&EPA
                          United States
                          Environmental
                          Protection
                          Agency
                    Office of
                    Solid Waste and
                    Emergency Response
Publication 9345.0-051
August 1992
ECO   Update
Office of Emergency Remedial Response
Hazardous Site Evaluation Division (OS-230)
                                                          Intermittent Bulletin
                                                         Volume 1, Number 5
Briefing  the BTAG:  Initial  Description of Setting,
History,  and  Ecology  of  a  Site
   For many  Superfund  sites,  contaminants can cause
ecological harm as well as posing risks to human health.
Part of the responsibility that a Remedial Project Manager
(RPM) mist carry out during the site remediation process
is to assess whether ecological harm has occurred or may
occur.    Many  Regions have  Biological Technical
Assistance Groups (BTAGs) to assist RPMs in managing
such assessments.1
   This Bulletin focuses on the first opportunity that an
RPM has for conferring with the BTAG about possible
ecological effects at a site.  This meeting usually occurs
early in the planning stages in the Superfund process, the
RPM will have the contractor review whatever information
is  readily available about  the site's setting,  history,
contaminants, and ecological characteristics.  The RPM
then makes this information  available to the BTAG as a
site description.  This group's input assists the RPM in
providing the contractor with clear direction for planning a
well-focused investigation: that is, one that has clear-cut -
objectives and that makes the most efficient  use of limited
resources. The RPM should find that expert input at this
early stage results  in long-term savings in both the time
and effort needed to evaluate  a site's ecological  condition.
    These groups are sometimes known by different names, depending
on the Region, and not all Regions have established BTAGs. Readers
should check with the appropriate Superfund manager for the name of Hie
BTAG coordinator or other sources of technical assistance in their
Region. A more complete description of BTAG structure and function is
available in "The Role of BTAGs in Ecological Assessment" (ECO
Update Vol. 1, No. 1).

   2 "Developing a Work Scope for Ecological Assessments" (ECO
Update Vol. 1, No. 4) discusses the process of planning and designing
ecological assessments.
                                Although the initial meeting with the BTAG has the
                              same purpose  and scope throughout EPA Regions, the
                              details of  such a meeting can vary considerably from
                              Region to Region.  When preparing the site description for
                              this meeting, the RPM should contact the Region's BTAG
                              coordinator to learn how  the Region handles  these
                              briefings.

                                          IN THIS BULLETIN

                              Objective of Initial Site Description	1

                              Sources of Information about the Site	2

                              Information in the Site Briefing	2

                              BTAG's Preview	5
                              The Meeting	5
                              BTAG's Recommendations	5
                              Meeting Follow-Up	5
                              Appendix A: Check Sheet	8

                              The  Objective of  the  Initial   Site
                              Description:   Assessing   Whether
                              More   Ecological   Information  is
                              Needed

                                 The initial  site  description begins the process of
                              evaluating  whether a site's contaminants have caused or
                              could later  cause adverse ecological effects. By reviewing
                              readily  available information  about the  site's  setting,
                              history, contaminants, and ecological characteristics, the
   ECO Update is a Bulletin series on ecological risk assessment of Superfund sites. These Bulletins serve as supplements to Risk Assessment Guidance for
Superfund, Volum e II: Environmental Evaluation Manual (EPA/540-1-89/001). The information presented is intended to provide technical information to EPA and
other government employees. It does not constitute rulemaking by the Agency, and may not be relied on to create a substantive or procedural right enforceable by any
other person. The Government may take action that is at variance with these Bulletins

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BTAG  can  assess  whether the  site  requires  further
investigation.  Although little site-specific data may exist
at this stage of the RI, providing the BTAG with  this
information will assist in evaluating the site.

   What types of recommendations can an RPM expect to
hear after presenting the site to  the BTAG?  For some
sites, the BTAG may decide that no significant ecological
impact  has  occurred or  is  likely to  occur  and  that
consequently  the site  requires  no  further ecological
investigation.  In other cases, the BTAG may advise the
RPM to  pursue further ecological  studies.   In these
instances, the BTAG will be able to suggest:

   •   What information is lacking,

   •   Which studies will elicit this information, and

   •   What level of effort is appropriate to obtaining the
       information.
Sources  of Information  about  the
Site

   The investigator  bases the site description for  the
initial  briefing  on information  about the site and  its
surrounding.  Studies and reports already in the  site's
record contain useful  information.  For example, both the
Preliminary Assessment (PA) and the Site Inspections (SI)
can provide a description of the site's geographical setting,
known or suspected contaminants, and general information
about the surrounding area.

