to report eating their fish at least
HP-1.3  sometimes and almost half (46%) of anglers gave fish away sometimes or frequently.
           More than half (57%) of anglers in this area ate more fish than advised by the NYS
           DOH advisories."1
           Health Consultation: 1996 Survey of Hudson River Anglers. Hudson Falls to Tappan Zee
          Bridge at Tanytown. New York, Public Review Draft, February 1999, New York State
          Department of Health, Center Tor Environmental Health, prepared under a Cooperative
          Agreement with U.S. Department of Health & Human Services. Public Health Service
          Agency for Toxic Substances and Disease Registry, p. 14.
                                                                                               HP-1
OFFICERS AND OIBECTOIU
('"•Mil
                                                                                             M»fjone L Hart
                                                               David H. Morrinivr
                                                               Fbornlll
                                                               Whcebck WN;mey III
                                                                                             AnnctlinnellisKn
                                                                       1 1:1. \snkiK
                                                              JehV.Johniort
                                                              "in HMAk>
                                                              Eliiibcth B. high

                                                              CiiherineS. Armitagc
                                                              David J. Bnunrldd
                                                              AnncP. Ciboi
                                                              David C Qapp
                                                              Christopher GDavi<
                                                              B. Harrison Frankel
                                                              Robert |> Frcenxin
                                                              Aniu Carlson Caniu-ic
                                                              farickGarvnr
                                                              Cynthia H. Gibbons
                                                              MB. Thumon Gixxnv
                                                              Mormon H. Hecladu-r
                                                              Christine LcWr Hcwiri
                                                              FnnkMinucci
                                                              AmhonjrJ. Monello
                                                              Fonntj. Murray. Jr.
                                                              Vfcrrk- 1_S. Prior
                                                              SammlF. Pryorlll
                                                              Rudolph S. Rauch III
                                                              David N. Redden
                                                              Frederic C ftch
                                                              H.UaudcShojul
                                                             .Mmr.Wnrr
                                                             Alexander £. Zagnrcos
                                                             NathCanre
                                                             William H. Ewcn
                                                             John Fiench 111
                                                             Eliiahcih J. MeCorinaek
                                                             BarnahavMcHenrx
                                                             CharleiP.Noyam
                                                             Mr». r-RdeiiekH.OjSni.vJr.
                                                             Uuwnee Rockefeller
                                                             David iivc
                                                             Mrs. Thomas M
                                                             llll^ll
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         Alison A. Hess, C.P.G.
         January 28, 2000
         Page 2

HP-1 .3        In boih (the Hudson River Sloop Cleaiwater Survey and the NYS DOH Survey "the fish
(Continued)  that anglers kept were among the most contaminated species in each part of the river."

                As EPA has concluded the 1996 NYS DOH Angler Survey also concluded that "Some
         anglers and others who eat fish from die Hudson River are being exposed to levels of PCBs that
         are a health concern and are at risk of adverse health effects."* Institutional controls, such as the
         fish advisories, are not a substitution for a cleanup of the Hudson River as has been suggested by
HP- 1.4 &c General Electric Company. It is important to note that due to the PCB contamination offish,
         women of childbcaring age and children are advised not to eat any fish, from any location along
         die Hudson.

                New scientific information concerning non-cancer health effects of PCBs has shown that
         the Food and Drug Administration 2 parts per million (ppm) level, on which New York State
         advisories are based, is not adequately protective of human health. Hie scientific and public
         heahh community now advocates a much lower level. Based on EPA's most recent findings for
         non-cancer health risks that eating fish from the mid-Hudson results in PCB exposure that is 30
HP-1 .5 times higher than EPA Hazard Index Reference level, it is imperative that EPA adopt a much
         lower level than the FDA level of 2 ppm. The EPA should adopt a level no greater man 0. 1  ppm
         as has been done recently by the State of Connecticut for their fish advisories.

                The alarming reality that human health and ecological resources of the Hudson River are
         threatened from Fort Edward to New York City, reminds us that 200 miles of this great River is
         and will continue to be severely impacted by the PCB contamination dial started some 60 years
         ago. These most recent reports, in conjunction with other EPA findings, indicate that the
HP-1 .6 sediments are the dominant source of PCBs to the rest of the river system and that the natural
         breakdown of PCBs is inappreciable, provides compelling and irrefutable evidence for the need
         to remove PCB-contaminated sediment from die upper Hudson River.
                                                    Respectfully Submitted,
                                                    Rich Schiafo
                                                    Scenic Hudson
          3 Ibid.
          slbid.

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                                                                    HP-2
 January 27,2000

 Jeanne M. Fox
 Regional Administrator
 United States Environmental Protection Agency
 290 Broadway
 New York, NY 10007-1866

 Re: EPA Baseline Risk Assessments of PCBs in the Hudson River

 Dear Ms. Fox-

 On behalf of over seven hundred Appalachian Mountain Club members in from the
 Albany region who live near and enjoy the varied recreational resources within the
 Hudson River watershed, I am writing to comment on the EPA Baseline Risk
 Assessment of PCBs in the Hudson River. The Appalachian Mountain Club promotes
 the protection, enjoyment and wise use of the mountains, rivers and trails of the
 Northeast.  Central to our  mission is the belief that mountains and rivers have an
 intrinsic worth and also provide recreational opportunity, spiritual renewal and
 ecological and economic health for the region.

 The findings of the Human Health Risk Assessmenr for the Mid-Hudson River and the
 Ecological Risk Assessment Addendum continue to provide scientific evidence
 supporting the need for a thorough PCB clean up ofthe upper Hudson River. The
 EPA's own reports indicate that PCBs from the Upper Hudson River continue to pose
 a threat for 200 mj'«* of the river. For some species, the report shows, ftaure
 concentrations of PCBs in the lowerHudson River win generaUy exceed levelsknown  Hp_2.i
 to cause advene ecological effects through 2018. Given the on-gomg threat posed by
 the PCBs in the river sediment to the environment and to human beings, a is time to
 move forward with adeanjip^eeision. The Environmental Protection Agency should
"move steadily towards releasing a decision on clean up plans by the end of This year.
 For every delay, human health and ecological well being continue to be jeoparoaeo.
 For this reason, any requests for additional studies or for "side by side" peer  review
 should not  obstruct the Reassessment schedule. The river has waited long enough.

 New scientific information concerning non-cancer health effects of PCBs has shown
 L the Food and Drug Administration's level of 2 parts per million (ppm) does not     HP-2.2
 wovide adequate protection of human health. The EPA's own findings tor nowancer
 £uTrisks from consuming fish from At miiHudson river show that PCB exposure

-------
 is 30 Ti'mM higher than the EPA Hazard Index Reference level. Due to the level* of risk
 and of hazard, the EPA should adopt a level of no greater than 0.2ppm instead of
 using the FDA level. This action would be supported by much of the scientific and
 public health community aT"^ ""Quid set a standard Thar is more protective of human
 health.

 Fish Advisories are not a substitute for removing PCBs from the river. There is already
 jubftattriai mrifaftfu f fo*t niattV anglers do not follow or understand the posted
 warnings and share fish caught from the Hudson with members of their families, thus  JJP-2 3
 putting multiple lives ac risk of adverse health effects. The EPA muse continue to assess
 the risks in the Hudson River with the assumption that the advisories do not exist.

 The evidence is in. It is time to move forward with a full and comprehensive clean up
 of the Hudson River in order to protect human and ecological health. It is time to stop
 the continuation of exposure to health risks *»
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                                                                     HP-3
US EPA Region 2
Ms. Alison Hess
Remedial Project Manager
290 Broadway
New York, NY 10007-1866

Re:   Comments Health Risk Assessment, Lower Hudson River

Dear EPA:

      Please refer to the attached documents for supporting technical information

regarding my comments. The EPA presented documentation indicating that there "might

be" a possible health risk with those citizens which consume at 51 one-half pound meals

per year, when the central tendency fish ingestion rate has been determined to be six half-  HP-3.1

pound meals per year (Connelly et al.. 1992). The public health protection/ worst case

scenario of 51 half-pound meals per year for 40 years is mathematically conservative and

is not supported nor denied by current health data, and cannot be related to any

community health based studies which may support or deny this conclusion.

      At the recent public meeting I asked the question, "Are there any Community

Health Based studies which would show any indications of health effects or higher cancer

rate in communities which have been exposed to PCB in any fashion in NY?" The        HP-3.2

answer, to the best of my memory, was related to the amount of time it would take to

accumulate this type of information and this was the best way to get answers quickly. The

problem is not easy to understand, so why do we expect the answers to come  any easier?

I believe that PCB's have been in the Hudson River for many years, we have known

about this for years, and only recently has anyone tried to quantify the related health

effects and show direct health effects to the communities that live in and around the

Hudson River. The NY State DEC keeps record of everyone who has obtained a fishing

-------
 license in NY. This would probably show families whom have fished for years in and

 around the Hudson and someone could utilize the money being spent to find actual health

 effects in communities and families with the hypothetical exposures being presented by

 EPA at this time. Again, this problem has been present for many years and even the most

 vehement environmentalist wanting cleanup of the Hudson would have to agree that the    HP-3.3

 Hudson River is in better shape than it was 20 years ago! Also, according to EPA in

 1999, NY State still had 79 Fish Advisories in effect for PCBs, Chlordane, Cadmium,     HP-3.4

 Dioxins, Mirex, and DDT.

       The process to find out possible health effects from PCB's started at  least  10 years

 ago  and  only in  the past year has  anyone actually gone into the homes of people

 potentially effected by PCB's. The New York State DOH and ATSDR have  begun studies

 to quantify any effects in population along the Hudson in Glens Falls and  Fort Edward,

 NY. This information must be apart of any health based decision making process and the

 ATSDR must perform a Health Assessment for pre and post treatment alternatives to

 ensure optimal public health protection. We cannot afford to start a "Clean-up" project

 based upon limited information on the possible health effects that the "clean-up" could
                                                                                 HP-3.5
 cause in the communities. Example: MTBE was placed into gasoline supplies to help stop

 air pollution, but nobody wanted to study the effects of MTBE in groundwater prior to its

 release into the environment. To initiate a clean up without studying all potential impacts

 is irresponsible and I  do not want  the Hudson River to be another example  of a

 recommended clean-up project gone wrong (like MTBE in groundwater supplies)!

Please consider the following information while reviewing the immediate EPA Health

Risk Assessment and the need (if any) for Immediate action:

-------
100% of New York State's lake acres and river miles are under fish advisories.
National Academy of  Sciences (NAS) found that FDA and State codes should be
strengthened io reduce consumption of organisms with high contaminant levels; agencies
should support research to determine the actual risks from consuming organisms with
contaminants, and States should continue site closures, health advisories, and continue
public education about the risks on specific chemical contaminants.
NAS found that data evaluating contaminant levels in fish do not consistently focus on
the analysis of edible tissue. "These analyses, by their design, offer insufficient insight
into contaminant levels in the edible portion of the seafood products." Also, "There is an
apparent lack of coordination in the development and use of data on chemicals in the
aquatic environment among FDA, EPA, and the NOAA, and other States."	
NAS: "the CDC  should  develop an  active and  aggressive program, founded  on
community-biased health surveys, to better determine the level and source of seafood-
borne illness in the US population."                                	
The FDA specifies PCB concentration limits of 0.2 to 3 parts per million in infant foods,
eggs, milk fat, and poultry fat. These products (concentrations) can be sold to consumers.
The 51 half-pound meals - about 25 pounds of recreational fish consumption for the
maximum exposed individual. The FDA-NAS reported that in 1991 about 4 pounds of
recreational fish were consumed per year in addition to the 15-16 pounds of commercial
fish per year. Total = about 20 pounds offish consumed per year, 5 Ibs. less than max.
In 1993, research has shown that nature has some processes already chemically reducing
the PCBs present in the Hudson River.                                       	
 The ATSDR'does not know whether PCBs causes cancer in people. Also, ATSDR with
 NYSDOH is currently researching effects of PCB exposure by conducting community-
 based health surveys.                                                    	
       In addition, there was a reference during the public meeting that the current health
 advisories are not acceptable means to prevent exposure to health risks. 1 would like to
 remind all of: us that Public Education and Awareness programs are the backbone of all
HP-3.6
HP-3.7
HP-3.8
HP-3.9

HP-3.10


HP-3.11


HP-3.12

HP-3.13
HP-3.14

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public health programs. The reason the USA is in good health is because of the good

public health education! Proper refuse and garbage control prevent vector and rodents,

washing hands prevent the spread of foodbome disease and infection in hospitals, and

even lead poisoning can be avoided by education to avoid high lead content water and

using first flush activities if the situation fits the level of protection.

      To say in passing that public health education is not an effective method of public

health disease prevention is not accurate.

Thank you.
Scott T. LeRoy, M&REHS/RS, Soil Scientist
2434 Route 9D
Wappinger Falls, NY 12590
9142971909
sleroy@bestweb.net

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Hudson River PCB Research Project Announced
                                                                       Page 1 of 2
 [Press Releases: ^]



 :--,Horn* Rage  ^.
   Commissioner •
     Info for
   Researches
                       From  the  Commissioner
                                  DOH NEWS

 State of New York
 Department of Health


                Hudson River PCB Research Project Announced

 ALBANY, April 23,1999 - The State Health Department today announced a new research
 project, PCBs and Health: The Hudson River Communities Project, that will examine the
 possible effects of exposure to PCBs on the human nervous system. For the project, the
 Health Department is recruiting 100 residents, both men and women, between the ages of 55
 and 74 who have lived in the villages of Fort Edward or Hudson Falls for at least 25 years.
 These villages are two areas where PCBs have been used in manufacturing operations. In
 addition, a control group is being recruited consisting of men and women, also between the
 ages of 55 and 74, who have resided in the city of Glens Falls for at least 25 years. Glens
 Falls was selected because it is upriver from where PCBs were used in manufacturing
 operations.

 The focus of the project is current and past exposure through the consumption of PCB-
 contaminated fish or through airborne PCBs. Therefore, to be eligible for the project.
 participants must not have worked in a job where they may have been potentially exposed to
 PCBs. Information collected from the Fort Edward/Hudson Falls group will be compared to
 information collected from the Glens Falls control group. Department of Health researchers
will analyze project data to see if the two groups score differently on the nervous system
tests, and whether or not the differences are associated with higher PCB exposures and
blood PCB levels.
                      PCBs are a group of 209 man-made chemicals that were used in many commercial and
                      electrical products until their manufacture was banned in the mid-1970s. The manufacturing
                      of PCBs was halted in the United States because of evidence relating to environmental
                      buildup and its potential harmful effects. Edible portions of sport fish from the Hudson River
                      are also known to contain PCBs.

                      This project is designed to address whether exposure to PCBs may cause biological changes
                      in the nervous system such as memory loss, decreased muscle coordination and control, and
                      decreased sense of smell.

                      This two-phase project will include interviews, biological sampling, and nervous system tests
                      in Phase I, and environmental sampling in Phase II. The interviews will include questions
                      about participants' consumption and preparation offish caught locally, residential histories,
                      and lifestyle characteristics such as cigarette smoking. Biological sampling will include
                      collecting a blood sample from each participant and analyzing the samples to determine
                      blood PCB level. The nervous system tests will measure small changes in short term
                      memory, muscular movement abilities, and sense of smell. They will involve identifying
                      odors, shapes or words and performing simple tasks with hands and fingers.

                      The environmental sampling in Phase II will involve air testing for PCBs in and near
                      participants' homes. Participants will be paid up to $100, including $50 for the interview,
                      blood sampling, and nervous system tests, and another $50 for the  completion of the air
                      sampling. This project is funded by the Agency for Toxic Substance Disease Registry
                      (ATSDR) for three years and will begin this summer.
                     4/23/99-39 OPA

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           U. S. FOOD AND DRUG ADMINISTRATION
             OFFICE OF REGULATORY AFFAIRS
                 5600 FISHERS LANE
              ROCKVILLE, MARYLAND 20857
 Seafood Training  Program
    National Academy of Sciences

       Report on Seafood Safety

               Executive Summary
     Seafood Production Distribution and Consumption
   Microbiological and Parasitic Exposure and Health Effects
                    and
       Naturally Occurring Fish and Shellfish Poisons

    National Academy Press, Washington, D.C.
                   1991
DEPARTMENT OF HEALTH AND HUMAN SERVICES
          PUBLIC HEALTH SERVICE
      FOOD AND DRUG ADMINISTRATION

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National Academy of Sciences
          Report on
     SEAFOOD  SAFETY
  National Academy Press, Washington, D.C.
              1991

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                          Executive Summary
                                   OVERVIEW

        Fish and shellfish are nutritious foods that constitute desirable components of
 a healthy diet Most seafoods available to the US. public are wholesome and unlikely
 to cause illness in the consumer.  Nevertheless, there are areas of risk. "Hie major risk
 of acute disease is associated with the consumption of raw shellfish, particularly bivalve
 molluscs. For persons living in areas in which reef fish arc consumed (Hawaii, Puerto
 Rico, the Virgin Islands), there is a  risk of ciguatera; other natural toxins (paralytic
 shellfish poisoning,  neurotoxic shellfish poisoning,  etc.) have been associated  with
 shellfish from  endemic areas.  Finally, there are less well-defined risks of acute and
 chronic disease related to environmental contamination of  aquatic  food  animals.
 Dealing with such risks on  a short-term basis requires improvements in the present
 system of regulatory control. In the long term, amelioration and eventual elimination
 of some hazards  require strengthening and more  effective  application  of control
 measures to prevent the disposal of human and industrial waste into offshore marine
 and fresh waters.
       Because of the  strong  public interest in seafood  safety  and the declared
 intention at the  congressional level  to  develop a  new inspection system, a clear
 opportunity exists to introduce innovative methodologies  for control  that address
 directly the important health issues associated with seafood consumption.
       This report reviews the nature  and extent of public health risks associated with
seafood, and examines the scope and adequacy  of current seafood safety programs.
Tne conclusions and- recommendations arrived  at are summarized in  the following
material:

       • Most  current health risks associated with seafood safety originate in  the
environment and should be dealt with  by control of harvest or at the point of capture.
With minor exceptions, risks  cannot be identified by an organoleptic inspection system.

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2                                                               SEAFOOD SAFETY

      • Inspection at the processing level is important to maintain safety of seafoods,
but there is  little evidence that increased inspection activities at this  level would
effectively reduce the incidence of seafood-borne disease.
      • With currently available data, it is possible to  identify the source of much
of the acute illness associated with seafood consumption, though the dimensions of the
problems are not always known;  these data, in turn, can form the basis  for national
control  programs.
      • Chronic fllness resulting from 9fnfr*rf consumption is associated primarily with
environmental contamination; thus, control depends on improved understanding of the
occurrence and  distribution  of the  chemical  agents  involved, the  exclusion  of
contaminated seafood from the market,  and  increased  action to  prevent additional
pollution of the waters.
      • Because  well  over  half  the  nation's  seafood  supply  is imported  and
environmental contamination is globally pervasive, it is  important that the safety of
imported seafood be ensured  through  equivalent  control measures  in exporting
countries.
      • One-fifth of the fish and shellfish eaten in the United States is derived from
recreational or subsistence fishing, and these products are not subject to health-based
control; there is need to  improve  protection for consumers of these  products by
regulation  of harvest  and  by  education concerning  risks associated with their
consumption.
      • Because the problems  are largely regional, the  primary effective control-
except  for imports-is  at  the  state level,  and  this effort should be strengthened.
However, there is need fqr federal oversight,  general  rule setting,  and support to
ensure  the effectiveness of state-based programs and to provide expert assistance  and
specialized facilities.
       • There is a  lack of understanding of the nature  of seafood hazards in the
food service  sectors and by the consuming public and health professionals; a vigorous
campaign for information dissemination  and education in these  matters is needed,
particularly for high-risk consumers  and high-risk products such as raw shellfish.
        • An improved national  surveillance system should be developed to  provide
more reliable and comprehensive  information on  seafood-borne disease incidence.
Data will then permit meaningful risk identification and  risk assessment as a basis for
effective regulation  of seafoods (current data on disease  occurrence in seafood
cojisumnJion, are top fragmentary, ta allow reliable risk assessment of microbiological
 and natural  toxin hazards).

        A summary  of hazards,  risks, and their control  for the major groups of
 hazardous seafoods in shown in Table 1-1.  They are arranged in order of importance.
        Among seafood consumers, the group at greatest  risk appears  to be consumers
 of raw  molluscs because of environmental contamination and naturally occurring vibrios.
 Consumers  of recreational and  subsistence fishery  products are the second  largest
 constiiuencv at risk,  hoih from nntural tiixms and from  enx-ironmeni.il comumm.mi.v

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12                                                            SEAFOOD S4FE7Y

      • Primary regulatory authority should be at the itate level, wjthfuading. quality
control, and ip*"foifa«» assistance from a federal seafood safety program.
      • Imported seafoods must be certified to be free of natural toxins through
equivalency arrangements or more effective memoranda of undemanding (MOUs) with
exporters.  An MOU refers to a formal agreement between a US. government agency
fe.fr  FDA) and another government  agency (federal, state, local), or  an informal
agreement with a foreign government or oiher foreign institution.
      • Educational programs on the  dangers of natural  seafood toxins must be
developed for recreational and subsistence fishers, and health providers must be given
information to improve the identification and treatment of fliness due to seafood toxins.


                               Chemical Residues

EXTENT OF RISK

       Fish and shellfish accumulate chemicals from the environment in which they live,
but the extent of accumulation depends on such factors as geographic location, species
of  fish, feeding patterns,  solubility  and  lipophilicity of the  chemicals, and their
persistence in the environment.  Moreover, whereas land  animals used for human
consumption are fed mostly food of plant origin, aquatic animals that contribute to the
human diet are generally predators of other animals and, in some cases, predators of
predators.   Because of this, chemicals have  an opportunity  to  become more
concentrated through bioacpumulation.
       The most difficult area for risk evaluation is the problem of chemical residues
because the health effects suspected do not take the form of obvious, distinctive, and
acute illnesses. The potential risks of concern (e.g, modest changes in the overall risk
of cancer, subtle impairments of neurological development in fetuses and children) are
generally quite  difficult  to  measure directly in  people exposed  at levels that  are
 common for U.S. consumers.  Immunoincompetence increases cancer risk. Inferences
 about the potential magnitude  of these problems must be based on  the levels of
 specific chemicals present, on observations of human populations and  experimental
 animals exposed at relatively high doses, and on  reasonable theories about the likely
 mechanisms of action of specific toxicants and the population distributions of sensitivity
 and  human  exposure.  In nearly all cases the current  state of knowledge on these
 subjects must be regarded as quite tentative.' Additionally, the number, and variety of
 chemical residues are substantial, although a small minority  constitute the bulk of the
 risk  that can be assessed quantitatively at this time.-
        Overall, several chemical contaminants in some species of aquatic organisms in
 particular locations have the potential to pose hazards to public health that are gre
 enough to warrant additional efforts at control.  Available  information  suggests thai
 these risks, in the aggregate, are not generally of a magnitude comparable to the high
 environmental health hazards characterized to date; nevertheless, their control *uu,u

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  EXECUTIVE SUMMARY                                                       13

  significantly improve public health.  Some examples of risks that may be significant
  include reproductive effects from polychlorinated biphenyls (PCBs) and methylmercurr
  carcmogenesis from selected congeners of PCBs, dioxms, and dibenzorunns (all of
  which appear to act primarily by binding to a single type of receptor); and, possibly,
  parkmsonism in the elderly from long-term mercury exposure. Several other metallic
  and pesticide residues also warrant attention.


