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
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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
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
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THIS PAGE LEFT INTENTIONALLY BLANK.
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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
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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).
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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.
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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
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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,
TAMS/Gradient Corpi.itition
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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
-------
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.
TAMS/Crac/ienr Corporation
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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).
TfiMSICradtent Corporation
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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.
TAMSICradient Corporation
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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.
TAMS/Cnu/ienr Corporation
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REFERENCES
Agency for Toxic Substances and Disease Registry (ATSDR). 1999. lexicological Profile for
Polychlorinated Biphenyls (Update). Draft for Public Comment. U.S. Department of Health and
Human Services.
Arnold, D., F. Bryce, P. McGuire, R. Stapley, J. Tanner, E. Wrenshall, J. Mes, S. Fernie, H.
Tryphonas, S. Hayward, and S. Malcolm. 1995. Toxicological consequences of Aroclor 1254
ingestion by female rhesus monkeys. Part 2 Reproduction and infant findings. Food Chem
Toxicol. 33:457-474.
Bakerman. 1994. ABC's of Interpretative Laboratory Data, 31*1 edition, Interpretive Laboratory
Data, New York.
Barclay, B. 1993. Hudson River Angler Survey. Hudson River Sloop Clearwater, Inc.,
Poughkeepsie, New York.
Bove, F.J., B.A. Slade, and R.A. Canady. 1999. Evidence of Excess Cancer Mortality in a
Cohort of Workers Exposed to Polychlorinated Biphenyls. Journal of Occupational and
Environmental Medicine 41(9):739-740.
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 University, Ithaca, New York. Report for the New York Sea
Grant Institute Project No. R/FHD-2-PD, September. (Raw survey data also received
electronically from study authors.)
Connelly, N.A., B.A. Knuth, and T. Brown. 1996. Sportfish consumption patterns in Lake
Ontario anglers and the relationship to health advisories. N. Am. J. Fisheries Management 16:90.
Eastern Research Group (ERG). 2000. Report on the Peer Review of the Revised Baseline
Modeling Report for the Hudson River PCBs Superfund Site. Prepared for the US
Environmental Protection Agency, Region H May 10.
Ebert, 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. Fisheries Management 13:737-
745.
Frumkin, H., and P. Orris. 1999. Letter to the Editor. Journal of Occupational and
Environmental Medicine 41(9):741-742.
Kimbrough, R.D., M.L. Doemland, and M.E. LeVois. 1999a. Mortality in male and female
capacitor workers exposed to polychlorinated biphenyls. J Occupational Environmental
Medicine 41(3):161-17'1.
TAMSlCradient Corporation
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Kimbrough, R.D., M.L. Doemland, and M.E. LeVois. 1999b. Authors' Reply to Letters to the
Editor. Journal of Occupational and Environmental Medicine 41(9):742-745.
New York State Department of Health (NYSDOH). 1999. Health Consultation: 1996 Survey of
Hudson River Anglers, Hudson Falls to Tappan Zee Bridge at Tarrytown, New York. February
(Raw survey data received electronically from Edward Horn of NYSDOH in June, 1998.)
Rice, D.C. 1999. Behavioral impairment produced by low-level postnatal PCB exposure in
monkeys. Environ. Res. Sec. A. 80:S113-S121.
U.S. Environmental Protection Agency (USEPA). 1984. Record of Decision for the Hudson
River PCBs Site. U.S. Environmental Protection Agency, New York, New York.
U.S. Environmental Protection Agency (USEPA). 1989a. Exposure Factors Handbook. Office
of Health and Environmental Assessment, Washington, DC. EPA/600/8-89/043, July.
U.S. Environmental Protection Agency (USEPA). 1989b. Risk Assessment Guidance for
Superfund (RAGS), Volume I. Human Health Evaluation Manual (Part A). USEPA, Office of
Emergency and Remedial Response, Washington, D.C. USEPA/540/I-89/002, December.
U.S. Environmental Protection Agency (USEPA). 1990 National Oil and Hazardous Substances
Pollution Contingency Plan, Final Rule, codified as amended at 40 C.F.R. Part 300.
U.S. Environmental Protection Agency (USEPA). 1991a. "Risk assessment guidance for
Superfund. Volume I: Human health evaluation manual - Supplemental Guidance: Standard
default exposure factors." Office of Emergency and Remedial Response (Washington, DC).
OSWER Directive 9285.6-03; NTIS PB91-921314.20p. March 25,1991.
U.S. Environmental Protection Agency (USEPA). 1991b. Phase 1 Report - Interim
Characterization and Evaluation, Hudson River PCB Reassessment RI/FS. Prepared for USEPA
Region n by TAMS Consultants, Inc. and Gradient Corporation. USEPA, Region n, New York,
New York.
U.S. Environmental Protection Agency (USEPA). 1992. "Guidance on Risk Characterization
for Risk Managers and Risk Assessors." Memorandum from F. Henry Habicht, ffl Deputy
Administrator to Assistant Administrators and Regional Administrators. USEPA, Office of the
Administrator, Washington, DC.
U.S. Environmental Protection Agency (USEPA). 1993. Science Advisory Board Review of
Office of Solid Waste and Emergency Response "Draft Risk Assessment Guidance for Superfund
(RAGS), Human Health Evaluation Manual (HHEM)," EPA-SAB-EHC-93-007, Science
Advisory Board, Washington, D.C., 1993.