   The investigator may also find that State agencies or
local groups have useful information  about the site.  For
example, if the site contains a fishing stream, the State fish
and  game agency may routinely monitor fish species.
University researchers  may  have conducted  biological
surveys  at or  near  the  site.    Environmental  impact
statements concerning nearby facilities  or  projects may
have  additional data on natural  resources in  the area.
Historical  societies, fish and game clubs,  local or State
chapters of such organizations as the Audubon Society or
Nature Conservancy,  and local experts, such as foresters,
soil conservation specialists, and naturalists, also may have
information relevant  to  a  site description.   In  particular,
such groups may have lists of habitats and species found in
the area.

   In some Regions, field reconnaissance trips occur even
at this early stage, with the  RPM, the contractor,  and a
BTAG member visiting the site.  Observing and studying
the site enables the BTAG member to carry back to  the
group   an  expert's  first-hand   observations.    Such
   3 The term "investigator" refers to the individual charged with
responsibility for designing and/or carrying out any part of an ecological
assessment.  Investigators can include government scientists, contractors,
or university scientists. However, the RPM retains ultimate responsibility
for the quality of the ecological assessment.
observations are  especially helpful  at this point  in the
Superfund  process when few, if any, ecological studies
have  occurred.   For  example,  a BTAG  member may
identify dense growth of a species associated with polluted
sites or, alternatively, may note the  absence of expected
species.

   RPMs need to be aware that  Regions vary in their
policies    concerning    field   reconnaissance    visits.
Consequently,  an RPM  who wishes to  have  a  BTAG
member present on such a visit needs to consult the BTAG
coordinator to find out whether and  when this can take
place.


The Information  in the  Site Briefing

   The information contained in a  site briefing varies with
the nature  of the  site and its contaminants, the sources of
information available about the  site,  and  the evaluations
already performed there.  However, an RPM should keep
in mind that the more the BTAG learns about a site,  the
more  specific direction it can offer.  The Appendix at the
end of this  Bulletin provides a check  sheet that RPMs may
wish to use to make certain that the  site description is as
detailed as possible, given the information that is readily
available to the  contractor at this early  stage.  Ii most
cases,  the  site  description  will  lack   some  of  the
information listed in the Appendix.  Such gaps can prove
helpful in  pointing  to  issues  that  may  require  further
investigation.

The  Setting

   A   site's  setting includes its  geographical location
(including coordinates) and its surroundings.  The setting
should include the site's town, county,  and  State and
should describe the land  use of the area around it.  Land
use upstream and downstream of the site  also constitutes
important information about the setting.   Land uses may
include  industrial,  business,   residential,   military,
agricultural, recreational, and  undeveloped.  The  setting
should note especially such natural areas as parks, refuges,
wetlands, and coastal zones.

   The BTAG will also  find helpful  a description  of the
general topography of the  area  associated with the site.
Consequently, the site description should include such
information as whether the site is wooded or open, flat or
hilly,  marshy or dry.  The setting should describe surface
water associated  with the  site,  along with such related
information as the water body's  location,  size, depth, and
flow rate, where applicable.  A description of the aquifer,
the overlying strata, and the ground water discharge  area is
also important  to  the  site's  description.   The  site's
elevation, its size, and its accessibility may prove useful to
know.  Investigators can find some of this information in
the topographical maps published by  the U.S.  Geological
Survey  and in the National Wetlands Inventory  maps.
Geographical  Information  Systems  available  in  the
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Regions  may  also  provide  additional  information  on
natural resources in the  vicinity  of the site.  While the
setting generally  contains several pieces of information,
this description need not be lengthy.

   To  appreciate  the  relevance  of this  information,
consider the following hypothetical examples:

   An abandoned mine.  One Superfund site consisted of
land containing a former nickel mine  and the area that it
had contaminated.  The  RPM's description of the sit
setting indicated  that the site occupied a steep mountain
slope,  which received  heavy  snow cover  in winter.
Contaminants from the mine had leached into streams that
drained the area.   These streams in turn emptied into a
larger stream, which local anglers fished for brook  trout
before it flowed into a National Park.   This description of
the setting alerted the BTAG to several important  facts
about the site:

   •   Because of the slope's steepness, at least part of
       the  site  was not  easily  accessible,  making it
       difficult  and  possibly   costly  to   assess  the
       ecological condition of these parts of the site.