  PRINCIPAL CONCLUSIONS

       • A  small  proportion  of  seafood  is  contaminated  with  appreciable
  concentrations of potentially hazardous organic  and inorganic chemicals from both
  natural and human sources. Some examples of the risks that may be significant include
  reproductive effects  from PCBs and methylmercury,  and cardnogenesis from selected
  PCB congeners, dioxins,  and chlorinated hydrocarbon pesticides,
       • Consumption of some types of contaminated seafood poses enough risk that
 efforts toward evaluation, education, and control  of that risk must be improved.
       • Present quantitative risk assessment procedures used by government agencies
 should be improved  and  extended to noncancer effects.
       • Current  contaminant  monitoring and  surveillance programs  provide  an
 inadequate  representation  of the  presence of contaminants in  edible portions of
 domestic and imported seafood, resulting in serious difficulties in assessing both risks
 and specific opportunities for control
       •  Dye to the uneuenness of contamination among spedes and geographic
 sources,  ft is feasible to  narrowly target control efforts and soil achieve meaningful
 reductions in exposure.
       •  The  data base for evaluating the safety of  certain chemicals that find then-
 way into seafood via aquaculture and processing is too weak to  support a conclusion
 that these products are being effectively controlled.


 PRINCIPAL RECOMMENDATIONS

       •  Existing regulations to minimize chemical and biological contamination of the
 aquatic environment  should be strengthened and enforced.
       •  Existing FDA and.staie-jegulations should be-strengthened arid enforced to
 reduce the human consumption of aquatic organisms  with relatively-high contaminant
 levels (e.gn certain species from the Great Lakes with'high PCB  levels, swordfish and
 other species with high  methylmercury levels).
       •  Federal agencies should actively support research  to determine actual risks
from the  consumption of contaminants associated with seafood and to develop specific
approaches for decreasing these  risks.
       •  Increased environmental monitoring should  be  initiated at the state level as

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                                                      SEAFOOD SAFETY
14

•-
 e    .n  contamination advboriB tailored to the
reproductive or other special nib, and mformanon sores of speafle groups of

        pubBc education  on *f«iSc chentol wnamtont  bmd. dx»ld  be
                       ernment «e»cie, *o»M ccmite .be opno.of.u.uory

        AddWoial study of potential chemical contamination rub ««ocj.«
      e taponed iqtaf. pnxluas
 standards.
                                                        a,
    SCOPE AND ADEQUACY OF CURRENT SEAFOOD SAFETY PROGRAMS

              Recnlatoiy Guidelines, Monitoring and Inipecdon

      Tie current «ynem of goven-nce d«gned « protect *
                    of an intricate and comptanentny lyitem of
              and the National Marine
                   responsibility may lie with one or more of that health.
                   . or agricuhural deparunenu.  S«a«s generaH, «nd « adopt
                         ,. federal government b setting regulator, guidelines
and dbek*
         o«r    te«d an    e

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EXECU77VE SUMMARY                                                         15

contaminants is a task shared by EPA and FDA. Their strategy has been to focus on
a limited number of chemical contaminants and to set regulatory limits by means  of
"tolerance  levels."  Results of various federal and state efforts to monitor contaminant
loads in the nation's marine and freshwater environments suggest strongly that several
chemicals require a more fundamental review and evaluation.
       In terms of assessing and managing risks, the overall posture of relevant federal
agencies, particularly FDA. appears to be almost totally reactive.  In the committee's
judgment, there has been less effort than would be desirable to discover and quantify
hazards that are not yet on the public agenda, to evaluate options-for reducing risks,
and to implement policies that protect both the health of consumers and the stability
of commercial markets.
       One of the more important activities at  both the federal and the state levels is
environmental monitoring.   Because the  majority of seafood is from wild stocks, ihe
quality of harvesting waters is of fundamental concern. The EPA and certain sate
governments [primarily by way of their involvement in the National Shellfish Sanitation
Program (NSSP)J have instituted programs to establish the level  of contaminants  in
seafood harvesting waters.
      These efforts have led to important  insights into general water quality but, for
the most pan, do not supply sufficient information on the  question of seafood safety.
Among other things,  they lack  (1) sufficient  geographic scope, (2) a  common
methodological approach, and (3) sufficient focus on  the edible portion of seafood in
order to  determine public health, as opposed to environmental health, impacts.  This
last point is an important one. Except for the monitoring of harvesting waters carried
out as pan of the NSSP, data evaluating contaminant levels in fish and shellfish do not
consistently focus on the analysis of edible  tissue. More often the focus is on whole
fish or on liver and gallbladder  analysis.  These analyses, by  their  design, offer
insufficient insight into contaminant levels in the edible portion of seafood products.
       Inspection efforts by FDA and various state and local public health agencies are
designed to ensure safety, but are insufficient to ensure in all cases that the regulatory
guidelines defined by FDA and EPA are not being exceeded. The sampling strategies
employed by these various agencies are designed to focus inspection and enforcerrent
activities on areas in which the  probability of a problem  appears highest  Ongoing
governmental efforts to develop  new inspection programs,  with a focus on the public
health aspects of the raw product and the environment from which these products are
derived,  along with continued control of seafood  production and processing,  could
provide measurable additional benefits in.seafood safety..  ••     •       •  <
      Given many of the intrinsic attributes of seafood'already discussed, it is clear
that an approach recognizing the advantages of regional/local control and surveillance
is essential. The question of seafood safety  should continue to be one in which federal
and state roles are viewed as  a cooperative  partnership.  It is  also apparent that
seafood commerce is taking place within  an increasingly interdependent international
economy.  Many of the major trading partners  of the United States are developing  or
     T refinin  torm:il regulatory prngmniN lor «.c:ifuod s;ifct%.  These effort  *h.>..!J

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 16                                                           SEAFOOD SAFETY

 be taken into account in designing a domestic program.
 PRINCIPAL CONCLUSIONS

       • Federal  (mostly  FDA)  guidelines  for  microbial  and  natural  toxin
. contamination should be extended  and updated.  Those that exist have not been
 adequately conveyed to the fishing industry and to interested memben of the public.
       • Federal guidelines on chemical contaminants in seafoods are limited in scope
 and, in some cases, questionable  as to the levels set  There is an apparent lack of
 coordination in the development and use of  data on chemicals in the aquatic
 environment among FDA, EPA, the National Oceanic and Atmospheric Administration
 fNOAA) and the states.  Better recognition is required of the importance of regional
 factors in the occurrence of toxic fish  and shellfish and of the existence of high at-
 risk groups (e.t, pregnant women, children, recreational and subsistence fishers).
       • The present  federal  monitoring and inspection system is  too  limited in
 frequency  and direction to ensure enhanced safety of seafoods.  The monitoring
 process depends too much on evaluation of the product, rather than on safety of raw
 materials, with the single notable  exception of the NSSP. However, even NSSP is not
 providing  adequate protection because molluscan shellfish appear  to cause  most
 seafood-borne disease.                                     ....,._    ^  f
       • Recreational and subsistence fishing is largely ignored m health and safety
 monitoring at the federal level Consumers of seafood from these sources can be at
 high  risk  from natural  toxins and chemical pollutants in certain regions  and in
 particular species of fish. The health risks include cancer and the subtle impairment
 of neurological development  in fetuses and children.
        • The present system of data collection on seafood-borne Olness by CDC does
 not provide an adequate picture  of the extent and causes of such disease.
        • Seafood advisories  warning of local or species-associated health risks are
 issued mostly by state authorities  and vary  greatly in both their content and their
 distribution.  Nevertheless, these advisories serve a useful purpose.
        • Because of the regional nature of much of the domestic fisheries problems,
 states seem the logical level  at which to tackle seafood control problems.   However,
  help  and  guidance from the  federal level  are required.
        •  State programs-tor monitoring,  surveillance,.and..control of seafood safety
  are generally in place in coastal states that  use federal guidelines and action  levels
  where these are available.  However, the quality and effectiveness of the programs vary
  greatly as a function of the  financial and  administrative support available to  the
  responsible state units,  and in accordance with the  character of the resource,   f
  ereater emphasis should be  placed on the development of formal arrangements with
  foreign producers  to  guarantee that imported  seafood  has been  harvested and
  processed in noncomaminated environments.

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EXECUTIVE SUMMARY                                                        17

       • Present training and education of industry and regulatory personnel are too
limited both in scope and in number*  T**«rfBcicHt attention is even to the education
of physicians and other health professionals on tpafood safety and the characteristics
of seafood-borne disease.'  This is also true of the consuming public.
       • The regulation of imported .seafoods .to ensure safety is largely based on end
product inspection and testing, except where MOUs east This is ineffective because
h involves a mainly reactive process.
       • The regulation of imported seafood products is carried  out largely without
regard to other national or international programs.  There  is tremendous variance in
both regulatory limits for contaminants and inspection protocols in various countries,
which leads to excessive and cumbersome inspection strategies for the importing state,
and may also lead to  a general restriction in the  number of countries engaged in
international  seafood trade in the future.
PRINCIPAL RECOMMENDATIONS

      •  A more concise, comprehensive, and generally available single source for all
FDA guidelines relating to seafood safety should be  developed  and updated on  a
regular basis. This information should be disseminated to industry and integrated into
state regulatory processes through more routine and uniform training programs.
      •  The development of an interagency structure with a single focus on seafood
safety could contribute significantly toward increasing communication within the federal
regulatory system, but the responsibility for primary control should be with the state.
      •  Federal agencies should develop a set of monitoring and inspection practices
focusing more strongly on environmental conditions and on contaminant levels in the
edible portion of seafood at the point of capture.
      •  Strong consideration should be given to creating a marine recreational Gshing
license system that is linked to the distribution of information characterizing the level
and scope of potential risk from eating recreationally caught fish. Strong consideration
should also be given to the closure of  recreational harvest areas deemed to pose  a
threat to human health.
      •  The CDC should develop an  active  and aggressive program, founded on
community-based health surveys, to belter determine the level and source of seafood-
borne illness  in the U.S. population.
      •• Consideration-should.be given to.the development of agreements with foreign
authorities and individual producers to  ensure that imported products are treated in
a manner consistent with and equivalent to domestic- products.
      •  A  more pronounced and  consistently  defined federal role in the risk
characterizations  leading to seafood health advisories should be developed.  A more
consistent and  focused effort in determining and  communicating public health risks
from contaminated seafood should also be developed.

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18                                                           SEAFOOD SAFETY

      • As more countries  require the  equivalency of  domestic and imported
products, h is apparent that the time has come fior the international community to
begin a process that would ""'"""•»* the differences existing among national regulatory
guidelines and approaches.
             OPTIONS FOR REDUCING PUBLIC HEALTH RISKS

                Monitoring, Control, and SnntUIanee Me
      The current system involves (1) surveillance by federal and state agencies to
identity seafood-borne disease (e,g, CDC and state health departments); (2) evaluation
of risk and setting of guidelines and action levels mostly by federal agencies (e.g, EPA
and FDA); (3) control of risk by inspection and testing of edible fish and shellfish (e.g.,
states, FDA, and NMFS); and  (4) action to protect consumers by embargo, detention,
seizure, or recall, and by issuance of warning advisories (e.g^ states and FDA). This
system needs revision and  strengthening to develop a  truly risk-based regulatory
process i
      The  data base on which regulation depends is  inadequate.  Tie disease
surveillance system of CDC suffers from inadequate resources and should be refocused
to provide a more  complete and balanced account of seafood-borne disease. More
analytical data on contaminants are needed, which could be obtained by increasing
FDA analyses and sponsoring  broader integrated studies of marine and fresh waters
by EPA and corresponding state agencies.
      Inspection and testing should focus on actual problems (as in HACCP systems),
and  there should be increased  efforts to develop rapid, reliable test methods  for
dangerous microorganisms, toxins, and contaminants. This will require a restructuring
of inspecrional systems to accommodate newer methodologies and to train personnel
in their application. Emphasis on purely sensory evaluation should be decreased.
      Problems of interagency jurisdiction, unclear regulations, or poor cooperation
among state and federal agencies should be addressed and rectified. This will require
added resources.
                    Characteristics, of .Control- Requirements-

      Control measures should be applied initially at the earliest stage of seafood
production by monitoring of water quality and condition.  Such measures would apply
to  the  molluscan  shellfish  problem  and to  most natural toxins  and  chemical
contaminants, and would permit the exclusion of potentially dangerous fish or shellfish
from markets by fishing closures and use of advisories.  Rapid and simple tests  should
be developed and used 10 screen potentially hazardous fish or shellfish at the point or
harvest to reduce costs to the fishermen and to protect the consumer from toxin* arul

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                  Seafood Production, Distribution,
                              and Consumption
                                       ABSTRACT

               Consumption of seafood has increased over the last decade, without a concomitant
        increase in reported illness. This increased consumption vend is expected to continue both
        for prepared and for fresh or frozen varieties.  The 1989 consumption  figure was 1S.9
        pounds of edible meat per person per year. Total commercial landings were a record &S
        billion pounds in 1989, and  imported edible products  totaled 12 Wilton pounds.  The
        majority of the seafood supply was harvested from wild populations. The aquaculture
        ponton of this supply will  probably increase. A substantial amount of seafood (600 million
        pounds of finfish and 300 million pounds of shellfish) is caught recreattonally. About 70%
        of commercially produced seafood in the United States is sold fresh or frozen.  Canned
        seafood constitutes  approximately 25%, and smoked/eared products 5%, of the seafood
        consumed.  The United States exported  1.4 bflltoa pounds of edible domestic fishery
        products in  1989. The largest importer was Japan; Canada, the United Kingdom, France,
        and  South  Korea  also provided good markets.  The  seafood  harvest by industry  is
        fragmented, diversified, seasonal, complex, and difficult to manage. Stadia are nrrlfil to
        monitor changing consumption trends and patterns.  The processing, distribution, and
        merchandising  of finfish  and shellfish wOl  require more emphasis  to reduce cross-
        contamination.  Attention must be given to aquacnlture in order to produce high-quality,
        consistently  available species.  Attention must also be focused on the harvesting, handling*
        distribution, and preparation  of recreationally harvested fish to ensure consumer safety!
        MQre_emphasis--sbouid.-be~placed~on-educating thc-indusuy and tht censumer-about~ safe-
        handling practices that can reduce potential food-handling problems.



                                  INTRODUCTION

       As Americans become increasingly aware  of the relation between diet and good
health, the consumption  of fishery products will most  likely increase.  The  consumer
Tccognizes-that fish- and- shellfish ^re nutritious and  wholesome- foods.' Thfy  are
perceived  as an  excellent source  of high-quality protein,  containing  lipids  with  high
levels  of unsaturated fatty acids, and perhaps  contributing to the enhancement of
human health by reducing the  risk of cardiovascular disease.   Likewise, seafood is
characteristically tender,  easily digested, and a good source of many important minerals
and vitamins (NRC, 1989).

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                                             SEAFOOD SAFETY
                                                        of


doeinemed in subsequent chapters of tto report





         DEMOGRAPHICS OF THE SEAFOOD INDUSTRY

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 PRODUCTION, DISTRIBUTION, AND CONSUMPTION                               22

 diversity of the resource base (NMFS, 1990).  Over 4,000 processing and distribution
 plants handled the commercial products of the nation's  256,000 fishermen. Almost
 95,000 boats and vessels constituted the fleet (NMFS, 1990).
       Although commercial establishments are easily documented, the number of
 recreational fishermen and-their support base are more, difficult .to quantify. Increasing
 number* of anglers for fish from the nation's freshwater, estuarine, and marine waters
 are producing a growing share of the fresh and frozen seafood in today's diet  The
 number of recreational harvesters has been estimated to be in CTT« of 17 million
 individuals (NOAA, 1990).
       Fresh and frozen seafood constitute about 70% of the product consumed in the
 United States. Canned seafood, particularly tuna, constitutes almost 25% of domestic
 consumption, and cured/smoked products account for the  remaining 5% of per capita
 consumption.
                            FISHERY RESOURCES

      Commercial landings (edible and industrial) by US. fishermen at ports in all the
fishing states were a record &5 billion pounds (3.8 million metric tons) valued at $3.2
billion in 1989 (NMFS,  1990).  This was an increase  of L3 billion pounds (576^00
metric tons) in quantity, but a decrease of $2813 million in value, compared with 1988.
The total import value of edible fishery products was $5.5 bfllion in 1989, based on a
record quantity of 3.2 billion pounds.  Imports of nonedible (industrial) products set
a record in 1989, with products valued at $4.1 billion, an increase of $676.1 million
compared with 1988 (NMFS, 1990).
      The  trade  deficit in fishery products has not declined.  The dollar value of
imports  was higher in 1989 than in the  previous year (NMFS, 1990).  Canada is still
the largest importer to the United  States, sending in more than 700 million pounds of
fishery products in 1988.  Ecuador was ranked second and Mexico third.  Whereas
Canada  ships finfish products, shrimp is the primary commodity exported by Ecuador
and  Mexico.  Imports from Thailand  and  China are  both increasing due  to rising
shrimp production from  their expanding aquaculture systems.
      On a worldwide basis, aquaculture is becoming a major new factor in seafood
production.  The  cultivation of  high-value species, popular  in the U.S. market,  is a
major factor in import sourcing. China, for example, along with other Asian nations,
is replacing South and Central American countries as a major shrimp supplier to the
United States.   Aquaculture is expected to determine much 'of the future fisheries
growth, because wild stocks are  nearing full utilization  (NMFS,  1990; NOAA, 1990).
      The  total export value of edible and nonedible-fishery products  of domestic
origin was a record S4.7 billion in 1989, an increase of $14 billion compared with 1988.
The United States exported 1.4 billion pounds of edible  products valued at S2.3 billion.
compared with  1.1  billion  pounds at $2.2 billion exported in  1988.   Exports of
ni'ficJsrile producis were  valued at  S2.4 billion.  Japan continue* to be America's hoi

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26
   customer.
                                                SEAFOOD SAFETY


                                of seafood was iold to the Japanese
              *.
                                        (GNP)-
                 - »-—**
 edible n.eat per person m »» &*
 Ii2 poonds consumed P« «f » »
   odieti registered . tool of »
      Fre* and frozen fi"Ejll
     froien *eH&h •-"•v

                  5"* 5S-S)
  pound, compared «A l"
  ^   Although most
                                      eonsunptiOB of fte* and bora
                                      oe ot 03 pound from the 1988
                                     W* per apfta to 1989. FreA
                                     '*P« apita, «Wi earned
                                        ^ ,Sl "n» per eaph. me
                                        pound, (»»d «ig«). , U
         Service

  than 600      ..
  NMFS suggests that
  b, recreationa«sts.
              source,
                                          umed is torn comBereial
                                                the Nattonal Maroe

                                                    mewd Bore
                                               ^^^ ^

                                         »nd erustaceu, «. ha»e«ed
                                   « pound,  of domenic per capita
                                  commercial figure of over 13 pound, per
                                           .ILere.yo™! eatch «e jus.
                                             angler,  are not regulated
                                          * *• •-*« o
*e trend is toward more f""""?""1 V^omlercial processing indusoy appears
in Ac commercial sector » **"^*»2 ^"nience «• imported products and
headed toward consoM«,oa with .n«« -e£ «P«         ^^^.fon data,  as
       re.  Recreauonal Pa™'f?t'°", ","«„,, ^ Depanment of Commerce.
        b, both the Depanmen, of    »*•£ ^e   ^ ,„„ she,lflsn.  Mor,

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 PRODUCTION, DISTRIBUTION, AND CONSUMPTION                                27

                               AQUACULTURE

       Aquaculture is a rapidly growing mode of production in the seafood industry.
 Annual production of fanned fish and shellfish in the United States has grown 305%
 since 1980 (TFTQ 1988).   The  greatest production is of catfish (Sperber, 1989).
 Catfish production increased 31% from  1986 to-198V  According  to the Catfish
 Institute, farm-raised catfish increased from 5.7 million pounds in 1970 to 295 million
 pounds in 1988 and were expected to exceed 310 million pounds in  1989 (Sperber,
 1989).  Salmon production in the Pacific Northwest and Maine totaled 85 million
 pounds in 1987. In addition, other fish that are fanned include trout, redfish, sturgeon,
 hybrid striped  bass, carp, and tflapia, as well as shellfish and crustaceans  such  as
 oysters  and crawfish.   Crawfish  production acreage has  increased 145% to about
 160,000 acres. OveraO US. aquaculture production of fish and shellfish increased from
 203 million pounds in 1980  to some 750 million pounds in 1987.  It is estimated that
 by the year 2000, that figure will  reach 126 billion pounds.
      Large  amounts  of cultured fish  and shellfish are also  imported annually.
 Approximately one-half of the 500 million pounds of shrimp imported is cultured
 (Schnick, 1990); 143 million  pounds comes from China and Ecuador, neither of which
 regulates the use of chemotherapeutic agents in culture.  More than 40 million pounds
 of salmon is also imported  annually, often from  countries  similarly lacking tolerance
 levels for residues. Of special interest  are the use of chloramphenicol in shrimp
 cu-ture and ampicfllin in yellowtaO culture (Hawke et ai,  1987; Mauri, 1990).  The
 Food and Drug Administration (FDA) has not examined  imported seafood for drug
 residues, and  there is no information regarding levels that might be ingested (fr-hnirk.
 1990).            "
      Aquaculture also produces fish used to stock recreational fishing areas. This
 procedure is under the control of government agencies that follow FDA regulations,
 use only approved drugs, and abide by legal withdrawal times.
                          CONSUMPTION TRENDS

     • Today's consumer is changing rapidly.  Instead of single-income households, it
is increasingly more common to have both man and woman working.  The size of the
family is decreasing.  As many as one-fourth of all households are occupied by one
person.   This means  more  shoppers  and diners, most with little  time for home
preparation (Davivl989).*       »  •   •    •  •  •••    -.-...
      Most adult men and women now work outside the home.  In recent surveys, 7
out of 10 new home  buyers noted that they will need two incomes to pay their
respective mortgages.  Nevertheless, the growth in two-income couples has generally
created  an increase in disposable  income, but with little time to spend  it.  With as
many as 50% of new mothers working outside the home within the first year of
childhinh, ii is easy to see the revolutionary chance-, taking place among families. The

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                                                        SEAFOOD SAFETY

vorltine mother or single dweller does not have the time to prepare meals in the
SLdW. to nSwt Food Marketing Institute (FMI) survey* more than 30%
TSZtaTof women who work fuD-time did * much eoott* deuung, and food
shopping as their wives (Davis, 1989; EMI, 1988).                 mtutnommt
^Tfce population is aging.  Going into the next century,! fee fittest !"™°BP«*»
wfl] be thosV aged  45 to 54, along with those over age 85. By the year 2000. the
                     over age 65 wfll be the same throughout the country as the
                           An aging population n*ansdeoease
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  PRODUCTION, DISTRIBUTION, AND CONSUMPTION                               29

  Because of the potential of ever-increasing imports, the safety issue is becoming a
  matter of international concern.   Although agencies routinely sample and require
  country-of-origin labeling, the consumer is unaware of the complexity of attempting to
  truly safeguard these foodstuff.