TAMS/Gnuftenr Corporation
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U.S. Environmental Protection Agency (USEPA). 1995. "USEPA Risk Characterization
Program." Memorandum from Administrator Carol M. Browner to Assistant Administrators,
Associate Administrators, Regional Administrators, General Counsel and Inspector General on
March 21,1995, Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 1996a. Proposed Guidelines for Carcinogenic
Risk Assessment. Office of Research and Development, Washington, DC. EPA/600/P-92/003C.
April.
U.S. Environmental Protection Agency (USEPA). 1996b. PCBs: Cancer Dose-Response
Assessment and Applications to Environmental Mixtures. National Center for Environmental
Assessment, Office of Research and Development. Washington, DC, September.
U.S. Environmental Protection Agency (USEPA). 1997a. Exposure Factors Handbook, Volume
I-m. Office of Research and Development, USEPA/600/P-95/002Fa, August.
U.S.. Environmental Protection Agency (USEPA). 1997b. 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.
U.S. Environmental Protection Agency (USEPA). 1997c. Volume 2C - Data Evaluation and
Interpretation Report, Hudson River PCBs Reassessment RI/FS. Developed for the USEPA and
U.S. Army Corps of Engineers by TAMS Consultants, Inc., The Cadmus Group, Inc. and
Gradient Corporation. USEPA, Region H, New York, New York.
U.S. Environmental Protection Agency (USEPA). 1998a. Community Relations in Superfund:
Handbook, Interim Version.
U.S. Environmental Protection Agency (USEPA). 1998b. Phase 2 - Human Health Risk
Assessment Scope of Work. Developed for the USEPA and U.S. Army Corps of Engineers by
TAMS Consultants and Gradient Corporation. USEPA, Region H, New York, New York. July.
U.S. Environmental Protection Agency (USEPA). 1999a. Volume 2F-A - Human Health Risk
Assessment for the Mid-Hudson River, 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. December.
U.S. Environmental Protection Agency (USEPA). 1999b. Volume 2F - Human Health Risk
Assessment for the Upper Hudson River, 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. August.
U.S. Environmental Protection Agency (USEPA). 1999c. 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 H, New York, New York.
TMASlGradient Corporation
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U.S. Environmental Protection Agency (USEPA). 1999d. Responsiveness Summary for the
Phase 2 - Human Health Risk Assessment Scope of Work. Developed for the USEPA and U.S.
Army Corps of Engineers by TAMS Consultants and Gradient Corporation. USEPA, Region n,
New York, New York. April.
U.S. Environmental Protection Agency (USEPA). 1999e. Rogers Island Human Health Risk
Assessment. USEPA, Region n. July.
U.S. Environmental Protection Agency (USEPA). 1999f. "Integrated Risk Information System
Chemical File for Aroclor 1016." National Center for Environmental Assessment, Cincinnati,
Ohio.
U.S. Environmental Protection Agency (USEPA). 1999g. "Integrated Risk Information System
Chemical File for Aroclor 1254." National Center for Environmental Assessment, Cincinnati,
Ohio.
U.S. Environmental Protection Agency (USEPA). 1999h. "Integrated Risk Information System
Chemical File for Polychlorinated Biphenyls." National Center for Environmental Assessment,
Cincinnati, Ohio.
U.S. Environmental Protection Agency (USEPA). 1999L "Risk Assessment Guidance for
Superfund Volume I - Human Health Evaluation Manual Supplemental Guidance Dermal Risk
Assessment Interim Guidance." Office of Emergency and Remedial Response, Washington, DC.
March, 1999. Draft.
U.S. Environmental Protection Agency (USEPA). 2000a. Responsiveness Summary for Volume
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.
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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
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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
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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
-------
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
-------
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
-------
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
-------
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.
-------
• 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.
-------
• 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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New York State Angler Cohort
Buck, G.M., L.E Sever, P. Mendola, M. Zielezny, and IE. Vena. 1997. Consumption of
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Buck, G.M., P. Mendola, J.E. Vena, L.E. Sever, P. Kostyniak, H. Greizerstein, J. Olson, and FJD.
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Mendola, P., G.M. Buck, L.E. Sever, M. Zielezny, and IE. Vena. 1997. Consumption of PCB-
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OswegoTNY Newborn and Infant Development Project
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Courval, J.M., J.V. DeHoog, A.D. Stein, EM. Tay, J. He, H.E.B. Humphrey, and N. Paneth.
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Dutch FCB/PCDD Project
Huisman, M, C. Koopman-Esseboom, V. Fidler, M. Hadders-Algra, C.G. van der Paauw,
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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.
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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
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Koopman-Esseboom, C., N. Weisglas-Kuperus, M.A.J. de Ridder, C.G. Van der Paauw,
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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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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
-------
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
-------
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.
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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
-------
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
-------
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
-------
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
-------
National Academy of Sciences
Report on
SEAFOOD SAFETY
National Academy Press, Washington, D.C.
1991
-------
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
-------
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
-------
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.
-------
^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
-------
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.
-------
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
-------
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
-------
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
-------
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.
-------
• 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.
-------
•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
-------
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
-------
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.
-------
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,
-------
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
-------
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
-------
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
-------
(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.
12
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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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Flfa-04-00 16:12
From-
T-112 P 19/79 F-1BO
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
-------
Fdb-04-00 16:12 Fronr
T-312 P 20/79 F-180
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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Fib-04-00 16:12 From-
T-312 P 21/79
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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Ftb-04-00 16:13
Frora-
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
-------
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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Fron-
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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