   •   Both heavy  rains  and  the annual  spring  melt
       resulted in continuing migration  of contaminants
       into streams draining the site.

   •   The presence of a National Park down stream from
       the site indicated that site contamination had the
       potential   to  adversely   affect   a   sensitive
       environment.

   An industrial  site.  This consisted  of a small wooded
area bordered  by  several factories.    The  soil  in the
woodland had become contaminated with refuse from the
factories.  No ponds or streams occurred on this flat site.
In addition, the site's geology indicated that ground water
lay below an impervious layer.  Because industrial plants
surrounded the site, the site lacked surface water,  and its
contaminants had no access to ground water, the BTAG
concluded  that off-site migration of contaminants would
occur only through movement of biota.

   A  former landfill.   The  site  consisted of  a  former
landfill  operation located  in a  wetland  that overlay a
shallow aquifer.   Streams from the wetland  fed a  river
protected by the State.  Residences and industrial facilities
occupied the properties adjacent to the landfill. From this
description, the BTAG concluded that:

   •   As a wetland, this site merited special concern;

   •   The  streams  provided  a  means   of  off-site
       contaminant migration to the surrounding area;

   •   Migration of contaminants into the aquifer could
       occur, with any  discharge  of  ground water into
       surface water further spreading the contaminants;
       and
   •   The  river constituted  a  sensitive environment
       because it was a body of water designated by the
       State for protection of aquatic life.
The Site's History

   The site's history includes information about the events
that have resulted in its being designated a Superfund site.
In  general,  the PA  and  the  SI  recount  the  site's
contaminant  history, indicating both the activities  that
caused the contamination and the length of time  over
which these activities occurred.  As with the setting, this
information helps the BTAG to develop a picture of the
site.     In  addition,  such   information  can   indicate
contaminants potentially associated with the site.  Consider
again the three hypothetical  Superfund sites  described
above.

   The abandoned mine.  The old mining site had been
worked for 30 years before its closing.  For more than 30
years, then, tailings had been exposed on the mountainside.
From  this   information,  the  BTAG discerned  that
contaminants from the mine had had many years to leach
into the soil,  the streams that drain the mountainside, and
the sediments in these streams and that contamination was
on-going.

   The industrial  site.   The  contaminated  woodland
surrounded by factories had had a shorter but more diverse
history of contamination than the nickel mine.  Industrial
activities,   including    electroplating   and    plastics
manufacture,   had   been  occurring   in  the  buildings
surrounding the site for  15 years.   In general, the plants
had accurate  records of the chemicals and the amounts
they  had  used.    From this information,  the  BTAG
concluded that it had a clear and complete account of the
site's history  and required no further information on the


   The former  landfill.  The landfill site  presented  a
different picture.  Few  records existed to  show  which
chemicals the facility received and in  what amounts.  The
RPM learned  that  the   operation did not dispose  of
contaminants properly, frequently pouring liquid wastes
directly onto  the ground.  This sketchy history alerted the
BTAG that they could only guess at the precise nature and
extent of contamination.

The Contaminants of Concern

   The BTAG will want  to know what contaminants are
associated with the site and in which media and in what
concentrations they occur. The RPM  should also provide
the BTAG with the results of chemical analyses that have
already been  performed  at the  site.  The BTAG will want
to know  where samples were  collected  and,  where
applicable, at  what  depth(s).   The contractor  should
research whether the contaminant levels exceed Federal
Ambient Water  Quality  Criteria,  State  Water Quality
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Standards, or other widely accepted screening values. The
BTAG,  in  turn,  may  compare  a  site's  contaminant
concentrations with concentrations known to cause adverse
ecological effects to biota.

   If a site  has a large number of contaminants, tracking
all of them may prove unwieldy. The BTAG may be able
to advise the RPM as to which contaminants to choose as
contaminants of concern.  Alternatively, the BTAG may
advise that additional analyses be performed to document
the presence of certain contaminants at specific areas of
the site or in various media.