                      ACTIVITIES IN OTHER COUNTRIES
       A number of countries have endeavored to ««»«*««* the value of their teafood
 products by enacting  programs to ensure product quality.  Canada, Denmark, and
 Norway have given high priority to marketing safe, quality seafood items.  Q>narb for
 example, inspects vessels, landing sites, and processing facilities  on an annual basis.
 Vessels  must meet the same exacting standards as processing facilities or risk losing
 their certification.  Canadian plant registration requires compliance with a posted list
 of standards.  At inspection,  plants  are rated by use of a Hazard Analysis Critical
 Control Point (HAACP) approach. Critical findings result in more frequent inspections
 or the possibility of noncerthlcation.
       In Europe, similar programs are in place.  Denmark inspects fishing vessels.
 Each participant must  meet certain sanitation requirements, as well as certification for
 activities such as on-board processing. Distribution centers receive regular inspections
 that monitor all products entering the  marketplace.  The  advent  of  the European
 Economic Community (EEC) has brought forth a host of new regulations, ensuring that
 member nations comply with the policies of their EEC pa

       Many other countries have seafood inspection programs, but they are often not
 dedicated programs like  those  in  Canada, Denmark, Norway, Iceland, and New
 Zealand.  Consequently, they do not pay the same rigorous attention to detail Indeed,
 most countries have programs centered on seafood as a food group, not as a distinct
 entity that requires special attention.
                  CONCLUSIONS AND RECOMMENDATIONS

       Based on commercial sources, Americans consumed almost 60% more seafood
in 1989  than they did 10  years earlier.  This  increase  in  consumption was not
accompanied by a concomitant increase in reported seafood-borne illnesses. The total
supply of fishery products to fulfill the domestic requirement for seafood was in excess
of"8.5  billion pounds in 1989,' with over 300 species "involved-in  the catch-statistics.
Production and consumption trends  suggest  that .-domestic  seafood demand  will
continue, with more emphasis on prepared convenience foods along with the traditional
demand for fresh and frozen selections.  Production will have to be supplemented with
more imported and cultured sources. Recreational harvesting, both in the purist sense
and as subsistence  fishing, continues to contribute a significant ponion to the annual
per c:ipit;i miuke.

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30                                                            SEAFOOD SAFETY

      The committee recommends the following:

      •  Consumer information studies must be conducted to monitor the rapidly
changing consumption trends in the United  States., Pattens  of consumer use and
preparation, as wefl as sources  of seafood  products used in the home,  must be
evaluated. By better understanding consumption pattens, fishery managers and food
regulators wOl be more able to influence dietary intake, and reduce potential exposure
to fish from contaminated water.
      •  Changes in consumption patterns necessitate more attention to informing
consumers on how to best handle highly perishable products such as seafood. As much
as 50% of all reported, acute fish and shellfish problems might be eliminated by more
careful handling and proper preparation in the home or in food service establishments.
With the advent of more prepared foods, every effort should be made to ensure the
safety of the product both in the manufacturing/distribution chain and for the end user.
      •  Hie retail and institutional handling of seafood products requires increased
attention to control cross-contamination. A number of seafood-related fllnesses can be
traced to poor sanitation practices by employees or to lack of proper handling via the
distribution system.  More efforts will be needed  to alert all users to the importance
of timeAemperature relationships, HACCP concepts, good manufacturing practices, and
new technology (e.g, live holding tanks).
      •  Aquaculture promises to produce a larger share of domestically consumed fish
and shellfish in the years ahead.  Cultured  plants and animals hold the  promise of
being high quality, and generally free of some of the contamination associated with wild
species.  Care, however, must be taken to avoid the untimely use  of antibiotics and
other chemicals in these closed or recirculated systems, which are often used to control
pathogens in semiclosed systems.
      • The  safety of  recreationally harvested  fish and shellfish requires increased
vigilance,  which means  increased focus on  the  origin, handling, and distribution of
recreational products. These harvesting efforts may now account for over 20% of all
fresh  and frozen seafood consumed in the United States.  However, this catch is not
well controlled, and users may handle, distribute, and prepare the product in an unsafe
manner.   Further,  much of this product may be harvested  from areas not suited for
consumption due to natural or induced contamination problems. Increased educational
activity  is required to protect the consumer with regard  to this resource.  Fishery
managers will have to pay greater attention to the implications of soon caught fish and
shellfish on  consumer health.


                                REFERENCES

CDC (Centers for Disease Control). 198la. Salmonella Surveillance,  Annual Summary,
       1978. HHS Publ. No. (CDC) 81-8219.  Public Health Service, U.S. Department
       of He:i!ih and Human Service*. Atlanta. Ga. 25  pp.

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                                          ^aHEALTH ADVISORY
      The following!

        get updates).Tor
                       nendataons are based on contaminant levels in fish and shellfish and are updated on a regular basis (see page 44 tar instructions on how to

                       Urtmtte potential adverse health Impacts, the NYS Department of Health (DOH) recommends:
        Eating no more than one meal (1/2 pound) per week of fish from any freshwater, the Hudson River estuary and the area including Upper Bay of New YbrkHaibor
         north ol the Vsmzano Narrows Bridge. Arthur Kin. Kill Van Kull. East River to the Thregs Neck Bridge and Harlem River, except as recommended below.
        Women ot cMldbeanng age. Mams and children under the age of 15 should not eat any fish species from the waters listed below.
        Following trimming and cooking advice.
        Observing the Mowing restrictions on eating fish from these waters and their tributaries to the first barrier mpassabte by fish.
 Water (County)
                              8p«det
                            Recommended    Water (County)
                               Species
                           Recommended
 Arthur Kill (Richmond) ••

 Barge Canal (Tonawanda Creek)
   Lockport to Niagara River
   (Erie; Niagara)
 BelrnortLake(SunoM  •
 Big Moose Late (Hertdmer)
 Buffalo River & Harbor (Erie)
 Canadice Lake (Ontario)
 Canandalgua Lake (Ontario:
   Yates)
 Cany Falls Reservoir
   (St Lawrence)
 Cayuga Creek (Niagara)
 Cranberry Lake (St Lawrence)
 Delaware Park Lake (Erie)
 East River (New York City)
                              See Hudson River
                              boutholCatshll)
                              Carp   -
                              Carp
                              Yellow perch
                              Carp
                              Lake or brown trout over 21"
                              Lake trout over 24*
 Eighteen Mile Creek (Niagara)
 Ferns Lake (Hamilton)
                             All species
                             Smallmouth bass
                             Carp
                             American eel
                             Atlantic needlefish, bluefish.
                             striped bass, white perch
                             All species
                             Yellow perch over 12*  •
                             Smaller yellow perch
Fourth Lake (HerBmen Hamilton) Lake trout
Francs Lake (Lewis)      _.    Yellow perch
Freeport Reservor(Nassau)      Carp
Gill Creek (Niagara) Mouth       All species
  to Hyde Park like Dam
Grant Park Pond (Nassau)       Carp
Grasse River (St. Lawrence)      All species
  Mouth to Massena Power Canal
 Halfmoon Lake (Lewis)
 Hall's Pond (Nassau)
 Harlem River (New York City)
                             %M||MM. •••Mat*
                             iBiiow percn
                             Carp, goldfish
                             American eel
                             Atlantic needlefish, bluefish.
                             striped bass, white perch
•Herrick Hollow Creek (Delaware) Brook trout
 Hoosie River (Rensselaer)
 Hudson River
  Sherman island Dam to Feeder
   Dam at South Glens Falls
 Hudson Falls to Troy Dam

  Troy Dam south to bridge
   atCatsMll
   Bridge at CatskiU south to
   and including the Upper
   Bay of NY Harbor, Arthur
   Kill and Kill Van KuB
                             Brown trout, rainbow trout

                             Carp
                            1 meal/month
                            1 meal / month
                            1 msal / month
                                  Eat none
                                  Eat none
                            1 meal/month

                            1 meal / month

                                  Eat none
                            1 meal /month
                            1 meal /month
                                  Eat none
                            1 meal/month

                                  Eat none
                                  Eat none
                            1 meal/month
                                  Eat none
                            1 meal/month
                            1 meal / month
                                  Eat none

                            1 meal/month
                                  Eat none

                            1 meal / month
                                  Eat none
                                  Eat none
                            1 meal / month

                            1 meal / month
                            1  meal / month

                            1  meal / month
                             AH species—                     Eat none
                             Catch and release only
                             All species except American shad    Eat none

                             American eel. bhiefish, striped  1 meal / month
                             bass, Atlantic needlefish, rainbow
                             smelt white perch, carp, goldfish.
                             white catfish, largemouth bass.
                             smallmouth bass, walleye
                             Blue crabi                 Eat no more than
                                                      6 crabs per week
                                                            Eat none
Indian Lake (Lewis)
Irondequort Bay (Monroe)
KeukaLake(Yates;Steuben)
KiDVanKull
WnderhMk Lake (Columbia)
Koppers Pond (Chemung)
Lake Capri (Suffolk)
Lake Champlain:
  Entire lake

  Bay within Cumberland
  Head to Crab Island
Lake Erie
Lake Ontario and Niagara
 River below the fans
 (See Niagara River tor
 additional advice.)
hepatopancreas (mustard.
liver or tomalley)
cooking liquid                      Discard
AB species                  1 meal/month
Carp                             Eat none
Lake trout over 25"           1 meal/month
 See HuOsonRmr (south otCatsKII)
American eel                1 meal/month
Carp                       1 meal / month
Carp                       1 meal/month

Lake trout over 25'.          1 meal / month
walleye over 19'
American eel. brown bullhead.  1 meal / month
yellow perch
See page 43
American eel. channel catfish.       Eat none
lake tout over 25*. Chinook
salmon, brown trout over 20*.
carp
                                             Lake Ontario (Continued)
   West of Point Breeze
   East of Point Breeze
  Lett's Pond (Nassau)
  Long Pond at Croghan (Lewis)
  Upper Massapequa Reservoir
  (Nassau)
  Massena Power Canal
    (St Lawrence)
  Meacham Lake (Franklin)

  Mohawk River from Oriskany
   Creek to West Canada Creek
   (Oneida, Heriomer)
  Moshier Reservoir (Herkimer)
  Nassau Lake (Rensselaer)
  •Neversink Res. (Sullivan)
  New York Harbor

  Niagara River above the falls
  Niagara River below the fans;
  also see Lake Ontano
  Onondaga Lake (Onondaga)
 Oswego River (Oswego)
  from power dam in Oswego
  to upper dam at Fulton
 Bidders Pond (Nassau)
 •Rondout Res. (Sullivan. Ulster)
 Round Pond (Hamilton)
 SL James Pond (Suffolk)
 St Lawrence River
   Entire river
 White sucker, rainbow trout   1 meal / month
 coho salmon over 25*. smaller
 lake trout and brown trout
 White perch                      Eat none
 White perch                 1 meal/month
 Cam. goldfish               1 meal/month
 Splake over 12"                  Eat none
 White perch                 1 meal/month
 Smallmouth bass

 Yellow perch over 12"
 Smaller yellow perch
 Carp
 Largemouth bass, tiger
 muskellunge
 Yellow perch
                          1 meal/month

                                Eat none
                          1 meal/month
                                Eat none
                          1 meal/month

                          1 meal/month

Smailmoutn bass            1 meal / month
See Hudson Aver (south ol Catshll) and Marine
 Waters (See next page)
Care                      1 meal/month
While perch                      Eat none
Smallmouth bass            1 meal / month
All species                       Eat none
Channel catfish              1 meal/month
Goldfish
Smallmouth bass over 16*
Yellow perch over 12*
All species

American eel,
channel catfish. Lake trout
over 25', Chinook salmon,
brown trout over 20". carp

White perch, white sucker
rainbow trout, coho salmon
over 25', smaller lake and
brown trout
   Bay at SL Lawrence-Franklin    All species
   County line
 Salmon River (Oswego)          Smallmouth bass
   Mouth to Salmon Reservoir.
   also follow Lake Ontano advisories
 Sauquolt Creek Between dam at ClayvHIe  Brown trout
   and Mohawk River (Oneida)
 Saw Mill River (Westchester)     American eel
 Schroon Lake (Warren. Essex)    Lake trout over 2T

 Sheldrake River (Westchester)    American eel.
                              QOluilSn
 Skaneateles Creek (Onondaga)    Brown trout over 10*
 Seneca River to dam at Skaneateles
 Smith Pond at Rocknlle          White perch
 Centre (Nassau)
 Smith Pond at Roosevelt Park    Amencan eel
 (Nassau)                     Carp, goldfish
 Spring Pond at Middle Island      Carp, goldfish
  (Suffolk)
StJlhvater Reservoir (Hertdmer)
                                Eat none
                          1 meal/month
                          1 meal/month
                          1 meal/month

                                Eat none
                                                                                                     Splake.smallmoirth bass.
                                                                                                     yellow perch over 9'
                                                                                                     Yellow perch
                                                                                                     White sucker
Sunday Lake (Herkimer)
Three Mile Creek (Oneida)
Valatie Kin (Rensselaer) between  All species
  County Rte. 18 and Nassau Lake
Whitney Park Pond (Nassau)     Carp, goldfish
• Changes from the 1996-99 Fishing Regulations Guide
                          1 meal / month

                               Eat none

                          1 meal/month


                               Eat none

                          1 meal / month
                          1 meal/month

                               Eat none
                          1 meal/month
                          1 meal/month

                          1 meal/month

                               Eat none
                          1 meal /month
                               Eat none

                         1 meal /month

                          1 meal/month
                         1 meal/month
                               Eat none

                         1 meal /month
                                                                                                                                             I

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  ADDITIONAL ADVICE
  Advisories for Lake Erie—Due to PCB
  Contamination, women of childbeanng
  age, infants and children under the age
  of 15 are advised to eat no more than
  one meal per week of Chinook salmon
  less than 19 inches, burbot, freshwater
  drum, lake whrtefish, rock bass and yel-
  low perch,  and EAT NO MORE THAN
  ONE MEAL PER MONTH of all other fish
  from Lake Erie. Other people should eat
  no more than one meal per week of any
  Lake Erie species.
  Marine Blueflsh and Eels—The general
  advisory (eat no more than one meal per
  week) applies to bluefish and American
  eel. but not to most other fish from Long
  Island Sound. Peconic/Gardiners Bays.
  Block  Island Sound, the Lower Bay of
  New  York  Harbor, Jamaica  Bay  and
  other Long Island South Shore waters.
  Marine Striped Bass—Women of child-
  bearing age and children under the age
  of 15 should eat no  striped bass taken
 from the Upper and Lower Bays of New
 York Harbor or Long Island Sound west
 of Wading River. Other  people should
 eat no more than one meal per month of
 striped  bass  from  these  waters.
 Everyone should eat no more than one
 meal per week  of striped bass taken
 from Jamaica Bay. Eastern Long Island
 Sound.   Block    Island    Sound,
 Peconic/Gardiners Bays or Long Island
 South Shore waters.
 Blue Crab and  Lobsters—The hepat-
 opeas  (liver,  mustard, or  tomalley) of
 crabs and lobsters should not be eaten
 because it has high contaminant levels.
 Hudson River Shad—The advisory for
 women of childbearing age, infants and
 children under the age  of 15  is  EAT
 NONE for all fish from the lower Hudson
 River because of PCB contamination.
 However,  shad have lower PCB levels
 than other species.  A few  meals of
 Hudson River shad meat and roe, espe-
 cially using cooking and trimming meth-
 ods that minimize PCB content would
 not  pose  an unacceptable risk  for
 women of childbearing age  and chil-
 dren, assuming this is their only signifi-
 cant exposure to PCBs.
 Deformed or Abnormal  Pish—The
 health implications of eating these fish
 are unknown. Any grossly diseased fish
 should probably be discarded.
 Health  Benefits—When  properly pre-
pared, fish provide a diet high in protein
and  low in saturated fats.  Almost any
kind of fish may have real health benefits
  if it replaces a high-fat source of protein
  in the diet.
  Chemicals In Sportflsh or Game
   Summary
    The NYS Department of Environmen-
  tal Conservation (DEC) routinely moni-
  tors  contaminant levels  in fish and
  wildlife. The NYS Department of Health
  (DOH) issues advisories on eating sport-
  fish and game taken in New  York State
  because some  of these foods contain
  potentially harmful  levels  of chemical
  contaminants. The hearth advisories are:
  (1) general advice  on  sportfish taken
  from waters in New York State; (2) advice
  on sportfish from specific waterbodies;
  and (3) advice on eating game. The advi-
  sories are updated annually.
  Contaminants In Fish and Game
    Long-lasting contaminants, such  as
  PCBs, DDT and  cadmium, build up in
  your body over time. It may take months
  or years of regularly eating contaminat-
  ed fish to build up amounts which are a
  health concern. Health problems which
 may result from the contaminants found
 in  fish range from  small changes in
 health that are hard to  detect to birth
 defects and cancer. Mothers who eat
 highly contaminated  fish  and wildlife
 before becoming  pregnant may have
 children who are slower to develop and
 learn. The meal advice in this advisory is
 also intended  to  protect children from
 these  potential  developmental  prob-
 lems. Women beyond their childbeanng
 age and men face fewer  health risks
 from contaminants than children do.
  Some contaminants cause cancer in
 animals. Your risk of cancer from eating
 contaminated fish and wildlife cannot be
 predicted with certainty. Cancer current-
 ly affects about one in every three peo-
 ple, primarily due to smoking, diet and
 hereditary risk factors. Exposure to con-
 taminants in the fish and wildlife you eat
 may not Increase your cancer risk at all.
 If you follow this advisory over your life-
 time, you will  minimize your exposure
 and reduce whatever cancer risk is asso-
 ciated with these contaminants.
  The  federal  government establishes
 standards for chemical residues in food.
 When  establishing these standards for
fish, the  federal government assumes
that people eat about one-half pound of
fish each month. The contaminant levels
are  measured in  a skin-on fillet which
has not been trimmed; this sample is
used in determining whether or not the
fish exceeds standards. Fish cannot be
legally sold if they contain a contaminant
at a level greater than its standard. When
  sportfish from a waterbody contain cont-
  aminants at levels greater than federal
  standards,  the DOH issues a specific
  advisory.
  General Advisory
    The general health advisory for sport-
  fish is that  you eat no more than one
  meal (one-half pound) per week of fish
  from the state's freshwaters and marine
  waters at the mouth of the Hudson River.
  These waters  include the  New York
  waters of the Hudson River including
  Upper  Bay  north  of  the  Verrazano
  Narrows Bridge, Arthur Kill, Kill Van Kull.
  Harlem River, and the East River to the
  Throgs Neck Bridge. This general advi-
  sory is to protect against eating large
  amounts of fish that have not been test-
  ed or may contain unidentified contami-
  nants.  The general advisory does not
  apply to most fish taken from marine
  waters.
  Specific  Advisories for Freshwaters,
  the Hudson River and Upper Bay of
  New York Harbor
    Over  60 waterbodies in New York
  State have fish with contaminant levels
  greater than federal standards. DOH rec-
  ommendations suggest either limiting or
 avoiding  eating a  specific kind of fish
 from particular  waterbodies. In some
 cases, enough information is available to
 Issue advisories based on the length of
 the fish.  Older  (larger)  fish  are often
 more contaminated than younger (small-
 er) fish.
   Health advice is also given for Infants,
 children under the age of fifteen and
 women of childbearing  age. DOH rec-
 ommends that they not eat any fish
 species from the specific  waterbodies
 listed in the advisory. The reason for this
 specific advice is that chemicals  may
 have a greater effect  on developing
 organs in young children or In the fetus.
 They also build up in women's bodies
 and are often passed on  in mothers'
 milk.
  Waters which have specific advisories
 have at least one species of fish with an
 elevated  contaminant  level,  which
 means that a contamination source is in
 or near the water.
  When eating fish from waters where
 cadmium or mercury are listed as prima-
 ry contaminants, it is important to space
 out fish meals according to the specific
 advisory for that waterbody. For exam-
 ple, if you eat a meal of yellow perch
from Moshier  Reservoir, you should not
eat any more fish with the same mercury
advisory for  the rest  of that month.

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   However, for other contaminants, the
 total number of meals that you eat dur-
 ing the year is important and many of
 those meals can be eaten during a few
 months of the year. If most of the fish you
 eat are from the "One Meal a Week" cat-
 egory, you should not exceed 52 meals
 per year. Likewise, if most of the fish you
 eat are in the 'One Meal a Month" cate-
 gory, you should not exceed 12 meals
 per year. Remember, eating one meal of
 fish from the "One Meal a Month' group
 Is comparable to eating four meals from
 the 'One Meal a Week* group.
 Other Advisories
   DOH has  also issued special advi-
 sories for snapping  turtles and water-
 fowl. Cooking methods are recommend-
 ed that minimize the amount of contami-
 nants which would be eaten. Advisories
 for snapping turtles and waterfowl  are
 provided in  the  Hunting and Trapping
 Guide.

 Rtduelng Exposure To Chemical
 Contaminants From Fish
   Fish are an Important source  of pro-
 tein  and are low  In  saturated  fat.
 Naturally occurring fish oils have been
 reported to  lower plasma cholesterol
 and triglycerides thereby decreasing the
 risk   of  coronary   heart   disease.
 Increasing fish consumption is useful In
 reducing  dietary fat  and controlling
 weight. By eating a diet which includes
 food from a variety of protein sources an
 individual is  more likely  to have a diet
 which is adequate in all nutrients.
   Although eating fish has some health
 benefits, fish with high contaminant lev-
 els should be avoided. When deciding
 whether or not to eat fish which may be
 contaminated, the benefits  of  eating
 those fish can be weighed against  the
 risks. For young women, eating contam-
 inated fish is a health concern not only
 for herself but also to any unborn or
 nursing child since the chemicals may
 reach the fetus and can be passed on In
 breastmilk. For an older person with
 heart disease, the risks, especially of
 long term health effects, may  not be as
 great a concern when compared to the
 benefits of reducing the risks of heart
 disease.
   Everyone can benefit from eating fish
they catch and can minimize their conta-
 minant intake by following these general
 recommendations:
   • Choose  uncontaminated species
     from waterbodies which are not list-
     ed in the DOH advisories.
   • Use a  method of filleting the fish
     which'  will reduce the skin, fatty
     material and dark meat. These
     parts of the fish contain many of the
     contaminants.
   • Choose smaller  fish, consistent
     with  DEC  regulations, since they
     may have lower contaminant levels.
     Older (larger) fish within  a species
     may    be   more  contaminated
     because they have had more time
     to accumulate contaminants In their
     bodies.
   • For shellfish, such as crab and lob-
     ster, do not eat the soft green sub-
     stance  found In the body  section
     (mustard,   tomalley,    liver   or
     hepatopancreas).  This part of the
     shellfish has been found to  contain
     high  levels of  chemical contami-
     nants,  including PCBs and heavy
     metals.
   • Cooking methods  such as broiling,
     poaching, boiling  and  baking,
     which allow fats to drain out, are
     preferable. Pan frying is not recom-
     mended. The cooking liquids offish
     from  contaminated waters  should
     be avoided since these liquids may
     retain contaminants.
   • Anglers who want to enjoy  the fun
     of fishing but who wish to eliminate
     the potential  risks .associated with
     eating   contaminated   sportfish
     should   consider  "catch  and
     release" fishing. Refer to  this fish-
     ing guide for suggestions on catch
     and release fishing techniques.
Cleaning and Cooking Your Fish
   Many contaminants are found at high-
er levels in the fat of fish. You can reduce
the amount  of these contaminants in a
fish meal by property trimming, skinning
 and cooking your catch. Remove the
 skin and trim all the fab the belly flap,
 the line along the sides, the fat along the
 back and under the skin. (See diagram
 below.)
   Cooking or smoking fish does not
 destroy contaminants in fish but heat
 from cooking  melts some of the fat In
 fish and allows some of the contaminat-
 ed fat to drip away. Broil, grill or bake the
 trimmed, skinned fish on a rack so that
 the fat drips' away. Do not use drippings
 to prepare sauces or gravies. If you deep
 fry the fish, do not reuse the cooking oil.
   These precautions will not reduce the
 amount of mercury or other  metals.
 Mercury is distributed throughout a fish's
 muscle tissue  (the part you eat),  rather
 than in the fat and skin. Therefore, the
 only way to reduce mercury intake is to
 reduce the  amount of contaminated fish
 you eat
   To receive an updated, complete ver-
 sion of the  advisories, or for more DOH
 information on health effects from expo-
 sure to chemical contaminants, contact
   Environmental Health Information
   1-800-458-1158
   (toll-free number)
   Leave your  name, number and brief
 message. Your call will be returned  as
 soon as possible.
   The complete, updated advisories
 are available at
 http://www.health.state.ny.us
 or can  be requested by  E-mail:
 BTSA@health.state.ny.us.
   For more DEC Information on contam-
 inant levels and eating  sportfish, con-
tact:
   Bureau of Habitat
   50 Wolf Road, Albany. NY 12233-4756
   (518)457-6178.
             Remove all skin
               Cut sway all fit
               along the back
    Cut away a V-shaped wedge
    to remove the dark fatty tissue
    along the entire length of the fillet
                                                        off the belly tat
                                                       44

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 oEPA
                        United States
                        Environmental Protection
                        Agency
                                     Office of Water
                                     4305
EPA-823-F-99-005
July 1999
Fact Sheet
 Update:  National Listing of Fish  and Wildlife Advisories

 Summary
 The 1998 update for the database National Listing of rah and Wildlife Advisories (NLFWA) is now available from the U.S. Environ-
 mental Protection Agency (EM). This database includes all available information describing state-, tribal', and federally-issued fish
 consumption advisories in the United States forthe SO states, the District of Columbia, four United States territories and one tribal
 organization. It also includes information from 1997 for 12 Canadian provinces and territories. The database contains advisory
 information provided to EPA by the states as of December 1998. The number of advisones in the United States rose by 205 m 1998
 to a total of 2.506. a 996 increase over 1997. The number of waterbodies under advisory represents 15.8% of the Nation's total lake
 acres and 6.8% of the Nation's total river miles. In addition. 10096 of the Great Lakes waters and their connecting waters and 58.996
 of the Nation's coastal waters an also under advisory. The total number of advisories in the United States increased for three major
 contaminants-mercury. KBs, and DDT—out declined for dioxirs and thtardane.

 Beginning in 1996. EW contacted health officials in Canada in an effort to identify fish consumption advisones m effect. The number
 of Canadian advisories in effect as of December 1997 was 2.625. No updates to information on Canadian advisories were made in
 1998. All of the 1997 Canadian fish advisories resulted from contamination from one or more of the following five pollutants:
 mercury, PCBs. Oioxms/furans. toxaphene. and mirex. Provincewide advisones for mercury were in effect for New Brunswick and Nova
 Scotia n 1997.
          The NLFWA is now available for use on the Internet at: httptfwww.epa.gov/ost/rish
Background
The states and the four U.S. territories and Native American
tribes (hereafter referred to as states) have primary respon-
sibility for protecting residents from the health risks of
consuming contaminated noncommertially caught fish
and wildlife. They do this by issuing consumption adviso-
ries for the general population, including recreational and
subsistence fishers, as well as for sensitive subpopulations
(such as pregnant women, nursing mothers, and children).
These advisories inform the public that high concentrations
of chemical contaminants (e.g., mercury and dioxins) have
been found in local fish and wildlife. The advisones include
recommendations to limit or avoid consumption of certain
fish and wildlife species from specific waterbodies or, in
some cases, from specific waterbody types (e.g.. all lakes).
Similarly, in Canada, the provinces and territories have
primary responsibility for issuing fish consumption adviso-
ries for their residents.

States typically issue five major types of advisories and
bans to protect both the general population and specific
subpopulations.
                                 • When levels of chemical contamination pose a health risk
                                   to the general public, states may issue a no-consumption
                                   advisory for the general population (NCGP).

                                 • When contaminant levels pose a health risk to sensitive
                                   subpopulations, states may issue a no-consumption
                                   advisory for the sensitive subpopulation (NCSP).
                                 • In waterbodies where chemical contamination is less
                                   severe, states may issue an advisory recommending that
                                   either the general population (RGP) or a sensitive
                                   subpopulation (RSP) restrict their consumption of the
                                   specific species for which the advisory is issued.
                                 • The fifth type of state-issued advisory is the commercial
                                   fishing ban (CFB), which prohibits the commercial
                                   harvest and sale offish, shellfish, and/or wildlife species
                                   from a designated waterbody and. by inference, the
                                   consumption of all species identified in the fishing ban
                                   from that waterbody.
                                 As shown in Table 1, advisories of all types increased in
                                 number from 1993 to 1998.
Tank* "HII SrfUlminrin t-i'.iirrl Iroml993 to!998 by Type ; ^•-.\..;/-->/vfe;^i?=V:.;— .i-Vik^^ :.

No Consumption - General Population
1 No Consumption - Sensitive Subpopulation
Restricted Consumption - General Population
Restricted Consumption - Sensitive Subpopulation
Commercial Fishing Ban
1993
503
555
993
689
30
1994
462
720
1.182
900
30
1995
463
778
1,372
1,042
55
1996
563
1.022
1,763
1.370
50
1997
545
1.119
1.843
1.450
52
1998
532
1.211
2.062
1.595
50

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 Advisories in Effect
 The database includes information on

   • Species and size range of fish and/or wildlife
   • Chemical contaminants identified in the advisory
   • Geographic location of each advisory (including
      landmarks, river miles, or latitude and longitude
      coordinates of the affected waterbody)
   • Lake acreage or river miles under advisory
   • Population for whom the advisory was issued.

The  1994.1995.1996.1997. and the new 1998 versions
of the NLFWA database can generate national, regional,
and state maps that illustrate any combination of these
advisory parameters. In addition, the 1996 through 1998
versions of the database can provide information on the
percentage of watertxxlies in each state that is currently
under an advisory and the percentage of waters assessed.
A new feature of the 1998 database provides users access
 to fish tissue residue data for those waterbodies under
 advisory in 16 states. The name of each state contact, a
 phone number, FAX number, and e-mail address are also
 provided so that users can obtain additional information
 concerning specific advisories. Comparable advisory
 information (excluding tissue residue data) and contact
 information for 1997 are provided for each Canadian
 province or territory.


 Advisory Trends
 The number of waterbodies in the United States under
 advisory reported in 1998 (2,506) represents a 9% increase
 from the number reported in 1997 (2,299 advisories) and a
 98% increase from the number of advisories  issued since
 1993 (1,266 advisories). Figure 1 shows the number of
 advisories currently in effect for each state and the number
of new advisories issued since 1997. The increase in
advisories issued by the states generally reflects an increase
in the number of assessments of the levels of chemical
contaminants in fish and wildlife tissues. These additional
                    Total Number of Fish Advisories in Effect in Each State in 1998
                                           (change from 1997)
      D
    GUO(O)
                                    0(0)

-------
 assessments were conducted as a result of the increased
 awareness of health risks associated with the consumption
 of chemically contaminated fish and wildlife. Some of the
 increase in advisory numbers, however, may be due to the
 increasing use of EPA hsk assessment procedures in setting
 advisories rather than Food and Drug Administration (FDA)
 action levels developed for commercial fisheries.

 Bioaccumulative Pollutants
 Although advisories in the United States have been issued
 for a total of 46 chemical contaminants, most advisories
 issued have involved five primary contaminants. These
 chemical contaminants are biologically accumulated in the
 tissues of aquatic organisms at concentrations many times
 higher than concentrations in the water. In addition, these
 chemical contaminants persist for relatively long periods in
 sediments where they can be accumulated by bottom-
 dwelling animals and passed up the food chain to fish.
 Concentrations of these contaminants in the tissues of
 aquatic organisms may be increased at each successive
 level of the food chain. As a result top predators in a food
 chain, such as trout salmon, or walleye, may have concen-
 trations of these chemicals in their tissues that can be a
 million times higher than the concentrations in the water.
 Mercury, PCBs,  chlordane,  dioxins, and DDT (and its
 degradation products, DDE and ODD) were at least partly
 responsible for 99% of all fish consumption advisories in
 effect in 1998. (See Figure  2.)

 Mercury
Advisories for mercury increased 8% from 1997 to 1998
 (1.782 to 1,931) and increased 115% from 1993 to 1998
 (899 to 1,931). The number of states that have issued
mercury advisories also has risen steadily from 27 in 1993
to 40 in 1997 and remained at 40 in 1998. The rise in the
number of mercury advisories in 1998 can  be attributed
primarily to issuance of new mercury advisories in 11
states. The majority (80%)  of these new advisories,
 Figure 2
           Trends in Number of Advisories
             Issued for Various Pollutants
                                         • 1998
                                         • 1997
                                         • 1996
                                         .- 1995
                                           1994
                                         01993
                     Number of Atbaarm
 however, were issued in three states: Minnesota (61).
 Georgia (57), and Indiana (17).

 It should also be noted that 10 states (Connecticut,
 Indiana, Maine, Massachusetts, Michigan, New Hampshire,
 New Jersey, North Carolina, Ohio, and Vermont) have
 issued statewide advisories for mercury in freshwater lakes
 and/or rivers. Another five states (Alabama. Florida,
 Louisiana, Mississippi, and Texas) have statewide advisories
 for mercury in their coastal waters. To date, 90% of the
 1,931 mercury advisories  in  effect have been issued by the
 following 11 states: Minnesota (821), Wisconsin (402),
 Indiana (126), Florida (97), Georgia (80), Massachusetts
 (58), Michigan (53), New Jersey (30), New Mexico (26),
 South Carolina (24), and Montana (22).

 PCBs
 Advisories for PCBs increased 15% from 1997 to 1998
 (from 588 to 679) and increased 112% from 1993 to 1998
 (319 to 679). The number of states that have issued PCB
 advisories increased only slightly from 31 to 35  from 1993
 to 1994, declined to 34 states in 1995 and 1996, and
 increased to 35 states in 1997 and up to 36 states in 1998
 with the addition of Hawaii.  The majority (77%) of the new
 PCB advisories in 1998 were issued by four states: Michigan
 (48), Illinois (11), Indiana  (5), and Minnesota (5). To date,
 79% of the of the 679 PCB advisories in effect have been
 issued by 10 states: Indiana (125), Michigan (104),
 Minnesota (83), Wisconsin (54). New York (47), Ohio (37),
 Georgia (25), Nebraska  (22), Pennsylvania (22). and
 Massachusetts (20). Three states (Indiana. New York, and
 District of Columbia) have issued statewide freshwater
 (river and/or lake) advisories  for PCBs. Six other states
 (New Jersey, Connecticut,  New York, Rhode Island, New
 Hampshire, and Massachusetts) have issued PCB advisories
 for all of their coastal marine waters.

 Other Pollutants
 The total number of advisories for DDT (and its degrada-
 tion products, DDE and  DDD) increased from 33 in 1997
 to 34 in 1998. The total number of advisories for dioxins
 rose from 54 in 1993 to 63 in 1994, held steady at 63 in
 1995, declined to 60 in  1996, increased to 65 in 1997, and
 fell to 59 in 1998, a 9%  decrease from the previous year.
 Dioxins are one of several chemical contaminants for which
 advisories have been rescinded by marry states, in pan
 because many pulp and paper mills have changed their
 processes. In 1998, three states (Arkansas, Michigan, and
 Virginia), rescinded a total  of four dioxin advisories. The
 number of chlordane advisories also decreased, by 11%.
from 117 in 1997 to 104 in 1998.

Wildlife Advisories
 In addition to advisories  for fish and shellfish, the database
also contains several wildlife advisories. Four states have
issued consumption advisories for turtles:  Arizona (3),
Massachusetts (1), Minnesota (8), and New York (statewide
advisory). One state (Massachusetts) has an advisory for

-------
  frogs, New York has a statewide advisory for waterfowl
 (induding mergansers), Arkansas has an advisory for
 woodducks, and Utah has an advisory for American coot
 and ducks. Maine issued a statewide advisory for moose
 liver and kidneys due to cadmium levels.
1 Table 2. Summary of Statewide Advisories by Walerbody Type
State
Alabama
Connecticut
Dist of Columbia
Florida
Indiana
Louisiana
Maine
Massachusetts
Michigan
Mississippi
New Hampshire
New Jersey
New York
North Carolina
Ohio
Rhode Island
Texas
Vermont
Lake

Mercury
PCBs



Mercury
Mercury
Mercury

Mercury
Mercury
PCBs
Chlordane
Mirex
DDT
Mercury
Mercury


Mercury
River

Mercury
PCBs

Mercury
PCBs

Mercury
Mercury


Mercury
Mercury
PCBs
Chlordane
Mirex
DDT
Mercury
Mercury


Mercury
Coastal Waters
Mercury
PCBs

Mercury

Mercury
Dioxins
PCBs
organics

Mercury
PCBs
PCBs
Cadmium
Dioxins
PCBs
Cadmium
Dioxins


PCBs
Mercury

 1998 Advisory Listing
 The 1998 database lists 2,506 advisories in 47 states,
 the District of Columbia, and the U.S. Territory of American
 Samoa. Some of these advisories represent statewide
 advisories for certain types of waterbodies (e.g., lakes,
 rivers, and/or coastal waters). An advisory may represent
 one waterbody or one type of waterbody within a state's
jurisdiction. Statewide advisories are counted as one
 advisory. The database counts one advisory for each
 waterbody name or type of waterbody regardless of the
 number of fish or wildlife species that are affected or the
 number of chemical contaminants detected at concentra-
 tions of human health concern.  Eighteen states (Alabama,
 Connecticut District of Columbia, Florida, Indiana,
 Louisiana, Maine, Massachusetts. Michigan, Mississippi,
 New Hampshire, New Jersey. New York, North Carolina,
 Ohio, Rhode Island, Texas, and Vermont) currently have
 statewide advisories in effect (see Table 2). Missouri
 rescinded its statewide advisories for lakes and rivers in
 1998, and Mississippi added a statewide coastal advisory
 for mercury. A statewide advisory is issued to warn the
Table 3. Fish Advisories Issued for the Great Lakes
Great Lakes
Lake Superior
Lake Michigan
Lake Huron
Lake Erie
Lake Ontario
PCBs
•
•
•
•
•
Dioxins


•

•
Mercury
•
•

-

Chlordane
•
•
•


                                                              public of the potential for widespread contamination of
                                                              certain species of fish in certain types of watertxxlies (e.g.,
                                                              lakes, rivers and streams,  or coastal waters) or certain
                                                              species of wildlife (e.g.. moose or waterfowl). In such a
                                                              case, the state may have found a level of contamination
                                                              of a specific pollutant in a particular fish or wildlife species
                                                              over a relatively wide geographic area that warrants
                                                              advising the public of the situation.

                                                              The statewide advisories and 2,506 specifically named
                                                              waterbodies represent approximately 15.8% of the
                                                              Nation's total lake acreage and 6.8% of the Nation's total
                                                              river miles. In addition. 100% of the Great Lakes waters
                                                              and their connecting waters are also under advisory (see
                                                              Table 3). The Great Lakes waters are considered separately
                                                              from other lakes, and their connecting waters are consid-
                                                              ered separately from other river miles. The percentages of
                                                              lake acres and river miles in each state that are currently
                                                              under a fish advisory are shown in Figures 3 and 4, respec-
                                                              tively.

                                                              In addition to the Great Lakes, many other Great Waters
                                                              of the United States are currently under fish consumption
                                                              advisories for various pollutants. The Great Waters include
                                                              not only the Great  Lakes but also Lake Champlain (which
                                                              is under advisories for PCBs and mercury), the Chesapeake
                                                              Bay, 28 National Estuary Program (NEP) Sites, and 23
                                                              Figure 3
               Percentage of Lake Acres
               Currently Under Advisory
  Dcu u
Eleven states have 100% of their lake acres under fish advisories (these
include some states with statewide advisories), another 8 states nave
10% to 50% of their lake acres under advisories. 21 states have <10%
of their lake acres under advisories, and 15 states have no lake acres
under advisories.

-------
                Percentage of River Miles
                Currently Under Advisory
  Ocuta
Cteveg states have 100% of their river miles under fish
advisories (these include states with statewide advisories). 30 states
have <10% of their river miles under advisories, and 13 states have no
river miles under advisories.
 National Estuarine Research Reserve System (NERRS) Sites
 (see Table 4). Although the Chesapeake Bay itself is not
 under any advisories, the Potomac, James, Black, and
 Anacostia rivers, which connect to the Chesapeake, are all
 under advisories. All of these rivers, with the exception of
 the James River (which is under advisory for kepone), are
 under chlordane advisories. The Anacostia River is also
 listed for PCBs. and the Potomac River is listed for PCBs and
 dioxins in addition to chlordane. Baltimore Harbor, which
 also connects to the Chesapeake, is under advisory for
 chlordane contamination in fish tissue.

 A number of the major estuaries listed in the NEP and/or
 designated as NERRS sites are under fish and/or shellfish
 advisories for a range of chemical contaminants (see Table
 4). Sixty-three percent of the total number of NEP.  NERRS,
 and combined sites are under fish consumption advisories.
 There are 18 sites that have no current fish consumption
advisories.

Several states have issued fish advisories for all of their
coastal waters. Using coastal mileages calculated by the
1 Table 4. -Fish Corrumiption Advisories Issued for NEP and NERRS Sites
Waurbody
CascoBay. ME*
Wells. ME'
Great Bay. NH '
Great Bay, Little Bay,
and Hampton Harbor. NH *
Massachusetts Bay •
Buzzards Bay, MA '
WaquoitBay. MA'
Hamgamen.ru"
long Island Sound. NY/CT'
Peconic Bay. NY *
Hudson fever. NY '
New York/New Jersey Harbor '
Bamegat Bay. W •
iacoues fommaii-GfW Bay
and Muta River, NJ'
Delaware Estuary. DE/NJ/FA ' '
Albernarte-Psmhco Sounds. NC *
Ashepoo-Ccn*»»we-
Edisto Basin, SC'
Indian River Lagoon, Fl '
Charlotte Harbor. Fl '
Rookery Bay, n '
Sarasota Bay FL '
Tampa Bay FL '
Ipalachicola Bay. Fl '
Mobile Bay. Ai *
CascoBay, MF
liflHS, Arm.
Great Bay. NH'
Weeks Bay. A)'
Baratama-Tenebonne
Estuarine Complex, LA *
Gahcston Bay TX '
Corpus Christ) Bay. TX'
Pugei Sound. WA '
Columbia River, OR/WA *
San francoco Bay, CA '
PCBs


•























•




•
•
•
Dioms
•
•



























•

•
•
•
Mercury



























•
•
•
•
•

•
Cadmium


































Chlordane










P
•
•
•
•


















•
Others




• '
•'
• '
























•>
•'
•*
                                                                                     10rganic compounds.
                                                                                     'For waterfowl.
                                                                                     •Specific emoaynBiru of Puoet Sound
                                                                                      are lilted for the following poDuuno.
                                                                                      creosote, pentaehloropnenol, volatile
                                                                                      organic compounds (VOCs), tatncnton>
                                                                                      ethylene. arsenic, m«*s (urapeafied).
                                                                                      vinyl chloride, potyaromauc hydnxarDore
                                                                                      ff*Hs), polynudew aromsties, and
                                                                                      pestioctes (umpecified)
                                                                                     •DDT.
                                                                                     'DDtdieldrin. other umpeafied

                                                                                     'NH'itH.
                                                                                     'NERRS ste.