   The abandoned  mine.   At the old mining site, the
BTAG recognized that soil, surface  water, and sediment
were  all potentially contaminated with metals.  Since the
chemical analyses  performed  during the SI concentrated
mainly  on  surface water, the BTAG  advised chemical
testing of soil and sediment.  In addition, the analyses of
surface water  lacked  a  reference  site,  so the  BTAG
suggested that future analyses include an upstream water
sample.

   The industrial site.  Because of the variety of industrial
facilities adjacent  to the  site, the initial site chemistry
included both inorganics and organics. Since some of the
organics were volatile,  the SI  had  analyzed air as well as
soil.  The variety of contaminants present at this site made
it advisable  for any future ecological assessment to focus
on a subset  of the contaminants. To this end, the BTAG
advised the  RPM as to which chemicals to consider the
contaminants of concern.

   The former  landfill.  Because of the sparse history of
the  landfill, the  BTAG regarded   both organics and
inorganics as potential  contaminants  and soils, sediments,
surface  water,  and  air  potential  contaminated  media.
Consequently, the BTAG advised chemical analyses more
extensive than those conducted as part  of the SI.  The
BTAG also  suggested that the RI examine contamination
of the river. As at the woodland site, this site had  a large
number of contaminants, and the BTAG offered the RPM
advice on selecting contaminants of concern.

Ecological  Description

   This part of the site description helps the BTAG decide
whether the contaminants and  their history at the site
represent a potential  for ecological harm  to the area
associated with the site.  In preparing this description, the
RPM  should  make  full use of  all  readily available
information.

   Central to an ecological description is  a list  of the
habitats, which are types of environments, associated with
a site.  These include  wetlands, woodlands, grasslands,
open fields,  ponds, streams, estuaries, coastal zones, and
other natural areas.

   The  ecological  description also  includes geological
information, such as hydrology, sediment types, and soil
types.    Consequently,  the  RPM  needs  to  describe all
surface  waters—lakes, ponds, rivers, streams (including
intermittent  streams), and flood plains—in greater detail
than was required for the site's setting.  The topographical
maps published by the U.S. Geological Survey can provide
much of this information.   Maps providing  information
about floodplains include the Flood Insurance Rate Maps
and the Flood Hazard Boundary Maps published by the
Federal  Emergency  Management Agency.   For  areas
largely  owned by the  State or Federal  government, the
controlling  agency  generally  has   information  about
floodplains.  The SI may  contain measurements of soil and
sediment parameters. Such information enables the BTAG
to decide whether the contaminants of concern are likely to
adsorb to the site's soil and sediment.

   Whatever information the RPM has about plants and
animals in the  site-associated area also belongs in the
ecological description.  In addition to species spending all
or most of their time in the  site-associated area,  this
information  should  include  migratory species using the
area during  only part of  their life cycle.  Some sites may
have species of special  interest,  such as game species,
Federal- or State-listed endangered or threatened species,
or species protected under other statutes.

   The  abandoned mine.  An ecological description of the
old mining site showed that it had no ponds or lakes but
did contain  a number  of fastflowing streams  with hard,
gravelly sediments.   The fishing stream into which these
emptied had finer sediments.   This  information led the
BTAG to conclude that the streams with the gravelly beds
probably had little or no adsorbed contaminants but the
fishing  stream's  finer  sediments may have  adsorbed
contaminants from the water column.   As to the area's
biota, State  surveys indicated that brook trout, minnows,
dace, shiners, and suckers all inhabited the streams.  The
local  Audubon chapter  provided  a  list  of bird species
sighted  in the  area.   Hunters  routinely took deer  and
occasionally bear.   The team  that  made  the site  visit
reported spotting  several squirrels and diipmunks and
noted that vegetation consisted largely of pine and birch
trees  with limited  undergrowth.   The  flora and fauna
described for the site held no surprises for the BTAG.

   The  industrial site.  While researching the  site, the
investigator learned that a State-listed endangered species
inhabited  woodlands in  this  general area,  raising  the
possibility that the site could be home to members of this
species.  With respect to vegetation, pine trees dominated
the site, which also contained grasses  and  shrubs.  In
places the dry  sandy soil was bare  of vegetation.  The
BTAG suggested  that the RPM have additional chemical
analyses performed  on soil samples from this  part of the
site.   No  readily  available information existed as to the
site's resident animals.