-------
 National Oceanic and Atmospheric Administration, an
 estimated 58.9% of the coastline of the contiguous 48
 states currently is under advisory. This includes 61.5% of
 the Atlantic Coast and 100% of the Gulf Coast No Pacific
 Coast state has issued a statewide advisory for any of its
 coastal waters although several local areas along the Pacific
 Coast are under advisory. The Atlantic coastal advisories
 have been issued for a wide variety of chemical contami-
 nants including mercury, PCBs, diorins, and cadmium,
 while aU of the Gulf Coast advisories have been issued for
 mercury.

 Summary of Canadian Advisories
 No new information was collected regarding fish advisories
 in Canada for 1998. Beginning in 1996, EPA contacted
 health and environmental officiate in the 12 Canadian
 provinces and territories to obtain narrative and geographic
 information system (G1S) information on advisories
 throughout Canada. Figure 5 shows the number of
 waterbodies  under advisory in 1997 for each of the
 Canadian provinces. The number of Canadian advisories in
 effect in 1997 was 2,625. Provincewide advisories for
 mercury were also in effect in 1997 for Nova Scotia and
 New Brunswick. With respect to chemical contaminants,
 advisories in Canada have been issued for a total of five
 bioaccumutative chemical contaminants including mercury
 (2,572), PCBs (59), dioxins/furans (68), toxaphene (16),
 and mirex (9). More than 97% of all Canadian advisories
 have been issued for mercury.
 Figure 5
  Total Number of Fish Advisories in Effect in Canada

•Prowncewrde advisories in effect in 1997 far Nan Scotia
(all riven and lakes) Mid New Bruwrick (all lakes)
 Database Use and Access
 The NLFWA database was developed by ERA to help
 federal, state, and local government agencies and Native
 American tribes assess the potential for human health risks
 associated with consumption of chemical contaminants in
 noncommercially caught fish and wildlife. The data
 contained in this database may also be used by the general
 public to make informed decisions about the waterbodies
 in which they choose to fish or harvest wildlife; the
 frequency with which they fish these waterbodres, the
 species, size, and number of fish they collect: and the
 frequency with which they consume fish from specific
 waterbodies.

 EPA will make this 1998 update of the NLFWA database
 available on the Internet at:

   http://www.epa.gov/ost/fish

 Further information on specific advisories within a particu-
 lar state is available from the appropriate state agency
 contact listed in the database. This is particularly important
 for advisories recommending that consumers restrict their
 consumption of fish from certain waterbodies. State health
 departments provide more specific information for
 restricted consumption advisories (RGP and RSP) on the
 appropriate meal size and meal frequency (number of
 meals per week or month) that is considered safe to
consume for a specific consumer group (e.g., the general
 public versus pregnant women, nursing mothers, and
young children). For further information on Canadian
advisories, contact the appropriate provincial contact given
in the database.

For more information concerning the National Fish and
Wildlife Contamination Program, contact

   U.S. Environmental Protection Agency
   Office of Science and Technology
   401 M Street SW. Maildrop 4305
   Washington, DC 20460
   US. EPA contact Jeffrey BigJer
   Phone 202 260-1305 FAX 202 260-9830
   e-mail: Bigler.teff9epa.gov

-------
  What levels of exposure have resulted in harmful health effects?

                         Figures 1.1,1.2, and 1.3 on the following pages show the relationship
                         between exposure to PCBs and known health effects. Other PCBs may
                         have different toxic properties.  In the first set of graphs, labeled "Health
                         effects from breathing PCBs," exposure is measured in milligrams of PCBs
                         per cubic meter of air (mg/m3).  In the second and third sets of graphs, the
                        same relationship is represented for the known  "Health effects from
                        ingesting PCBs" and "Health effects from skin contact with PCBs." Expo-
                        sures are measured in milligrams of PCBs per kilogram of body weight per
                        day (mg/kg/day).  It should be noted that health effects observed by one
                        route of exposure may be relevant to other routes of exposure.

                        In all graphs, effects in animals are shown on the leftside, effects in humans
                        on the right. The first column on the graphs, labeled short-term, refers to
                        known health effects from exposure to PCBs for 2 weeks or less. The
                        columns labeled long-term refer to PCB exposures of lonqerthan 2 weeks.
                        The levels  marked on the graphs as anticipated to be associated with
                        minimal risk of developing health effects are based on information gener-
                        ated from animal studies; therefore, some uncertainty still exists. Based on
                        evidence that PCBs cause cancer in animals, the Environmental Protection
                        Agency (EPA) considers PCBs to be probable cancer-causing chemicals in
                        humans and has estimated  that ingestion of 1 microgrnm of PCB per
                        kilogram per day for a lifetime would result in 77 additional cases of cancer
                        in a population of 10,000 people or equivalently, 77,000 additional cases
                        of cancer in a population of  10,000,000 people. These risk values are
                        plausible upper-limit estimates.  Actual risk levels are unlikely to be higher
                        and may be lower.

What recommendations has the federal government made to protect human health?

                        For exposure via drinking water, EPA advises that the following concentra-
                        tions of PCB 1016 are levels at which adverse health effects would not be
                    •i   expected: 0.0035 milligrams PCB 1016perliterof waterforadultsand0.001
                        milligrams PCB 1016 per liter of water for children.
                       EPA has also developed guidelines for the concentrations of PCBs in
                       ambient water (e.g., lakes and rivers) and in drinking water that are
                       associated with a risk of developing cancer. The guideline for ambient water
                       is a range. 0.0079 to 0.79 nanograms of PCBs per liter of water, which
                       reflects the increased risk of one person developing cancer in populations
                       of 10.000.000 to 100.000 people. The guideline for drinking water is a
                       range. 0.005 to 0.5 micrograms of PCBs perliterof water, which also reflects
                       the risk of one person developing cancer in populations of 10.000,000 to
                       100,000 people.
PCBs.4

-------
                       The Food and Drug-Administration (FDA) specifies PCB concentration
                       limits of 0.2 to 3 parts per million (milligrams PCB per kilogram of food) in
                       infant foods, eggs, milk (in milk fat), and poultry (fat).

                       The National Institute for Occupational Safety and Health (NIOSH) recom-
                       mends an occupational exposure limit for all PCBs of 0.001 milligram of
                       PCBs per cubic meter of air (mg/m3) for a 10-hour workday, 40-hour
                       workweek. The Occupational Safety and Health Administration (OSHA)
                       permissible occupational exposure limits are 0.5 and 1.0 mg/m3 for specific
                       PCBs for an 8-hour workday.
Where can I get more information?
                       If you have more questions or concerns, please contact your state health
                       or environmental department or

                         Agency for Toxic Substances and Disease Registry
                         Division of Toxicology
                         1600 Clifton Road, E-29
                         Atlanta, Georgia 30333
                                                                               PCBs-5

-------
ScottLeRog	.	



From: Scott LeRoy 
To: sleroy@bestweb.net
Subject: Defining and Demonstrating Injury
Date: Saturday, January 22.20001:49 PM

Response to Public Comments on the Draft Scope for the Hudson River Natural
Resource Damages Assessment Plan June 1999 NYSDEC, Wednesday, November 17.
1999

The Hudson River Natural Resource Trustee Council (Trustee Council)
received numerous comments on the Draft Scope for the Hudson River Natural
Resource Damages Plan. This document is designed to address issues and
questions raised in the public comments and provide a general overview of
the range of topics identified relative to the Hudson River natural
resource damage assessment (NRDA).

Defining and demonstrating injury


Numerous comments related to the way we define and measure injuries. The
DOI regulations provide guidance on this topic: they describe the
requirements for assessing injuries to natural resources that result from
the release of a hazardous substance. The process involves determining a
pathway from the  source of the hazardous substance(s) to the injured
resources, and then determining whether services normally provided by the
resource have been reduced as a result of the release. The DOI rule defines
injury in terms of direct biological impacts as well as exceedences of
federal and state drinking water standards, surface water quality standards
and criteria, and relevant Food & Drug Administration action and tolerance
levels. A tolerance level exceedence occurs when concentration of a
contaminant in an organism(s) is sufficient to exceed levels for which a
State health agency has issued limits or bans on their consumption.


Agency for Toxic Substances and Disease Registry

How can PCBs affect my health?

Animal testing is sometimes necessary to find out how toxic substances
might harm people or to treat those who have been exposed. Laws today
protect the welfare of research animals and scientists must follow strict
guidelines. People exposed to PCBs in the air for a long time have
experienced irritation of the nose and lungs, and skin irritations, such as
acne and rashes. It is not known whether PCBs may cause birth defects or
reproductive problems in people. Some studies have shown that babies bom
to women who consumed PCB-contaminated fish had problems with their nervous
systems at birth. However, it is not known whether these problems were
definitely due to PCBs or other chemicals. Animals that breathed very high
levels of PCBs had liver and kidney damage, while animals that ate food
with large amounts of PCBs had mild liver damage. Animals that ate food
with smaller amounts of PCBs had liver, stomach, and thyroid gland
injuries, and anemia, acne, and problems with their reproductive systems.
                                                Page 1

-------
Skin exposure to PCBs in animals resulted in liver, kidney, and skin
damage.

How likely are PCBs to cause cancer?

It is not known whether PCBs causes cancer in people. In a long-term (365
days or longer) study, PCBs caused cancer of the liver in rats that ate
certain PCB mixtures. The Department of Health and Human Services (OHHS)
has determined that PCBs may reasonably be anticipated to be carcinogens.

Is there a medical test to show whether I've been exposed to PCBs?

There are tests to find out if PCBs are in your blood, body fat, and breast
milk. Blood tests are probably the easiest, safest, and best method for
detecting recent exposures to large amounts of PCBs. However, since all
people in the industrial countries have some PCBs in their bodies, these
tests can only show if you have been exposed to higher-than-normal levels
of PCBs. However, these measurements cannot determine the exact amount or
type of PCBs you have been exposed to or how long you have been exposed. In
addition, they cannot predict whether you will experience any harmful
health effects.

Has the federal government made recommendations to protect human health?

The EPA has set a maximum contaminant level of 0.0005 milligrams PCBs per
liter of drinking water (0.0005 mg/L). The EPA requires that spills or
accidental releases into the environment of 1 pound or more of PCBs be
reported to the EPA. The Food and Drug Administration (FDA) requires that
milk, eggs, other dairy products, poultry fat. fish, shellfish, and infant
foods contain not more that 0.2-3 parts of PCBs per million parts (0.2-3
ppm) of food.
                                               Page 2

-------
Aerobic and Anaerobic PCB Biodegradation in the Environment                                Page 1 of 1


 Environmental Health Perspectives Volume 103, Supplement 5, June 1995



 [Citation in PubMed] [Related Articles!


 Aerobic and Anaerobic PCB Biodegradation in the Environment

 Daniel A. Abramowicz

 Environmental Laboratory, GE Corporate Research and Development, Schenectady, New York


 Abstract

 Studies have identified two distinct biological processes capable of biotransfonning polychlorinated
 biphenyls (PCBs): aerobic oxidative processes and anaerobic reductive processes. It is now known that these
 two complementary activities are occurring naturally in the environment. Anaerobic PCB dechlorination,
 responsible for the conversion of highly chlorinated PCBs to lightly chlorinated or/Ao-enriched congeners,
 has been documented extensively in the Hudson River and has been observed at many other sites throughout
 the world. The products from this anaerobic process are readily degradable by a wide range of aerobic
 bacteria, and it has now been shown that this process is occurring in surficial sediments in the Hudson River.
 The widespread anaerobic dechlorination of PCBs that has been observed in many river and marine
 sediments results in reduction of both the potential risk from and potential exposure to PCBs. The reductions
 in potential risk include reduced dioxinlike toxicity and reduced carcinogenicity. The reduced PCB exposure
 realized upon dechlorination is manifested by reduced bioaccumulation in the food chain and by the
 increased anaerobic degradability of these products. - Environ Health Perspect 103(Suppl 5):00-00 (1995)

 Key words: aerobic PCB biodegradation, anaerobic PCB dechlorination, dioxinlike toxicity,
 carcinogenicity, PCB biotransformation                   	

       This paper was presented at the Conference on Biodegradation: Its Role in Reducing Toxicity and Exposure to
       EflvxroDincntfij ContflminBiits ndo
       26-28 April 1993 in Research Triangle Park, North Carolina.

       Address correspondence to Dr. Daniel A. Abramowicz, Manager, Environmental Laboratory, GE Corporate
       Research and Development, P.O. Box 8, Schenectady, NY 12301-0008. Telephone (518) 387-7072. Fax (518) 387-
       7611.

 {Table of Contents! (Full Article! f Citation in PubMedl [Related Articles]

 Last Update: September 24,1998

-------
General Electric

-------
John 6. Hoggont Managot
Hjdion«V«f*ogiom                                 Albanf.W 12303
                                              Far (5TQ 842-2731
                                              	    HG-1
                                              Gtnwcri EtecMc Company
                                                 : 51MM-3177
February 4, 2000


Alison A. Hess, C.P.G.
U.S. Environmental Protection Agency
290 Broadway, 19m Floor
New York, NY 10007-1866

RE: HUDSON RIVER HUMAN HEALTH RISK ASSESSMENT- COMMENTS

Dear Ms. Hess:

Enclosed are the comments of the General Electric Company (GE) on the US
Env ronmental Protection Agency's (EPA) 'Phase 2 Report - Rev.ew Copy, Further
cEeSon and Analysis, Volume 2F - A Human Health Risk Assessment For the
Mid-Hudson River" (HHRA, December 1999).

The central conclusion of the mid-Hudson Human Health risk assessment * that PCBs
posemo unacceptable risk to people who swim, wade, or boat in or drink water from the
m°d Hudson ri7er, or breath the air in the vicinity of the river. The sole nsk of concern to
PPA was to the hypothetical person who consumes extraordinary large amount offish
over aW periodI of time. Even in this case the calculated risks were very near to me
level deemed to be acceptable by EPA.  All-in-all this should have come as very good
n£ws particularly considering that the analysis was based on assumptions that grossly
overestimated exposure to and toxicity of PCBs.

We were disappointed to see that comments we submitted to EPA on September 7.1999
on^yorupper^dson Human Health Risk Assessment were not considered and as a
result this risk assessment suffers from the same flaws.

While we have attempted to work within the stringent comment deadlines you imposed on
commentors. we found it impossible to complete our review since we only just received
the EPA Baseline Modeling Report that provides one of the key inputs into the risk
assessment  As a result we reserve the  right to supplement these comments.

-------
Alison Hess
February 4,2000
Page 2
Please place a copy of this letter and associated comments in the site administrative
record.

If you have any questions on these comment, please let me know


                                 Yours truly,
                                 /John G. Haggard

JGH/bg

Enclosure

ce.    Richard Caspe, U.S. EPA
      William McCabe, U.S. EPA
      Douglas Fischer, U.S. EPA (ORC)
      Marion Olsen, U.S. EPA
      Michael OToole, NYDEC
      Walter DemicK, NYDEC
      Nancy Wm. NYDOH
      Anders Carlson, NYDOH
      Bob Montione, NYDOH

-------
       COMMENTS OF GENERAL ELECTRIC COMPANY ON
            Mid-Hudson River Human Health Risk Assessment
          Hudson River PCBs Superfund Site Reassessment RI/FS
                            February 4,2000
General Electric Company •                 Ogden Environmental and Energy Services
Corporate Environmental Programs            IS Franklin Street
320 Great Oaks Office Park. Suhe 323          Portland, ME 04101
Albany, NY 12203

-------
                      TABLE Of CONTENTS

1.0 INTRODUCTION AND EXECUTIVE SUMMARY	

2.0 THE FLAWS IN THE UPPER-HHRA ARE REPEATED IN THE MID-HUDSON
   ASSESSMENT AND RESULT IN OVERESTIMATES OF RISK	2
   2 LI EPA Should Reevaluatt its Current RJD for PCBs.	3
   2.J.2 EPA Incorrectly Dismissed the Findings of the fdmbrough Stvdy	S
3.0 EPA INAPPROPRIATELY TREATS THE MID-RIVER AS PART OF THE
   HUDSON RIVER PCB SUPERFUND SITE	6

4.0 THE PREDICTIONS OF WATER, SEDIMENT AND nSH PCB
   CONCENTRATIONS THAT FORM THE FOUNDATION OF THE RISK
   ASSESSMENT ARE HIGHLY UNCERTAIN AND FAIL TO PROPERLY
   ACCOUNT FOR ALL PCB SOURCES	7

5.0 EPA FAILED TO CONDUCT A PROBABILISTIC MODEL OF POTENTIAL
   EXPOSURE TO ANGLERS ON THE MID-HUDSON RIVER.	8

6.0 CONCLUSIONS	-	10

7.0 REFERENCES	.........	„„..........—	.....	...	.... 11

ATTACHMENTS	13

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 1.0  Introduction and Executive Summary

 General Electric Company submiis these comments on EPA's Mid-Hudson River Human Health
 Risk Assessment (Mid-HHRA). In September, 1999, GE submitted comments on EPA's Human
 Health Risk Assessment for the Upper Hudson River (Upper-HHRA).  In light of the similarities
 between the two documents, it is apparent that EPA failed to consider GE's earlier comments in
 preparing the Mid-HHRA. The Mid-HHRA thus suffers from many of the same problems as the
 Upper-HHRA.

 Despite the ominous language that EPA favors, the central conclusion in the Mid-HHRA is that
 PCBs pose no unacceptable risk to people who swim, wade, boat in or drink water from the mid-
 Hudson River or breathe the air near the river. EPA asserts there is a remote risk of an additional
 case of cancer in 10,000 among  people who eat extraordinarily large quantities offish (a half HG-1.1
 pound a week for 40 years), whose diet inexplicably tilts toward some of the most unpopular and
 unappealing, fish (eel and carp), and who, for no clear reason, eat the same species of fish from
the same pan of the river each week for 40 years — a combination of unrealistic circumstances.

GE's comments on the Mid-HHRA focus on several problems:

   •  The same unrealistic exposure and toxiciry assumptions that GE and others identified  HG-1.2
      with  respect to  EPA's Upper-HHRA are  repeated  in  the Mid-HHRA and  result in
      significant overestimates of potential risk.
   •  The predictions of water, sediment and fish f CB concentrations thai form the foundation
                                                                                    HG-1.3
     of the Mid-HHRA are highly uncertain,  are based on unvalidated and unreviewed
     models, and fail to account properly for other PCB sources.
   • Unlike the Upper-HHRA, EPA does not bother to conduct a probabilistic analysis of risks
     from  fish consumption for the Mid-HHRA. EPA's basis for this decision - that PCB HG-1.4
     levels are lower in the Mid-Hudson  - is nonsensical  and is inconsistent with EPA
     guidance. As a result, the  Mid-HHRA relies entirely on a flawed, screening-level, point
     estimate analysis.

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   •  EPA inappropriately treats the Mid-Hudson as pan of The reassessment of the Hudson

      River PCBs Superfund Site which is limhed to the stretch of river between Fon Edward

      and Troy.


2.0  The Flaws  in the Upper-HHRA Are Repeated in the Mid-Hudson Assessment and

     Result in Overestimates of Risk


In September 1999, GE submitted  substantial comments on  EPA's Upper-HHRA.  These

comments identified a number of significant flaws in that risk assessment.  Although EPA had

nearly four months to address the issues identified in GE's comments, the Mid-HHRA neither

acknowledges these comments nor attempts TO address them in any feshion. As a result, the Mid-
HHRA repeats  many of the flaws GE had previously identified, flaws that result in significant

overestimates of risk to the Mid-Hudson angler. Rather than repeat GE's earlier comments, we

incorporate them by reference and summarize them below.


   The VGd-HHRA Overrates th* Toxieiiv of PCBs:  As with the. Upper-HHRA,  the Mid-
   HHRA relies  entirely on animal-based  estimates of PCB toxicity and fails to adequately
   consider the available human epidemiological data, including the findings of Kimbrough, et
   al. (1999). GE's Upper-HHRA Comments include a detailed critique of these animal studies,
   their relevance to humans, and a methodology for considering the epidemiological data. See
   Appendix A to GE's Upper-HHRA Comments.
   The  Mid-HHRA  Improperly  Dismisses  the Kimhrough  Study:    EPA's  presumptive
   conclusion that this srudy will not result in a change in the Agency's cancer slope factor for
   PCBs, coming before the Agency completes its own, internal review of Kimbrough et aL
   (1999) is ill-considered and has no support in the record. Indeed, GE's earlier comments
   responded in detail to the Agency's earlier criticisms of Kimbrough et al. (1999), bui, as with  HG-1.7
   GE's other comments, the mid-HHRA appears to ignore the substance of these comments in
   its unfounded dismissal of this study.
   The Mid-HHRA Relies on The Wrong Srodv to Estimate Fish Consumption Rates; The Mid-
   HHRA uses the  same  problematic srudy - Connelly  et al. (1992)  - to estimate  fish
   consumption rates that was used in the Upper-HHRA.  These limitations are set out in detail
   in Appendix B to GE's Upper-HHRA  Comments.  Problems include in-companbility of
   results with other surveys of northeastern anglers, low survey response rate,  incorrect  HG-1.8
   weighting of non-respondents, long-term recall bias, lack of information on meal sizes, and
   the need to make uncertain  assumptions  from survey results about the fish caught  and
   consumed. For the reasons described in our earlier comments, the Agency should have used
   the Connelly et aL (1996) and/or the Eben et al (1993) surveys.

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   •n^  vfid-HHRA Jninrnperlv A*-m..m.!  for Cookine  Loss: Although acknowledging ihai
   PCBs  are  removed  during  cooking,  ihe  Mid-HHRA,  as  with ihe  Upper-HHRA
   underestimates these losses. Instead of using 20 perceni loss for ihe central tendency andHG-1.9
   zero perceni loss for the RME,  EPA should have done a Monte Carlo analysis using the
   probability distribution.
 •  The  Mid-HHRA Immonerlv Relies  on  Connelly et al. (1992) Data to Establish Species
   Preference- Because The Connelly et al. (1992) study was not designed to ascertain species
   preference, but instead was intended to measure anglers' understanding and compliance with
   consumption advisories, it  should not be used to establish species preference.  Further, the HG-1.10
   species listed in the survey are different from those that would be expected to be caught in
   the mid-Hudson.  When combined with the significant uncertainly required 10 extrapolate
   from the survey results, Connelly  et al. (1992) is the  wrong study  to use for species
   preference.
   These problems are exacerbated in the Mid-HHRA by the manner in which EPA used the
   Connelly et al. (1992) study, in conjunction with Barclay (1993), to conclude that more than
   50% of The species the average angler targets and eats are comprised of bottom-feeders, such
   as caifish, brown bullhead, and eel.   This result is not only contrary to common sense, n is
   inconsistent with the Barclay and NYSDOH data, as well as the available abundance data
   which show thai the anadromous species, such as sniped bass and members of the hemng
   family are the primary fish in the Lower Hudson River.

   The  Barclay (1993) data (as presented in NYSDOH, 1999) show that the bonom feeders
   (brown bullhead  carp, catfish, and eel) comprise only 24% of the catch, significantly lower
   than the species preference of 52% estimated by EPA.  Conversely, the Barclay (1993) data
   show a species preference of 26% for white perch, which is substantially greater than EPA's
   estimate of 7.6%.  Preference for yellow perch is also higher than the preference used by
   EPA.  Barclay (1993) also demonstrated that there is a  substantial species preference for
   herring and American shad. These species are not considered at all by EPA.

In addition to the issues identified above, there arc several  additional issues that require further

discussion.


2.1.1 EPA Should Reevaluate its Current RID for PCBs


The noncancer human health data, along with scientific findings on the mechanisms by which
PCBs cause adverse effects in  certain animal species, should be used by EPA to reevaluate its
current RfD for PCBs. EPA's RfD for  Aroclor 1254,  which was used to assess Mid-Hudson

River PCB risks through the fish ingesrion pathway, is based on a study of Rhesus monkeys that
has little relevance to assessing human  noncancer risks.   The immunological findings  of the

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 study clearly do  not demonstrate  clinically significant effects  (see Paul and  White, 1973;
 ATSDR, 1993; Kimbrough, 1995).  Furthermore, studies of PCB-exposed workers showed no
 adverse immunological effects or clinical signs of imraunocoraproraise, even when the workers'
 blood concentrations of PCBs were more than ten-fold greater than the levels measured in the
 Rhesus monkeys (Emmett et aL, 1988a; 1988b). Moreover, the minor dermal and ocular effects
 reported in Rhesus monkeys are of Hide or no relevance 10 humans because such effects are not
 observed in humans at similar  exposures. For example, none of the  studies of highly exposed
 workers have reported finding the pattern of nail, dermal, and ocular effects seen in the primates
 (Ouw et al., 1976; Smith et aL, 1982; Wolff « al., 1982; Lawton, 1985; Emmeti et al., 1988a,b;
 Taylor et al., 1988).  The reasons for this  are apparent from the differences in metabolism
 between Rhesus monkeys and humans (Brown, 1994). In fact, the data indicate that humans are
 many times less sensitive to FCBs than Rhesus monkeys. Accordingly, EPA should reassess its
 current  RfD for Aroclor  1254 to  take  into account the  extensive human  health  data that
 demonstrate that the RfD is based on a gross exaggeration of the potential human health risks of
 PCBs.

 If EPA continues to rely on the monkey study as the critical study 10 derive a deterministic RfD,
 EPA should apply uncertainty factors based on recent data regarding exposure and toxicity of
 PCBs in humans and experimental animals. These uncertainty factors (UF) should be as follows:
 (1) a subchronic-to- chronic UF of 1 based on the fact that the monkeys were dosed  for more
 than 25  percent of their lifetimes and pharmacokinetic equilibrium had been reached between
 PCB concentrations in adipose tissue and blood; (2) an interspecies UF of 1 based on evidence
 that demonstrates that humans are less sensitive to the effects of PCBs than are Rhesus monkeys;
 and (3) consistent with EPA practice, UFs of 10. 3, 1 for inierindividual variability,  minimal
 LOAEL to NOAEL extrapolation, and database uncertainty, respectively. Application of these
 appropriate UFs results in a chronic RfD for Aroclor 1254 of 2 x 10"* mg/kg-day,  which is ten
times higher than the value currently used by EPA.
While a deterministic RfD may be appropriate for screening assessments, the uncertainty in the
estimate of the protective dose  should  be used  instead of the RfD when conducting a
probabilistic assessment of exposure. Failure to do this will unnecessarily bias the risk estimate

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upward. The use of a distribution eliminates this bias and allows ihe decision-maker to consider
properly the uncertainty in the dose response portion of the non-carcinogenic risk assessment
process.

2.1.2 EPA Incorrectly Dismissed the Findings of the Kimbrougb Study

G£'s  comments on the Upper-HHRA responded  to  several purported "limitations" of *e
Kimbrough et al. (1999) epidemiological study of capacitor workers identified by EPA.  Rather
than address GE's comments, the Mid-HHRA summarily dismisses the Kimbrough et al. (1999)
study on the grounds that these "limitations," combined with those identified in two Letters to
the Editor in the Journal of Occupational and Environmental Medicine (in which Kimbrough et
al. (1999) was originally published), lead the Agency to conclude now that the "study will not
lead to any change in its CSFs for PCBs." Mid-HHRA at 24.

The record provides no basis for EPA to reach this conclusion.  EPA  has not completed its
-internal" peer review (which will supplement the two rounds of pre-publicarion peer review to
which the study was subject), and it is premature to guess at what conclusions that review might
reach about the value  of the srudy.  Nor do  the Letters to the Editor raise new and substantial
issues about the Kimbrough et al. (1999)  study.   Kimbrough ei al. responded to all these
criticisms in detail, demonstrating why they do not undermine the validity of the  study's
conclusions  (A copy  of these letters and Kimbrough et al.'s response is attached to GE's
comments in Appendix A).   Simply citing EPA's earlier  "criticisms" and these letters as
purported evidence of controversy about the  smdy is not a valid basis for rejecting it and does
not substitute for an unbiased, reasoned and detailed assessment of the srudy itself.

Rather than rehash the controversy surrounding the Kimbrough et al. (1999) study, EPA should
rum its attention to determining how the study can be used to improve the  validity of and
certainty associated with EPA's  CSFs for PCBs. A critical element of this effort should be to
focus on determining the "dose" of PCBs to which the studied workers were exposed.  With a
proper reconstruction  of the dose, one can  use the valuable data  from the Kimbrough et al.
(1999) study to test and, if appropriate, revise the CSFs for PCBs.

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3.0  EPA  Inappropriately Treats The Mid-River As Part Of The Hudson River PCB
     Superfund Site
EPA continues its fallacious claim Thai the Hudson River PCBs Superfund Site extends
The Federal Dam at Troy to the Banery in New York City.  GE has addressed this issue in the     ' '
past  The Site is limited to approximately 40 miles of the River between the Federal Dam and
Fort Edward. This conclusion is consistent with the administrative record on which the listing of
The Site on the National Priorities List, is based.  EPA's  post-rulemaking statements to the
contrary cannot modify the promulgated extent of the Site.  United States v. ASARCQ, Inc.. 28
F.Supp.2d 1170 (D.Idaho, 1998) (post-rulemaking  statement cannot expand scope of Site).  In
any event, many post-rulemaking statements of the Agency are from the site boundaries set out
in the NPL. Indeed, EPA's singular remedial focus on the sediments in the Upper Hudson River
underscores the fact that the Agency still treats the Upper Hudson as the Superfund site.

This point has more than academic interest.  In the Mid-HHRA, EPA "evaluates both current and
future risks ... in the absence of any remedial action and institutional controls" in order to
"establish acceptable exposure levels for  use in  developing remedial alternatives for PCB-
contaminated sediments in the Upper Hudson River." Mid-HHRA at ES-1. ES-2.  In other
words, EPA intends to use the results of the Mid-HHRA to provide justification for remedial
action in the Upper Hudson,  it would be reasonable to look at the effect of potential remedial
measures in the upper river to assure that a  possible remedy will not adversely impact the lower
river. On the other h*™*. in light of the feet that the Site does not extend to the lower river and
EPA is not examining potential remedies or PRPs in ihe lower river, it is unreasonable 10 seek to
justify upper river remedial action on the basis of purported benefits to those who consume lower
river fish.

The impropriety of such an approach is obvious.  The presence of sources of PCBs in the lower
river is well known to EPA;  EPA, N«w York  and New Jersey,  in feet, are engaging in an
extensive effort to identify and reduce such sources.  The Agency also made the importance of
other contaminants plain in its 1984 ROD, concluding "that  detectable  levels of dioxin,

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dibenzofurans, mercuiy and chlordane (from known and unknown sources)  have also been
,dentified in Hudson River fish, and dial even if PCBs decrease to an acceptable level, the fishing
bans would continue on the basis of these other types of comaminants."  Many of the most
desirable fish in the lower Hudson, such as striped bass, are migratory and thus are exposed to
many potential sources of PCBs and other contaminants. Despite these tacts,  EPA's remedial
fonis remains uxed on the PCBs in ihe sediments of the upper river and, effectively on a single
PRP.   The Agency  is not examining potential remedial alternatives  in the  lower  river to
determine their potential benefits to lower river fish consumers or even comparing the effect of
such remedies with the actions it is considering in the upper river. Simply put, the Agency can
not rely  on benefits  to the lower river, where numerous  PCB sources exist  and  other
contaminants may be of concern, to justify remediation in the upper river without looking at
alternatives that directly address those lower river sources.

In short, EPA cannot have it both ways. The Agency cannot describe the site as encompassing
the 150 miles from Troy to the Battery and then address only one contaminant and one area
outside that 150 miles as the sole subjects for remedial consideration. Quite apart from the legal
requirements, if one  expands a Superfund she by 150 miles to  take in a diversely populated
estuary exhibiting contamination from a  large array of sources and chemicals,  one cannot
continue to consider only one area, one chemical, and one PRP as the target of remediation.
Superfund did not legalize vendettas.

The scope of EPA's Superfund activity at the Site is circumscribed by the characterization  and
definition of the site, which EPA promulgated in its rule making many years ago.

4.0  The Predictions  of Water, Sediment and Fish PCB Concentrations thai Form  the
     Foundation  of the Risk Assessment  are Highly Uncertain and  FaU to Properly
     Account for All PCB  Sources                                                   HG-1 '15

The Mid-HHRA relies on predictions offish, water and sediment PCB concentrations made by
the Farley et al.  (1999) fate and  bioaccumulation model,  EPA's bioaccumulation model
(FISHRAND), and EPA's fate and transport model (HUDOX). As discussed in our comments

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on
   the baseline ecological risk assessment for the Lower Hudson River (G£, 2000), the validity
of these  predictions  is questionable  because of inaccurate descriptions of the processes
controlling PCB fate  and bioaccumulation.  Of particular concern for the HHRA is that the
inaccuracy and uncertainty of the predictions increases with the length of the prediction.  Thus,
the 40-year predictions used in the HHRA are subject to  a large,  but unknown, degree of
inaccuracy. A significant issue  in this regard is the impact of the incorrect specification of the
migratory behavior of striped bass (and movements of motile species such as white perch). The
assumption that striped bass are exposed to PCBs only in the mid-Hudson results in a failure to
account for the substantial  contribution from the lower estuary and New York Harbor.  This
contribution increases with time in the model projections as the  PCB load from the  Upper
Hudson River declines and the  PCB load from the metropolitan NY/NJ PCB sources remains
constant (an assumption in the model predictions).
               »
5.0  EPA Failed to Conduct a Probabilistic Model of Potential Exposure to Anglers on the
     Mid-Hudson River                                                              HG-1.16

Although EPA conducted a probabilistic assessment  of risk for the Upper-HHRA, it failed to
include such an analysis for the Mid-Hudson reasoning thai "a Monte Carlo analysis of cancer
risks and non-cancer hazards for the  fish ingesrion pathway was not warranted for the Mid-
Hudson HHRA, because the concentrations of PCBs in the Mid-Hudson River are lower than in
the Upper Hudson."  [Mid-HHRA, page ES-2] This rationale is nonsensical and  inconsistent
with EPA guidance.

EPA's justification for not performing  a Monte Carlo analysis is inadequate. It is clear from the
Phase 2 Scope of Work (EPA, 1998) and the Phase 2 Responsiveness Summary (EPA, 1999) that
EPA intended to conduct  a Monte Carlo analysis for  the  Mid-Hudson.  Perhaps  the most
compelling examples are a subsection in the Scope of Work entitled -Monte Carlo Analysis",
where EPA states "as in the Upper Hudson Risk Assessment, the Monte Carlo analysis will
evaluate  annual exposures on a year by year basis..." (EPA, 1998), and in response to comments
on fish consumption rates in the Responsiveness Summary, EPA (1999) states "in addition, the
Monte Carlo  analysis will  consider the M distribution  of risk and hazards for Hudson River

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 anglers."  EPA gives no him in either document of a situation where a Monte Carlo analysis
 would not be warranted for the Mid-Hudson River.

 EPA (1997) in its guiding principles for Monte Carlo analysis, describes several situations where
 a Monte Carlo analysis is warranted. It is this same guidance thai EPA (1998) cites in the Phase
 2 Scope of Work when describing the prtsentarion of the results of the Monte Carlo analysis -
 'The Monte  Carlo  analysts information  will be  presented following the recommendations
 outlined in the Policy for Use of Probabilistic Analysis in Risk Assessment" (EPA, 1997). Tnus,
 EPA fails to follow its guidance by not conducting a Monte Carlo analysis for the Mid-Hudson.

 According to EPA's guidelines for probabilistic analysis, a Monte Carlo analysis is useful when
 screening-level risk estimates are above levels of concern. In addition, a Monte Carlo analysis
 is useful "when it is necessary to disclose the degree of bias associated with point estimates of
 exposure;  when ii is necessary to rank exposures, exposure pathways, sites  or contaminants;
 when the cost of regulatory or remedial action is high and the exposures are marginal; or when
 The consequences of simplistic exposure estimates are unacceptable." (EPA, 1997).  A Monte
 Carlo analysis does not add value only when screening risk estimates are clearly below levels of
 concern or when the costs of remediation are low (EPA, 1997). Low contaminant concentrations
 are not a valid basis for not performing a Monte Carlo analysis.

 All the factors favoring application of Monte Carlo techniques  are present  here. EPA's Mid-
 Hudson point estimate  analysis  purports to show that risks from fish consumption  are
 unacceptable.  Only a Monte Carlo analysis can begin TO charanerize  the degree  of bias
 associated with these point estimates.

 Accordingly, EPA should conduct a Monte Carlo analysis for the Mid-Hudson River. EPA has
previously developed a Monte Carlo exposure model for the Hudson River.  Although this model
 is flawed (as noted in GE's comments on the Upper-HHRA), no additional development time
would be required to implement the  model.  Whether  this model or GE's more sophisticated
time-dependent two-dimensional model,  as detailed in GE's comments on the Upper HHRA

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(GE, 1999) is used, we believe the results will demonstrate that fish consumption in the Mid-
Hudson is unlikely to pose unacceptable risks .

6.0  Conclusions

The purpose of the Mid-HHRA is to characterize current risks and their associated uncertainties.
                                                                                     HG-1.17
In some regards the Agency has performed well, and in others it has not.  The Mid-HHRA
concludes that the only material human health risk is the potential consumption offish from the
Mid-Hudson River.  EPA, however, poorly characterizes the fish consumption pathway and
arrives at hypothetical risk estimates that are unrealistically overstated.  Furthermore, the risk
assessment poorly communicates the findings and uncertainties. The major problems include:

   •   The Mid-HHRA follows a screening-level, point estimate  approach.   A Monte Carlo HG-1.18
       analysis, even a limited one like EPA's model of the Upper Hudson River, would result
       in reduced risk estimates and different risk conclusions.

   •   EPA's critique  of Kimbrough era]. (1999) is superficial and the claim of limitations is HG-1.19
       unfounded.   EPA needs to complete' an objective and scientific evaluation of this
       groundbreaking study.

   •   EPA grossly overestimates the toxiciry of PCBs and as a result overstates potential risks.
       Based on a weight-of-evidence appraisal, there is no credible information that PCBs HG-1.20
       cause cancer in humans.  Additionally, there is little, if any, evidence  that PCBs cause
       adverse effects in humans at environmental exposure levels.
1 We assume that EPA's statement thai oncer risks from fish consumption "are within ibt upper bound of the
cancer risk range generally allowed under the federal Superfund law" (Mid-HHRA at	] is a typographical
earn, but if not, EPA must clarify its conclusions about the cancer risks posed by fish consumption.
                                          10

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    •  The exposure assumptions made TO  estimate risks to the  angler materially overstate
                                                                                    HG-1.21
       potential exposures.

 As a result, it is apparent that EPA needs to redo the calculations of potential risk to the angler in
 the Mid-Hudson River to correct these errors.  Using a Monte Carlo analysis, the cancer risks
 would be acceptable, even if EPA uses its flawed model.

 7.0   References

 ATSDR-  1993. Toxicological Profile for Selected PCBs (Aroelor-J260, -1254, -J248. -1242. -
 1232. -1221. and-1016).  Agency for Toxic Substances and Disease Registry, Atlanta, QA and
 U.S. Department of Health and Human Services, Public Health Service. April.

 Barclay, B.   1993.  Hudson River Angler Survey:  A  Report on the Adherence to Fish
 Consumption Health Advisories Among Hudson River Anglers. Hudson River Sloop Clearwater,
 Inc., Poughkeepsie, New York.  March.

 Brown, J.F.  1994.  Unusual congener selection patterns for PCB metabolism and distribution in
 the rhesus monkey. Organohalogen Compounds 1 \ 29-31.
 Connelly, N.A., B.A. Knuth, and C.A. Bisogni. 1992.  Effects of the Health Advisory Changes
 on  Fishing Habits  and Fish Consumption in New York Sport Fisheries.   Human Dimension
 Research Unit, Department of Natural Resources, New York State College of Agriculture and
 Life Sciences, Fernow Hall, Cornell Universiiy, Ithaca, NY. Report for the New York Sea Grant
 Institute Project No. R/FHD-2-PD. September.

 Connelly,  N.A., B.A. Knuth, and T.L Brown.  1996.  Sportfish Consumption Patterns of Lake
 Ontario  Anglers  and the Relationship to Health Advisories.  North  American Journal of
Fisheries Management 16:90-101.

Eben, E.S., N.W. Harrington, K.J. Boyle, J.W. Knight, and R.E. Keenan.   1993. Estimating
consumption of freshwater fish among Maine anglers.  N. Am J. Fish. Mgr. 13:737-745.

                                         11

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Feb-04-00 18:11     From-                                                   T-3IZ  P 17/79   F-180
      Emraen, E.A., M. Maioni, J.M. Schmith, B.K.  Levin, and J. Jeffexys.  I988a.  Studies of
      Transformer  repair  workers exposed  to PCBs:   I.  Study  design, PCS  concentrations,
      questionnaire, and clinical examination results. Am. J. bid. Mud. 13:415-427.

      Emmen, E.A., M. Maroni, J. Jeffexys, J. Schmith, B.K. Levin and A. Alvares.  1988b.  Studies of
      transformer repair workers exposed to PCBs: II. Results of clinical laboratory investigations.
      AmJ.lnd.Med. 14:47-62.

      EPA.  1997.  "Policy  for Use of Probabilistic  Analysis in Risk Assessment at the U.S.
      Environmental Protection Agency."  Office of Research and Development,  Washington, DC,
      USEPA/630/R-97/001.

      EPA. 1998. Hudson River PCLs Reassessment Rl/FS Phase 2 Human Health Risk Assessment
      Scope of Work. U.S. Environmental Protection Agency - Region II. July.

      EPA. 1999. Hudson River PCBs Reassessment Rl/FS Responsiveness Summary for Phase 2-
      Human Health Risk Assessment Scope of Work.  U.S. Environmental Protection Agency -
      Region! April.

      Farley, K., R. Thomann, T. Cooney, D. Damiani, and J. "Wands. 1999. An Integrated Model of
      Organic Chemical  Fate and Bioaccumularion in  the Hudson River Estuary.  Environmental
      Engineering Department, Manhattan College. March.
      GE.  1999.  General Electric's Comments on Hudson River PCBs Superfund Site Reassessment
      RI/FS Phase 2 Human Health Risk Assessment. September 7.
      GE. 2000. General Electric's Comments on Baseline Ecological Risk Assessment for the Lower
      Hudson River.

      Kimbrough,  R.D. 1995. Polychlorinated biphenyls (PCBs) and human health: An update.  Crir.
      Rev. Toxicol. 25(2): 133-163.
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Fab-04-00 11:11     Fror                                                    T-312  P 18/79  HBO
      Kimbrough, R.D., M.L. Doemland,  and M.E. LeVois.  1999. Morality in male and female
      capacitor workers  exposed to polychlorinated biphenyls.   Journal  of Occupational and
      Environmental Medicine 41(3):161-171.

      Lawton, R.W., MR. Ross, J. Feingold  and J.F. Brown.  198S.  Effects of PCB exposure on
      biochemical  and  hemaiological findings  in capacitor workers.   Environ. Health fersp.
      60:165-184.

      NYSDOH.  1999.  Health Consultation:  1996 survey of Hudson River anglers, Hudson Falls to
      Tappan Zee Bridge at Taxrytown, New York. New York Slate Department of Health.  February.

      Ouw, H.K., G.R. Simpson and D.S.  Siyali.   1976.  Use and health effects of Aroclor 1242, a
      polychlorinated   biphenyl,   in  an   electrical   industry.     Arch   Environ.   Health
      (July/August):189-194.

      Paul, J.R. and C. White.  1973.  Serohgical Epidemiology. New York, NY: Academic Press.

      Smith, A.B., J. Schloemer, L.K. Lowry,  A.W. Smallwood, R.N. Ligo, Stanaka, W. Stringer, M.
      Jones, R. Hervin, and C.D. Glueck.  1982.  Metabolic and health consequences of occupational
      exposure to polychlorinated biphenyls. British J. Ind Med. 39:361-369.

      Taylor, P.R,  1988.  The Health Effects of Polychlorinated Biphenyls.  Harvard School of Public
      Health, Boston, MA.
      Wolff, M.S., A. Fischbein, J. Thornton, C. Rice, R. Lilis and I.J. Selikoff.  1982.  Body burden of
      polychlorinated biphenyls  among persons employed in capacitor manufacturing.  Int. Arch.
      Occup. Environ. Health 49:199-208.