   The former landfill. Because this area was a wetland,
the BTAG  had  concerns  about potential  cross-media
contamination between  soil and  surface  water.   With
respect  to vegetation, the SI noted that shrubs and grasses
dominated the  area's vegetation  and that the pollution-
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tolerant marsh plant Phragmites grew abundantly at the
site.

Known Ecological  Effects

   In   addition   to   the   ecological  description,  the
investigator  may  have  information  about  known  or
suspected ecological harm at a site.  For example, the site
may  have an  abundance of a "nuisance" or pollution-
tolerant species.  Alternatively, an expected species may
be absent, or present only in small numbers.  Local  sport
and nature groups or State agencies may have information
about changes in the  condition or abundance of certain
species.

    The abandoned mine.  In the course of routine surveys
of the fishing stream, the  State noted that a decline in the
population of several species,  including brook trout, had
occurred over the past ten years.

   The industrial site.  The bare areas of the woodland site
gave evidence of ecological impact.

   The  former  landfill.    The  abundant  growth  of
Phragmites,  known  for  its  association  with polluted
wetlands, suggested a disturbed ecological condition.

   At  this  stage of  the  investigation,  the  available
information can only suggest possibilities for future study.
Demonstrating a causal link between site contaminants and
ecological effects requires  considerably more evidence.


The  BTAG's Preview

   In many  cases, this briefing represents the first time
that the BTAG has encountered the site.  Having materials
ahead of time enables the group's members to familiarize
themselves with the site. By providing these materials, the
RPM enables  the  BTAG to give more thoughtful and
informed  advice  about  handling  the  site.   BTAG
coordinators have indicated that members sometimes take
this opportunity to consult additional outside experts.

   Precisely which materials the BTAG members ask to
preview varies considerably among the Regions.  These
documents could include the documents relating to the site,
such as the PA and the SI; all materials that will be used at
the meeting; or a "distilled" version  of these materials.
The RPM will need to check with the BTAG coordinator
to find out which materials to supply.

   At the very least, however, the RPM should provide the
BTAG with  a brief description and history of the site.
Many BTAG coordinators indicate that members find a
copy of the SI helpful  at this time. In addition, a map of
the site helps in following the details of a site  description.
The RPM should include among the pre -meeting materials
the reasons  for the  site's listing  and any additional
information that has expanded the reasons for the listing.
The Meeting

   EPA Regions have developed two ways of dealing with
the BTAG's first meeting concerning a site.   In some
Regions the RPM introduces the site in a presentation that
generally  lasts  no  longer  than  30  minutes.    The
presentation covers the  information that  the  RPM has
assembled:  the  site's  setting,  history,   contaminants,
ecological description,  and any  evidence  of  ecological
impact.  BTAG coordinators indicate that members find
maps and photographs particularly useful visual aids at
these briefings.    Maps should  show  the  source  of
contamination, the direction in which  it is moving, and the
nearest potentially exposed habitats (Figure 1).

   In other EPA Regions, the BTAG gathers specifically
to discuss the  SI or the  document on which the RPM is
currently working.  Here  the RPM does not make a formal
presentation.   Instead, he or she attends the meeting to
answer questions and to hear the BTAG's input first hand.
Even in these  Regions, however, the BTAG may  expect
the RPM to present a brief description of the site's setting
and a short account of its contaminant history.
The BTAG's Recommendations

   An important part of this initial meeting is the open
discussion, during which BTAG members ask questions
and develop suggestions for the site.  At this time,  the
BTAG will offer its advice.

   •   The group may  decide that a site does not pose a
       significant present  or future  ecological  risk.   In
       such a case, the BTAG will advise the RPM that
       the site does not require any further ecological
       assessment.

   •   Before deciding what to recommend with regard to
       future  ecological studies, the BTAG may decide
       that the group needs more information.   In this
       case the  BTAG's  recommendation  will  include
       suggestions as to the studies that could provide the
       additional information.