      Attachments

     Attachment A: Copies of the Letters  to the Editor, Journal of Occupational and Environmental
     Medicine 41(9): 739-745. September 1999.
                                              13

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       JOEM • Volume 41, Numoer 9, September 139%
                                             Trora t&%»lih Sciences Library
                                             Mercy Hospital, Portland. Maw
       Letters to  the Editor    ^^^     .
                                             This material nay be prelected by
                                            wpynghr Uw (Title 17U.S. Code).
       Rraden ait imnietl in niliffiii  letifn for publication m  thi» dtpan-
       mmt. Submit  ilu-m  lu   The hditur. Journal  nf  Occupational and
       Environmental Medicine, HJtSux370. Bryn Mflwr, PA 19010. Letim
       should be lypnvnilrn and double tyuted and should  be
        "for Publication."
                                                                                         739
        Evidence ol Excess Cancer Mortality
        in a Conort ol Workers Etposed to
        Poiychlorinaied Biphenyls
          To the Etiittii  To funnei
        previously repoiiea excesses in \.M-
        cer-specific mortality tn  workers
        who  have been  occupjtionally ex-
        posed 10 polychlontiaied bipnenyls
        (PCBi). Kimbrough vl hi1 reported «
        retrospective cohon mortality study
        of 7075  nuilc «nd  female  worker.
        exposed 10 PCS* during the capuci-
        tor-manufacturing  process  M  iw<>
        General Electric  (CEj plants ,n up-
        sute  New  York  Kiiribrough ft j
        concluded  that  the  >tud)  results
        railed 10 show any associauon be-
        tween occupational  PCB  exposure
        and cancer-related mortality  We in-
        terpret their study  findings ditler-
        ently.  Although  limitations in tne
        study approacn (outlined Deio» ) tend
        to dilute any excesses in cancer mor-
        tality resulting from PCB exposure.
        the findings Mill suggest a  rciam>n-
        ship  between  PCB  exposures  add
        excess cancer m  iminant
          First, this s-tudy demonstrated once
        again that modern industrial workers
        ore healthier than me general popu-
        lation  Known as  the "healthy wurker
        effect" (HWE), thi»  bia> result m
        standardized mortality ratios tSMRsi
        that  are considerably  less than ex-
        pected (eg.  SMR <  90) for all mor-
        tality and cancer mortality1"1 when
        workers are compared with a general
        population  Consistent  u-ith  the
        HWE  bias. KJtiiorough et hi (bund
        that all cancer  mortality was signifi-
        cantly beta* that expected m male
        hourly workers (SMR  =  8 1 ). male
        salaried workers  (SMR = 69).  and
        female salaried  workers'  (SMR  =
                        72) However, despue the HWE, fe-
                        male  hourly  workers had elevated
                        SMRs  for  all  cancer  mortality
                        (SMR = I lO) and for Uiree (intesti-
                        nal [SMR ^ 157J, rectal [SMR  =
                        169],  and melanoma (SMR  = 144])
                        of the six cancers of a pnon interest.
                        Melanoma  mortality  wa» aUo ele-
                        vated  for  male hourly  workers
                        (SMR - 130). Alihough the eleva-
                        tions  in  cancer-specific SMRs did
                        not achieve >unsncal  significance.
                        they were consistent with elevations
                        found in other studies of PCB-
                        exposea workers.*"6  Given the
                        HWE, these elevations  are  particu-
                        larly noteworthy.
                          Second, when looking at cancer
                        mortality rates, it is customary  to
                        include a latency period to adjust rbr
                        the ume lag between exposure and
                        clinical evidence of disease (or,  m
                        this study, cancer death).1 However.
                        Kimbrough et al included a latency
                        period only for all cancer mortality
                        and for  intestinal cancer mortality
                        among temale hourly workers When
                        female hourly  workers with at least
                        20 years of follow-up were evaluated
                        de, with a sufficient latency  period).
                        the SMR for all cancers increased
                        from  1 10 to 1 17* (P  =  U.058). The
                        SMR  for intestinal cancer* increased
                        from  157 to  189. thus  becoming
                        statistically significant (P < 0.05).
                          Third, proper assessment of expo-
                        sure should have accounted for tne
                        dotes  (calendar years;  of employ-
                        ment. the intensity of exposure fur
                        each type of job, and  (he  specific
                               There i< an enw in TiBlc 6 01 me
                             rcpun. Tne SMR fur "ail ik/iccis  ,(l
                        fcnule nuurijr workers wiin 3:20 ,»»' uieni-y
                        o»rr .ill icn^trlkurcmpluy merit mould Be • 1 17 •
                        11(4 "4AM 4H repuftol
 Aroclur PCB  u>rd  For example, in
 the earlier year? of plant operation
 (1446 m N54), any exposures would
 have  been tu A roc lor 1254. whereas
 exposures m the 1970s would have
 been to the less  toxic  Aroclor
 1016 *v  Industrial  hygiene  proce-
 dures at the plum probably improved
 Over  time as well. Therefore, length
 of employment alone was an inade-
 quate surrogate  of ixposure and u
 likely source of exposure misclassi-
 fication bia> I\\M could havc led to an
 undcrcstmute uf clTect  and  distor-
 tion  ol' exposure-response  relation-
 ships
  Kimbrousih et al assembled  the
 largest  cohon of hourly PCB work-
 ers studied to date,  including a large
 number of temale workers. How-
 ever,  most ot tne hourly workers had
 exposures tlut were comparable with
 exposures jimms:  the  general   US
 population  From the data provided.
 it appears  uui  approximately  one
 fourth of the person-years contrib-
 uted  by male hourly workers,  and
 approximately 10% of the person-
 years contributed by female hourly
 workers, were contributed by work-
 ers who hdd been  employed for at
 least 6 months m high-exposure jobs.
 Only  112 (3 Sti} male hourly work-
 en and  12  (05%) female hourly
 workers were employed exclusively
 in lu'grt-exposuie JODS The majority
 of the hourly workers never worked
 in high-exposure  |ub> Only & small
 percentage  ot hourly  workers  had
 evidence of PCB exposure  that was
 appreciably  greater  than  that of  the
 US population Therefore, relatively
 small elevations m  cancer mortality
 would be expected for this group,
 even  if PCB  cancer  potency were
 alarmingly hicn
  Fourth, although one of the goals
 of this  study wa%  to  evaluate   >ix
 ipecilk eancer*  of  a  priori interest
 de. melanoma, liver, rectal, gastroin-
 testinal  tract, brain, and hematopoi-
 etic cancel*),  me study focused  al-
 most entirely on ill cancer mortality.
 In planning tne study, tne researchers
should have realized that the sue and
age distribution of the hourly

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       740
                                                  Leners TO the  Editor
       TABLE 1
       Caicuiaions ot Siatisticai Power to Detect varying Standardized Mortality Ratios
       (SMPs) for me Su Cancers ol A Pnon interest
                               Eipecied
               Cancw          Numoer    SMR = ISO   SMR = 200   SMR = 300
MSI* nouriy workers
Melanoma
UvCi
Rectum
er
Bia.n
Biooo
Female nowiy womers
Maanuuiii
Uver
Rectum
Ci
Brain
BIOOO

38
25
34
140
51
141

20
22
16
127
37
10S

12%
9%
14%
36%
ISM
37%

8%
12%
10%
36%
11%
32%

35%
24%
37%
as%
44%
66%

22%
28%
22%
83%
32%
77%

80%
62%
80%
100%
69%
100%

S5%
65%
52%
100%
ra%
100%
          •61.
        force wouM rciuli in pu«r
        po*ei to evaluate the camels of a
        priori interest  Table  I  shuws the
        expected number or dejths tor eacn
        or'thcte w-inuers tor mule and female
        hourly workers and the resulting MJ-
        tisticyl power for SMRi from 150 to
        300.  usitij  die study •» mi-thud for
        determining  •>ttti.>cn..il  significance
        lie.  die  v59« cunnuunLe  mieival)
        BCCUUM. Hi the  buses m the study
        and  ihe luw  percentage of highly
        evpojtd workers, an SMR of 150
        might be a> hi^h a*  wuula  be ex-
        pert u.-d r»r these cancer  A* seen m
        Table i  for an  SMR  of  150, the
        study had less than a  one in five
        chance of obtaining  a  -aaiiMically
        significant result  tor tour ot' the six
        cancen  Given the sample  size and
        the numbers of expected careers, the
        study did nut have sufficient statisti-
        cal power (>8U%) to detect an SMR
        of 30U for most of the cancer*  of
        interest.
          Kimbrough ec ol  examined and
        reponea SMRs for categories of in-
        creasing length or employment and
        year* of latency only when " .  there
        was an elevated total SMR  witil two
        or mure  observed deaths  and  for
        which the Lower boundary ot  the
        95%  confidence interval (Clj was 90
        or above'" The impact of this deci-
        sion can be seen in Table  2  Given
TABLE 2
Number of Observed Deatns ana me
SMR Required for is90 as tne Lower
Limit ot me 95% Confidence interval
     No. ot Deatns         SMR
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
744
437
331
278
245
22a
209
IS?
168
130
1?«
169
165
161
157
154
152
150
the biases mentioned previously, it is
understandable Uut just one of the
six a priori  cancers  met these re-
quirements Furthermore, accounting
for a latency  penod  should be a
prerequisite for calculating any adult
cancer SMR. Otherwise, the SMR is
bused toward or below 100. Fur all
six cancers of a priori interest, anal-
yses accounting for latency and for
length of employment should nave
been  done and  presented,  allowing
the reader to decide whether or not
the TutuUs were lYieumngtul
   In summary the  Kimbrough  ct al
study suffered trom HWE bias, fail-
ure Ui aCwuunt for latency, exposure
mifti.U'.Mtit.Jiioii  potentially insuffi-
cient duiage differences between ex-
poitfU and compuriton  groups,  and
pm«r statist.cal power Nevertheless,
irtc Mudy did  find excc«*ev  in three
or the six luncers of interest. Future
research  should  include analyses
nude with internal  comparisons (to
minimize biases from HWE) of suf-
ficient numbers  of highly exposed
workers, us well as analyses account-
ing for cancer latency penods  This
might require an additional decade or
more of ibiiow-up on this cohort and
the  auuttion  ot  exposed workers
from other PCB plants (eg,  workers
at tne Massachusetts  plant included
=n Brown5 ). before a definitive state-
ment about the association between
PCB expooure and  specific,  cancers
can be made

               Frank J. Bove. ScO
             Barbara A. Slade. MD
           Richard  A. Canudy, PhD
   Agent* f»r Toxif Subtranfci and
                                                      yf Health
                                                      Hctilih Assessment
                                                       and Consolation
                                                            Aileuua  GA
                                      References
    Kimoruudn RD. DocinUrul ML. LeVo.s
    Vlh Mortality in .iiak anil lenulc eapue-
    itoi » Oiler* e\pui«i la pni;cniarinaieU
    Biph«ii»l> J (3*ui^ iitvuvn MtJ  1949.
    41 161-17)
    ChcckOn!) H Pcuu ME. Cawtorcl-
    Bro-n DJ  Krirardi fdtittuat m Oetu-
    [xt'ivnul  EpitUunouis)  .V<* YorK  O«-
    toru Um«cr»i[y ?ttt» i989 78-79.
    Kufk. RM. Mliih>li NA. Punned L.
    Muurc-£rs«n R. Silvmlnn MA A eem-
    paniun of PMRs ana SMRi u e»tim»wrs
    of occupational rruinaliiy
 4  Looiiu* D. Bruwnm; SK Scnem.1 AP
    Gregory I. $j*i» IM Cancer mwuiliy
    nnon;j cinini: utiiiry worKm exposeu to
    poiycnifiMuWfl b.plirnjlj Oteuf En expoi«o

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                               F-180
                               /*»!
    (0 pOl/chloriMieU bipftcnjrli M update
    A/f* fcnwwi HtulHi  1 087.42 333-319
  o SHIM T Stcsie C Snuin AB. WHIMS K.
    ShuitN RA  Mucuiii> 11110114 workeis e»-
    po«d iu pui/cnioniuiea biphen/li Am J
  7 Cne-.t,o»4x H Pearcf N. HiCUy JLS.
    Deniciil JM Ldtcni/ .ifiajjrus in uccupa-
    liunjl  cpiOemiulogy Ar(h Environ
    Hcu/iA IWU.45 U5-IUU
  3 Coglutiw VJ  A»e*>intf uie rawer nsk
    From environmental  PCB>  Environ
    HcultH P,rt^i 1998 106 317-323
  V Miye> HA McConncl £E. Neal bH. «
    j|  Comparative  carcinogenidiy in
    Sprjj«-Di»le; nb  of uic poiycnion-
    IUKU Dipnenyi matures Aroeion Iul6
    1 242  1254 jt\a 1260 r<*cu.o/5ci 1998.
   7/6 thv Edttos. We were glad to see
 die recent article on morality among
         exposed to polychlonnated
 biphenyls '  AI a  une  when  fewer
 and  fewer  companies  are  funding
 occupational epidemiological  stud-
 ies. we commend  the sponsor. Gen-
 eral Elcctni:, lor ttos initiative The
 completeness of case ascertainment
 was  Outstanding.  In addirion. this
 report was A. model  of clear Anting
 and dear display of  results
   Hywevei  wo issues, sample size
 and exposure. raise  significant con-
 cern  First  the study population was
 very  small Over 7000 worker* con-
 tributed  over  2UO.OOO person-years
 of ob>ervation, mure than in  prior
 PCB mortality studies. But when at-
 tention is restricted 10 (hose Corkers
 with  hign  exposure, moderate-  to
 long-duration employment, and ade-
 quate person-time after a latency pe-
 riod.  the numbers are dramatically
 reduced  For example, only one third
 of the cohort worked for longer than
 5  yean.  (We  note in passing that
Table 2. tne source of these  data,
 shows 7178 workers in the upper
panel and 707S worker* in (he ]ou/er
panel, a disparity the authors do not
explain) Similarly,  less  than  one
fourth or* the cohort was classified as
highly exposed, and  the median pe-
riod of high exposure was less than 2
yean.  Although data are not pre-
sented to support exact calculations.
it appear, that fewer than 10 cancers
 of any type, and more typically fewer
 than  three,  were cxpcitcii  m  any
 sex-salary stratum with high expo-
 sure, more than a year or employ-
 ment, and  more  ttian  2t) years of
 latency Could uV be *riy [tic article
 is conspicuously Silent on ih.:  uiue
 of statistical power'
   The  problem of  small number
 could have been dddre»ed A  com-
 pany as large a> GE presumably had
 other capacitor plant* and could have
 supported a multisite study Alturnu-
 lively, an industry-wide itudy would
 have been informative as we have
 seen  in the  semiconductor,  rubber.
 petrochemical, automobile, and other
 industries Indeed, we  wonder why
 restricting a cancer mortality study to
 only two plants hhuuld not be viewed
 as a willful effort to awoni a pv»iuv«
 finding.
   The  second  major  concern  lies
 with  exposure .i*>es>mem.  A» with
 many  historical  cohort studiev the
 authors created a rriatru to chuiacter-
 ize each individual s exposure li the
' designated "high exposure" jnb> did
 not  actually  entail  high  exposure.
 then misciatMticauon occurred und
 could  have  mtroauccd  substantial
 bias toward the null. Weie the expo-
 sures au-curately asscs^J'
   The arucie makes reference ID j
 readily  available  way ID vjlidaie tne
 exposure  assessment,  serum  PCB
 levels obuined dunng the  1970s on a
 sample  of several hundred  cohort
 members. Where are uic»e measure-
 ments0  Did the author* check  tneir
 exposure  assignments  against  Uie
 past serum measuretnents'  If not.
 why not0 If »o. wny wa> this com-
 pariion not reported'
   Another aifficulty  with exposure
 in this  article is  the admixture  of
 various types  of PCBs. More carci-
 nogenic forms,  such  as Aroclor
 1254. were used  in the early years.
 and less carcinogenic forms, such Ay
 Aroclor 1016. were used later  By
 combining ihe two rather than focus-
 ing  on the early  exposures, the au-
 thors may have obscured  a true ef-
 fect.
   Overall,  these  concerns  signifi-
 cantly limn the conclusions that can
 be drawn from the study. The authors
 conclude that their results  "would
 suggest  a bck of an  association."
 This conclusion is Overstated. These
 results do offer some evidence that
 PCBs are not highly potent carcino-
 gens causing relative nsks above 10
 or 20, a conclusion that was already
 fairly well established. But they pro-
 vide little reassurance that PCBs do
 not  double or triple the mk of some
 cancers after significant exposure.
   For this rnuon, we were especially
 concerned that the results  of the
 study  were not interpreted and pre-
 sented more carefully. The  authors
 might have noted, in their  conclu-
 sion, that PCBs are  serious health
 hazards irrespective of carcinogenic-
 ity.1 with effects that  include de-
 creased birth weight,3 neurodevelop-
 mental   abnormalities, *""  anJ
 interference wicn both estrogen9 and
 thyroid10 hormone function. Accord-
 ingly,  even negative findings in  a
 cancer study would not reassure us
 of safely. That omission in the JOEM
 article, in turn, may have contributed
 to overtly  misleading  journalistic
 coverage,  such as the Afe*  York
 Times headline: "Study Finds Littic
 Risks [sic] From PCBV"
   The authors of this study note that
 our knowledge of PCB health effects
 h "limited." On the path to  a more
 complete understanding, the  current
 study results represent  a great leap
 sideways.

       Howard Frumkm. MD. OrPH
  Department of Environmental and
               Occupational Health
  Rollins School of Public Health of
                  Emory University
                       Ariaaia. CA

            Peter Oms. MD. MPH
 Division of Occupational Medicine
             Coot Connry Hospital
                       Chicago. IL

References
 I. Kifflbreush RD Doemlaml ML LcV0i>
   ME Monjiii} in male and lenuic eapac-

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                                          T-312   P 22/79   F-1
        742
                                                                                                Letters to the  Editor
           unr
 exposed to
 fj<.hU>rm4t
           and  Human nuiin  int  i (Amy
           £«»iAM H*uU>,  ISWS II  Mi-Ill"
         3 Pjunuin S  Koopffl»n-E»»*bouiii C
           KidUrr MA Weisjsijj.Kuperu. >
           PJ  Eftecij of cn»ironinciiuic\|V'M,< i»
           pOlyClllurillalcil Diprtclljrls dlW UiiiMfli on
               site ano jro*cn m Dutch cmiurcn
                     1998*4 538-543
         4 RjUnucr L. StromOerg U. 0/rciiurk E
           (Xtman C. Nihson-Eliie P iLijnur L
           Pjl/vhlorinaied Biprtenyis in  Bioufl
           pla uii
                ve uDilihr* in DutCA Children ai 42
                 Ot .ye  ^ l«/  .VOH
                     Jm.uO>onSw
           PC8i a<
                                   n.jm< in
                    cl
           4:4
         V  Connor K Rjitumouftfty K Mv»>
           al HjrdnuyUtca polycnionnabd
           n/b  (PCB>) as vifrogcns ^ii
           gcn>  iiruciurr-3Cti<'ii>
           TtnnolAppI fhannarvl
           123
        lO  Poi»rficia  SP. hendr;  LB  Impj.i  or
           PCB> on in/roio normonc aim.icd
           deoelopmcnt. fi/tui// Ind Httllfl,
           14 IU3-12U
        1 1  Cbiinnun JH SiuU> f*ino> imk- n»k . rnini
           PCS'. Vrw r«/t r««rj MOrthlO i»»J
              Authors Rtply:  Thank  you
       r'or giving us the opportunity to reply
       to  the  letters  by Bove  ei  ai  and
       Frumkm ana  Oris commencing  oa
       our monjiiiy study of PCB-expotL-a
       capacitor workers '  We disagree
       with the statement by  Bove et al Uiat
       ". . .  limitations  in  the  >tudy  ap-
       proach wnii to dilute any excess in
       cancer mortality resulting from PCB
       exposure . . " The* assertions arc
                      not supporrea by the
      Although ^mc d for all-
 causet mortality ana cazwcr mortal-
 ity. Th»s it ponially true. The HWE
 is mutt pronounced for cardiovascu-
 lar deaths and thu.s affects all-cause^
 munaiuy :  It has  much  less or' an
 effect on lancer deaths.3
   The presentation by Bove et al of
 the all-cancer?  SMRs  und selected
 canwer-specitic SMRs without confi-
 dence intervals  (CIs) gives incom-
 plete information and is misleading.
 Hud  the confidence intervals been
 reported, the lock of significance for
 these SMR-, auuld have been imme-
 diately obvious to the reader. Bove et
 al  selected the  female hourly  em-
 ployee*  all-cancers SMR of  HO
 (95*  CI. 93 to 129J, intestinal csn-
 w (SMR  =  157;  <*5%  Cl, 96 to
 242).  rectal cancer (SMR = 169;
 95*  Cl.  46 to 434),  melanoma?
 iSMR - 144; 95% CI. 30 to 421),
 und melanomas in  male hourly em-
 ployees (SMR - 130; 95% Cl, 42 to
 303). Notably absent from Urn list of
 SMRs considered by Bove et al are
 me mule hourly SMRs for intestinal
 and rectal cancer (SMR = 57; 95%
 CI. 25 to 1 12: und SMR = 87; 95%
 CI. IS to 255. respectively).
  Bove et  al suggest that the mule
 ail-cancers SMRs of 81 (hourly em-
 ployees: 95% CI. 68 to 97) and 69
 (salaried employees. 95% CI. 52 to
 9U) are largely due to the HWE  A
careful examination of Table 4 in Our
article  suggests that the statistically
  m fejth the hOuily ami salaried rnalei
  result prnTiouiy irum the lower ihan
  expected  luii-.'  taiKcr  SMR irur
  hourly  worker^  42  obtefved/54 5
  expected. SviK - 77  $5f* Cl 5o tu
  104. and tor s.iiuned workers   12
  ut»erved/2y ft c*pevted  SMR =. 4 1
  95%CI.2l to 7|j
    The  sciicment by Buvr et ai that
  these elevations were consistent with
  elevations  found m uiher studio of
  PCB-expowd workers  <>  nut cor-
  rect.*'0 In addition to the thres stud-
  ies cited by Buve et al. there is the
  Benaz7i  cohoit  and  n% update oy
  Bena22l  et al' and Tirum et al " The
  result of the Brown1 and Sinks et al'
  studies  are inconsistent wuh each
  other. The Loonus et Jln  «tudy  of
  utility workers not capacitor  work-
  ers. did report an cicvji.oti m mela-
  nomas in iomw -.ubiets of the cohon
  that were presumed to have tiad e*-
  pohure to PCB»  ofiiile Burkina out-
  doors. Exposure ID sunlight a a<; nm
  adequate!) jkkuumed fur oy Luomis
  et al * Brown and Jones'' arid Brown*
  found on =\Lf,% of liver and  retiul
  cancers  Neither  Sinks  ei  al* nor
  Loomis  et  al"  ieportcd -,uch  in-
  creases  Sinks et al1 reported a non-
  significant elevation  m  brain and
  nervous  syiicm  i-anccr-,   Neither
  Brown and Jones.4 Bruwn." Benazzi
  et al.7 or  Tirom cl  al"  found  an
  elevation m hram cancer  These in-
  consistencies v.e,-e discussed m uur
  anicle.
    Bove  ei  at SULC mat w< only  in-
  cluded  a latency-period analysu  for
  all cancers and tor intestinal cancer
  Tnis  was dune primarily  because of
  space limiuiiuns  Cumulative expo-
  sure  und latency tables were  com-
  puted and evaluated for man>  other
  causes of death, including all of the
  cancers of. interest The interpretation
  by Bove  ei  al  that  ihc  intestinal
  cancer SMR  increases to a signifi-
  cant level tor women with 2=20 year*
  of latency ignores the importance of
  examining (he trend associated with
  latency  and  length of employment.
  Furthermore it might be worth not-
,  ing mat r'or women employed tor  10

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   fab-U4-OU  16:13
                 From-
               Volume 41, Numoer 9, Septemoer 1999
               longer *itn a latency period
                     SMR wa^  iuO The
  rT-. individual category-specific SMRs
       cannot be intcryieted us nicunmuful
 ±.--.  wjchout exiiTunution of the  trend
       across cumulative exposure catego-
       ries.  Although the  intestinal cancer
       SMR  fOl  latency  2:20 year* was
       significantly elected, there was no
       significant trend  indicating an  in*
       creoS." in iiSK with Cumulative expo-
       sure or latency, as  discussed m our
       article  Furthermore,  comparison
       witn the regional population resulted
       in a much-reduced SMR iSMK  =
       120; y5* Cl. 74 to 186) for intestinal
|       cancer iii female houiiy workers The
I       regional companion is  more repre-
       sentative because  higher ram of in-
       testinal  cancer are observed among
       me wniie piipuiatjon  or tlie nonh-
       eastern pan of the United States.
        Bove et al rai»e Lonccm* about our
       exposure asses»mcnt Several factors
       need to be recognued when assess-
       in? tne propnct)  oi  uur exposure
      j>«essiT\eiU and uur  use yf lenctti of
      employment *» a >um>sate of expo-
      sure  Workers au.umulaie PCB body
      burdens Over time, whicn persist for
      many year* even atter their occupa-
      tional HCB c^poiure i$ diseonunued.
      To iug^e>t mat PCB body  burdens
      among capacitoi worLcD were com-
      p&rable to those found m the general
      population is unjustified and is not
      supported  by  previously published
data.
          11'"'
               The  feet that workers  in
               plants  had  Significantly
     hisner body burden> than the general
     population has been demonstrated m
     other capauior plants " A» reponed
     in our hniLle. average scrum PCB
     level.; in the general population be-
     twL-cn  1976 ana 1979  were 5 to 7
     pans per billiun (ppt>. ^g/L) '* Geu-
     meinc mean serum PCB levels in GE
     wurkcp* in 1979 (2  yc«r» after PCBs
     were no lunger  used) were  277 ppb
     (K?/U spurred «s Aroeior 1242 and
     55 ppb (HS/U reponed as Aroclor
     1254 In I ¥83, 5 years after lermina-
     tion ot  ihe u»e of PCBs, geometric
     mean \erum levels  were  116 ppb
     IU.JJ/L) foi Aroclor 1242 and 34 ppb
     (Hg/U  fo< Aroclur  1254  In  1988.
  the geometric mean serum PCS lev-
  els were 90 ppb lu.g/L) qujnuuied
  as Aroclur  1242 and  32 ppb (u.$!/U
  quiiuitated a? Aruclor  1254 |S
  Workers preferentially retained  tne
  more persistent congeners MI that tne
  gas chromaiographic pattern of their
  body  burden gradually  approached
  that observed m [he general popula-
  tion,  with primai y retention of  the
  more highly chlorinated, poorly  mc-
  tabolizea congeners '3 The hulf-hvc\
  of the major PCB congeners retained
  in these workers were j> foiiow.%  for
  2.4.4' Uichlorobiphenyl.  1.4 year%
  for 2,4,4'5  tetrachloMbiphenyi,   3 2
  years, for 2.3',4,4',5  pentochlorubi-
  phcny],  5.8   year*,   and   for
  2,2'.4,4',5,5* heAachlorobiphenyl,
  12.4 years.10 Even  though different
  commercial mixture1* oi PCB> were
  used in the capacitor plant*, the con-
  generic Composition Oil a qualitative
  basi»  is similar '7 Produtuun beg^n
  m  1946 with the higniy Lhlorinated
  Aroclor 1254. and small amounts oi
  voclor 1254 were used m  the pidut
  at least through 1971
   The statement that Ln£th of em-
  ployment alone  was an  inadequate
  surrogate  for exposure ana a likely
 source of exposure misda^i'ic-inon
 bias leading to an undeiestirrution  of
 the effect and  a distortion of the
 exposure-response relauonsh.p i< nut
 supported by the lOAitokmetici  of
 PCBs, nor is it an accurate reprcNen-
 ution of the data analy^e^ conducted
 on  our cohort and reported in  the
 article
   Bove et al repon that the majority
 of hourly worker* newei worked m a
 high-exposure job. when in loci 126&
 of the  2984 male hourly employees
 (42 4%) did *ork m a ru»n-exposure
job  Only 13.8% of the female hourly
 employees worked m a  higri-e*pej-
 iure job. not  an  uncomrriun occur-
rence in  an  industrial  Setting  To
*u£»ex that the remaining portion of
the cohon experienced  PCB expo-
sure similar to that  of  me  general
population is not  an accurate repre-
sentation of the  fscis  This  ($ pre-
sented  in the exposure-assessment
section or our article
          T-31Z   P 23/79   F-180

                                743

     Bove ct al state in the opening
  .*>eiiiencv that although the goaJ of the
  study  was to evaluate s(x specific
  caneers. we focused almost entirely
  on all-cancers mortality Table 4 in
  ihe article presents SMRs and 95%
  CIs not unly for the six canccr> of
  iiitcrot but  for  32 other causes of
  death,  including 15 additional can-
  cers  The iji«ue of statistical power is
  raided by Bove et al and 1*0 tables
  were provided These table* were not
  properly referenced  nor  was  the
  meihcdulugy used  to generate these
  calculations  explained It  » unclear
  why an SMR of 150 should be con-
  sideicd  the  "highest expected" for
  tne»e cancers, when previous  publi-
  cations on smaller cohorts reponed
  xatisticaliy significant SMRs well
  above 150 Our study was an attempt
  to evaluate these earlier observations
  m  a larger study with  a longer fol-
  low-up period
    Bove et dl question the decision  to
  limit  tne latency by length of em-
  ployment  calculations to  cancers
  "ith more  than two observed  cases
  and a lower boundary of the 95% Cl
  of  90 or above.  This decision was
  made by the investigators to limit the
  multiple comparison problem and to
  provide more meaningful data, rather
  than to  obscure data. Additionally,
 the lack of  presentation  of  data
 should not be interpreted as the data
 not havmg  been analyzed. All  six  a
 pnun cancers of concern were exam-
 ined carefully; however, publication
 space  is limited  and presenting  a
 thble of latency by cumulative expo-
 Sure for  hver  cancer, for instance.
 with two deaths was deemed unwar-
 ranted
  In their summary statement, Bove
 et al dismiss our study  findings be-
 cause of the HWE effect, failure to
 account  for latency,  exposure  mi»-
 clarification, potentially insufficient
 dosage differences between exposed
 and  comparison groups, and  poor
 st«is»cal  power, yet they still insist
 that  we did  find e»ccs> cancer  risk
 fur three of the six a priori c*ncer> uf
interest and  give credence to those
findings  It is  inconceivable to the

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   T-31Z   P 24/79   F-180
        744

        investigators of [his study how Bove
        a al given (hi) litany of problem^.
        wf re able 10 differentiate the impact
        jnd direction of these  bia*es  with
        Such ceruiiity and specificity
          The authors take exception ro the
        cone of me  letter by Frumkin  and
        Orrib  and find statements  soch as
        ••conspicuously silent" and "willful
        effort to avoid a positive  finding"
        mllammatury and suggest that such
        iUiements do  little  to advance the
        understanding of PCBs  and cancer
        nsk.
          Most of  the  issues  raised  by
        fruniKm  ana Orris  have  been ad-
        drcfecd earlier Their suggestion to
        include more capacitor plants to in-
        crease  puwer  has  mem,  however.
        The General Ekctnc Company  hid
        only the ivvo facilities in upstate New
        York  (Hudson Falls and  Fon  Ed-
        ward; where capacitors  were made
        using PCSs.
          frumkin  and  Orris question
        whether high-exposure jobs actually
        entailed high exposure and raise con-
        cerns  about mi*cla£sificauon  Th«
        exposure miscla»ific:uion suggested
        by Frumkifl and Oms is highly im-
        probable, given the  distinction be-
        tween joos  with  direct  dermal and
        inhalation exposure  and  those  with
        only mnaiatioii exposure to PCB air
        level-, m the puuu. as explained and
        rctcrunccU in  our article Addition-
        ally, the chamuenzaaon  of  thu bias
        u> substantial is unwarranted and is
        an overstatement of the potential ef-
        fect.  Assignment  of exposure  for
        specific job categories was done be-
        fore determination of vital status. At
        both plants, workers  were located in
        the  same building,  and Uie  »ame
        air-ventilating system served me en-
        tire budding  We verified the physi-
        cal  layout by  conducting  a walk
        through the  building and by talking
        to  present and former  employees.
        Many workers had different jobs in
        the  different  exposure  categories
        (high,  undefiruble.  and  low). All
        workers, including  those  in low-
        exposure  jobs,  had significantly
        higher exposures  than the  general
        population, on the basis of PCS  se-
                         rum level-,  reported by  Liwinn ct
                         al.1' br«wn ct al  *'" ana Brown '"
                           The PCB blood levels (from i94
                         and 290 woikers)  mentioned  Dy
                         Frumk.ui anu Oins were ot luiuie-a
                         value in validating art eipO»ui£ jOb
                         matrix rur 7073 wuiTcer*  Although
                         (he joo  histuiie*  and the exposure
                         assignment did confirm (hat worker*
                         in high-c.».puturc jub-> hod high PCB
                         blood levels, these worker* were De-
                         lected cither beuau>e ut their known
                         high-expusme job" or  they  were
                         self-selected'" The hign-exposure
                         jobs were readily identified by plant
                         personnel inU  were confirmed  by
                         PCB  air-ie*ei  r«a«ling>. and  PCB
                         blood  lcvei>  Miidasiification  of
                         job* mtu the hish-exposure category
                         or misclassifyme high-exposure jobs
                         as lower-level exposure jobs was ex-
                         tremely unlikely
                           Frumkin and Oms suggested tfut
                         PCBs are ienuu* health hjuunls. ir-
                         respective  ul  haThinugeniCity  with
                         efr'eci-. ihai  include decreased birth
                         weight, neurodeveiopmental effects,
                         and interference  witn  thyroid  and
                         estrogen honnone function It ha<> nui
                         been shown that PCBs interfere with
                         estrogen-hommne  function  m  hu-
                         mans Studies conducted to e\amme
                         the erici.1% oi PCB> m  mianis  and
                         Children have  been  critically  re-
                         viewed'" '" or could not be support-
                         ed.20 Result; from thyroia function
                         tests  pertormed  in infant* were
                         within  the  normal range  Further-
                         more,  KiKipman-Esseboom et al2'
                         stated.  "The  mean dioxm-likc PCB
                         toxic equivalent levels and the mean
                         total PCB and dioxiu toxic equiva-
                         lent levels of the neurological normal
                         infants  were significantly  higher
                         (p = 0.04 for both) compared with
                         the level*  or  the neurologicaiiy
                         (mildly  or  definitely; abnormal in-
                         fants There wax no relationship be-
                         tween the TT3 (»erum total tniodo-
                         thyroninej.  TT4  (serum  total
                         thyroxme), FT4 (free thyroxme). and
                         TSH (thyroid stimulating normone)
                         levels ni maternal, umbilical, or in-
                         fant pbsma (collected la the second
                         week after binh) and the results  of
                         the  neonatal  neurological rxumiru-
             Leners TO the Editor

 tion» We conLiuJe that overt
 maluies found m tiic neonaui
 are not caused by either direct ciircij
 of PCB or dioxiii expo>urc or low-
 ered thyroid hormone  level-,•  Ac-
 cording to the National Center rur
 Health Siaustics,311 butli wcighr n
 affected by education Of the mtxfter.
 mother's  age.  birth order, interval
 between binhs, gender, uudcnuaic
 prenatal nutnuon. alcohol cuntump-
 uon, smoking,  lack of prenatal cme.
 incidence of elective induction  con-
 traceptive utilization, oui-of-ucdlock
 births,  metropolitan areas  dower).
 and race. The body sue 01* ihe par-
 ents  and maternal illnesses sucn as
 diabetes also play a role. These many
 variables  exemplify the difficulties
 of appropriately designing studies to
 examine  a  single factor  afteciu^
 birth weight Given these uncertain-
 ties  and the published cntui->m-> uf
 studies reporting  "other health ef-
 fects of PCBs " it ha» nut been bun-
 datively  shown  that  PCBs  cauie
 other "serious" health  problems m
 humans.
   We disagree witn the final  ami-
 ment by Frumkin and Oms that this
 study was a great leap  side * ay > on
 the path to a more complete under-
 standing ot  the  health effects  of
 PCBs. Tne issue of PCB; and poiun-
 rial health effect) has been a signifi-
 cant pubhc health concern for  mure
 chan 30 yean The lack of consistent
 findings in the previous cohort  stua-
 ies was asbumed to  have  resulted
 from small  cohort $i2es  and  snort
 follow-up penodi  Given the dispar-
 ate findings m these smaller capaci-
 tor cohorts, the appropriate next >tep
 was to assemble  a larger cohort of
 PCB-cxpoied workers  una examine
 them throughout a longer follow-up
 period. The fact that we were unable
 (o confirm  any  of the previously
reported findings  is important and
adtls  to die knowledge about PCB*
and health effects The a^urnpcion-
tlut  a negative study docs not  pro-
vide  valuable  information  imposes
significant restrictions on the scien-
tific  proce»» and the ability to  aJe-

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FBb-04-00  16:14
From-
        T-312   P 25/79   MIO
             • Volume 41, Numoer 9, Septemoer 1999
                                                                                                                    745
      'quaiely and objectively  assess all
      data.
    *i.1. Errata: The correct number of fc-
     :male salaried workers with a length
     * of employment of 10 to < 15 years *n
      Table 2 is 27; 5.8% is the correct
      percentage.  In Taole 6, line 2, lusi
      column, total SMft for 520 years of
      latency  should be   117.  The total
      number of  workers  in  the  upper
     panel of Table 2 should be 707S

              Renaie D. Kimbrough, MD
              Martha L. Doemiand, PhD
                Maunce E  LtVo.s, PhD
                  tnaitutffor Evaluaium
                            Heullh Bisk
                        Washington. DC

     References
      I. iCmbrousn RD. DoemUna  ML. LeVois
        ME Mortality in male and icnulc capic-
        nor worjcer* expose iu paiyiniorinaied
        Oipnenyb J Ot(»i> Eanrun Mrd  1999
        41:I6|-J71
      2 McMiirhaci AJ SLmuufUuefl mortality
        ntiOt and me  -neaiihy worker effect'
        scratching neneaih Uie MAX* / Oeea/i
        Mea  1976,18:165-165
      3. Checko~«/  H, Pearee  NE. Crawfuru-
        flro*n DJ  bsues of stuoy anign ana
        aalySil In KeSrOrch McrAudf ea to
       polychlenoatcd hphenyit Am J t'piOe-
       mad 1992.135 389-398
     6 Loomis 0. Browning SR. Schenk AP. et
       al Cancer  inoruijij  among ciectncal
       worker* exposed to poiycnionnwed Oi-
       pntnyli 0«v £nv»tun A. et al
       Cancer mortalif/ of capacitor manufkc-
       lunng worker* Am 1 lad M*a  1987.11.
       165-176
     8  Tiionl A. Presaiun A. Consonei 0. et al
       The monalit; of female worker* expoted
       toKBt SpuUaitot Pr«*  1996.20.200-
       202
     y  Brawn OP Jone> J  MOfblny and iiiduv
       Inal nygieue stuOjr of worker* exposed Iu
       poljrcrtjornuka Cipnenyli Arch Ea*trua
       Health 1981J6 120-129
    10  Wolff MS  Fiscnbcin A. Thumion 1. Ri-e
       C. L.l.< R. Selikoff U. Budy Buratn of
       poiycnionniitea Diphcnyb atnunj persoru.
                           employed m capacitor manufaeuiring. hi
                           Areh Oeeup Ea»ren Health 1983:49
                           199-208
                        II  Lawton  RW. ROM  MR. Femfiold  J.
                           Biown JF Jr Effeeb ofPCB exposure gn
                           OiOCflermeal and hernawiogieal findings
                           >n  ckpaeitor workers. Ea»t/«n  Htatih
                           Ptnpn.1 1985^0165-184
                        12  Uwra RW. Brawn JF. Rosi MR. Fan-
                           jjuid J. Comptfibiliiy and preciMon of
                           «rum PCB mcajurementJ. Are* En*run
                           Htulih. 1985.40.29-37.
                        13  Taylor PR. Rellly AA. Sulnu J, Law-
                           rence CE  E«imaung serum polyehion-
                           naieo Oiplienyl levels m hignJy e*po>ed
                           workers an empirical model J Touca
                           £m;mn Htoiilt l99I.34'«]3-«22
                        14  Kimoroush RD.  PoJ/chlorinated  bipne-
                           nyis (PCB*) and human oealdi:  m Sprajue-
                           Ddwiey rab of we polychlorinaied bipne*
                           nyl mikiures Aioeiort 1016, 1242. 1254.
                           ana 1260  TaacolSn. 1998.41:62-76
                       18  Brown JF Jr Determination of PCB mei-
                           kbdlic. exeretion. and Meumubbon rates
                           for ute a» tnojcuon of Oiological re-
                           iponse  anU  relative HM:  En,ito«  sv,
                           TeOimJ  1994:28:2295-2305
                       19 Pinetn N Human reproduction after cat*
                          ms PCBi-ontamiuted fi>n Health £n».
                       21)  Paneth N. Adepnng a public health ap-
                          proach to developmental neuroioticity
                          ft<*rmaueal Ttretol. 1996:18233-234
                       21  Buck CM. Epidemiologic perspcct.ve of
                          ine OevciopmenoJ nciiratoiu'eiiy m PCBs
                          in Duruina Nt*ntojcitvl Ttnmt 1996;
                          m.239-241
                       22  Quo YL, Yu M-LM, Ryan JJ  Oiflfereni
                          congeners of PC8yPCDF» may have
                          coniriDuted to differcai neJtn outcomes
                          m ine YuOieng cohon, te»n,uuxol
                          Ttraol. 1996.18-255-256.
                       23  Schann SL Developmental nturotcuic-
                          it> of PCBs m humans- what oo we know
                          anil wnere do we go from nan?1 Ntun.
                          tutuflTentol 1996:18217-227
                      24  Sauna SL  Response tu eominenurles.
                          feurouuaul Trruiol 1996.18 271-276.
                      25  BunB J. Israel L. Don in uitrv e^pnurc
                          to PCBs ewse oeveiopmental  toaicu;''
                         The  wcupational and environmental
                          medicine report. J Oee»p Eo.,r,,n Hied.
                          I991.H-13-I8.
  26  Crjndjejn P. W«ne P. Wruie RF. et n
      Cojjnm»e deficit in 7-jear-ulo Cliilorcn
      «iin prciuui  ekBOture iu  mwiylmer-
      c«ry  /Vrwuiiuirii/ Teruiat.  |997 19
  27.  Koupman-E^Jebuum  C.  Himmaii M.
     Tuuwen BC ei «I ^tf *bom infants uu«-
     no»ea a<  nearoiojicall,  jenomul »iin
     relation to PCB and diu*m exposure «nd
     men thyroid nomione staiui  D ue%. October i«W National
     Center for Heaiin Stati*tic> Serin 2 1 . No
     48
  Investigation of Elevated Urine Beta-
  2-Microgloouim in a Cohon of
  cadmium women
    To itir Editor  Pnor to (he issuance
 of (he 1993 Occupational  Safety and
 Health  Administrarjon  Cadmium
 Standard,  urine  testing for beu-2-
 micragiobulm (P2mj  v/as  nut fre-
 quently  performeo  Testing tor |5,m
 *as an esutenc  laboratory  test per-
 formed only on worker* w/nosc cad-
 mium levcK  had oeen founo to be
 elevated  The Cadmium  Standard
 mandated that all employees exposed
 to greater than 2 3  ^g/m1 cadmium
 dust or fuinei be tested at least an-
 nually for unne (J2m, as well as for
 blood cadmium (CdB) and unne cad-
 mium  (CdU)  Al a  nickel-cadmium
 battery  manufacturing facility, ap-
 proximately 1000 employees, some
 of whom had been  exposed to cad-
 mium and  some  of whom had not,
 were evaluated for p,m levch.  most
 for the first lime.
   Elevated 0am  was defined  as  a
     level higher  than 300  u>g/g cre-
 uinine1;  expectations u/ere uut ap-
 proximately 10% of workers  with
 cadmium levels higher than 10 n-g/L
 blood or IU u>£/g creaunine would
 al.su show an elevated (J2m level 1-J
 Because 34 employee* had such ele-
 vaied cadmium levels in 1993. it was
 expected  that approximately five or
 six would aUo show elevated (a}m
 levels. It  wa$ not  known how many
employees  with  other condition*

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