   •   The BTAG's evaluation of the available data may
       lead it to conclude that the site has a significant
       potential for ecological impact and should undergo
       an ecological assessment.  The  BTAG will then
       offer advice  on the  types of studies that will elicit
       pertinent  information  and  the  level   of  effort
       commensurate with  the adverse effect suspected.
Follow-Up of the  Meeting

   After the meeting has ended, the RPM will most likely
want a written record of the meeting's results. How such a
record comes into existence varies with the Region.   In
some Regions,  the RPM receives a copy of the minutes or
memorandum prepared by  one or more members of  the
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BTAG.  This document provides the RPM with a copy of
the BTAG's recommendations in the BTAG's own words.
Other   Regions  have  the   RPM  prepare  minutes,
summarizing both the presentation (if one occurred) and
the BTAG's advice.  BTAG coordinators in these Regions
say that this approach enables them to confirm that the
RPM has understood the group's suggestions. Regardless
of who  prepares the record, it is  generally  available no
later than two weeks following the meeting.
    The record of this first meeting constitutes a succinct
description of the site, its contaminant history,  and the
BTAG's  initial recommendations.   RPMs may wish to
copy this record, along with a map, to BTAG members to
refresh their memories about a site the next time it comes
up for review.  Alternatively,  RPMs can accomplish the
same  end by  copying  the check sheet (see Appendix) to
BTAG members.
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A Map Style Useful for the Initial Site Briefing
                          Figure 1
    visualiiing a Superfundshe with which ffiey are unfamiliar.
    Arrows indicate the direction in which runoff flows.
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ECO Update

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Appendix A:  Check Sheet for Ecological Description of Site
   Setting
   1.   What are the land uses/facilities in the vicinity of the site?
               North	
               South	
               East
               West
        What directions do contaminant gradients follow?
               Surface water, sediment	
               Soil
               Ground water
   2.   What is the site's highest elevation?_
       What is the site's lowest elevation?
   3.    Is the site readily accessible? 	Yes   	No
        If No, explain:	
   4.   For each pair of descriptors, circle the one that best describes the site.
               Wooded/open          hilly/flat         marshy/dry
               Other
   5.    Does the site contain or drain into surface water? 	Yes  	No
        If Yes what type(s)?
               Pond or lake:
                       Location	
                       Area
                       Average Depth (or depth range)_
               Stream or River (including intermittent streams):
                       Location	
                       L ength	
                       Average Width (or width range)_
                       Average Depth (or depth range)_
                       Type(s) of bottom	
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                        Flow rate	

                Estuary/embayment:
                        Location	
                        Area
                        Average Depth (or depth range)_
                        Type(s) of bottom	
                List any known parameters of site-associated surface water:
                        PH	   Temperature	  Dissolved Oxygen_
                        Total Suspended Solids	
                        Total Organic Carbon	
                        H ardne s s	
                        Salinity
                        Other (specify)_
                List any known sediment parameters of site-associated bodies of surface water:
                        Sediment type(s)	
                        Grain Size	  pH	   Eh	  pE_
                        Total Organic Carbon	
                        Acid-Volatile Sulfides_
                        Other (specify)	
                        (If more than one surface water body of each type, repeat information as needed.)

   6.   Does the site contain or drain into wetlands?   	Yes	No
        If Yes, what type(s) and size(s)?
        List any known surface water and sediment parameters of site wetlands, as in #5, above.

7.       Describe sub-surface hydrology.
        Overlying strata	
        Aquifer	
        Depth of aquifer_
        Location of groundwater discharge_
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Ecological  Description
        List and describe habitats that occur at the site.
               Woodlands
                Grasslands/open fields_
                Wetlands	
                Ponds
                Streams_
                Estuaries
                Coastal zones_
                Flood plains_
                Other natural areas
         List any known soil and sediment parameters for each terrestrial habitat.
                Soil type(s)	
                Grain Size	   pH	  Eh	  pE_
                Total Organic Carbon	
                Total Phosphorus	
                Nitrogen forms	
                Other
9.       Are any Federally or State listed endangered or threatened species known or suspected to occur on or near the site?
             Yes       No
        If yes, list:
10.      Does the site have any game species or species of interest for another reason?   	Yes	No
        If yes, list:
August 1992 • Vol. 1, No. 5                               10                                        ECO Update

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Known  Ecological Effects
11.     Does the site show any evidence of adverse ecological effects?  	Yes  	No
       If yes, list:
12.     Documentation attached:
       	Site map(s)
       	PA
       	SI
       	Contaminant concentration data
       	Species list(s)
       	Preliminary Natural Resources Survey (PNRS)
       	Other (specify)	
August 1992 • Vol. 1, No. 5                             11                                     ECO Update

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