Charge for the Ecological Risk Assessment Peer Review for the Rest of the Housatonic River

7/11/2003

CHARGE FOR THE ECOLOGICAL RISK ASSESSMENT
PEER REVIEW FOR THE REST OF THE HOUSATONIC RIVER

Background

In October 2000, the U.S. District Court approved and entered a Consent Decree agreed to by the
General Electric Company (GE), the U.S. Department of Justice, the U.S. Environmental
Protection Agency (EPA), the Commonwealth of Massachusetts, the State of Connecticut, the
U.S. Department of the Interior, the National Oceanic and Atmospheric Administration, the City
of Pittsfield, and the Pittsfield Economic Development Authority for the remediation and
restoration of the GE facility in Pittsfield, MA, and other properties and areas affected by
releases of polychlorinated biphenyls (PCBs) and other contaminants of potential concern
(COPCs) from that facility, including the Housatonic River.

Under the Consent Decree, EPA is to conduct an Ecological Risk Assessment (ERA) for the
portion of the Housatonic River and its floodplain beginning at the confluence of the East and
West Branches of the river (approximately two miles downstream of GE's facility in Pittsfield)
and continuing downstream. That stretch of the river and floodplain is known in the Consent
Decree as the Rest of River. EPA has completed the ERA for the Rest of River. The Consent
Decree provides that this ERA will be subject to Peer Review by a Peer Review Panel. This
document provides the charge for the Peer Review of the ERA for the Rest of River.

Objective and Scope of ERA

The objective of the ERA is to characterize and, where appropriate, quantify the risks to biota in
the absence of remediation from exposure to PCBs and other contaminants from the GE facility
that are found in the sediment, surface water, riverbank and floodplain soil, and tissue in the Rest
of River area.

To achieve this objective, EPA performed an ecological characterization of the Rest of River and
surrounding areas and, subsequently, the ERA. The ERA has four major components: (1)

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Problem Formulation; (2) Exposure Assessment; 3) Effects Assessment; and (4) Risk
Characterization. Assessment endpoints and supporting measurement endpoints were identified
in the Problem Formulation for the following receptors: benthic invertebrates, amphibians, fish,
birds (including insectivorous and piscivorous birds), mammals (including piscivorous and
omnivorous/carnivorous mammals), and threatened and endangered species. Where possible
and/or appropriate, three lines of evidence were evaluated for each endpoint; field studies, site-
specific toxicity studies, and a comparison of exposure and effects. A weight-of-evidence
approach (Menzie et al. 1996) was used to evaluate the lines of evidence for each assessment
endpoint.

Summary of Charge to Peer Review Panel

The Consent Decree specifies that the Peer Review Panel is to review EPA's ERA to evaluate:
"(1) consistency with EPA policy and guidance; (2) the protocols applied in the studies used in
the risk assessment; (3) interpretation of information generated from the studies included in the
risk assessment; and (4) the report conclusions." In addition, Appendix J to the Consent Decree
specifies that an opportunity will be provided to GE and other members of the public to submit
written comments and make oral presentations to the Peer Review Panel on issues relevant to the
Peer Review charge for the Panel members' consideration.

Questions to be Addressed by the Peer Review Panel

In evaluating the general items specified in the Consent Decree listed above, the Peer Review
Panel members shall give specific consideration to the questions listed below. In considering
these questions, the Panel members shall evaluate the following (hereinafter the "evaluation
criteria"): the objectivity, consistency, and reasonableness of both the procedures and inputs used
by EPA in the application of existing EPA guidelines, guidance, and policy; and those used by
EPA in the absence of Agency guidelines, guidance, or policy (see Attachment A for the list of
relevant EPA guidelines, guidance, and policy documents). If significant errors are observed in
the application of the appropriate methodologies, the Panel members shall provide specific
comments, describing the error(s) and suggested improvements. The suggested improvements
must be specific, clear, and consistent with existing EPA methodologies and guidelines.

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It is not expected or intended that the Peer Review Panel members will reach consensus on all
issues. For those issues for which consensus is not reached, the range of opinions of the Panel
members should be stated and summarized. The Panel members should identify any major data
or methodological gaps that may impact the use of this risk assessment for decision-making.
However, it must be realized that, while additional long-term research may be desirable to
address some questions, it is outside the purview of both the Risk Assessment and this Peer
Review.

In evaluating the general items specified in the Consent Decree listed above, the Peer Review
Panel members shall give specific consideration to the following questions:

1.	Was the ecosystem of the Housatonic River watershed properly characterized, and was
this information appropriately applied in the Problem Formulation and subsequently in
the ERA?

2.	Was the screening of contaminants of potential concern (COPCs), selection of assessment
and measurement endpoints, and the study designs for these endpoints appropriate under
the evaluation criteria?

3.	For each of the 8 assessment endpoints evaluated in the ERA (listed in Attachment B, and
for which a specific Section and Appendix was prepared), address the following
questions (discuss and label responses as 3.{assessment endpoint number).{question
letter) for consistency):

(a)	Were the EPA studies and analyses performed (e.g., field studies, site-specific
toxicity studies, comparison of exposure and effects) appropriate under the
evaluation criteria, and based on accepted scientific practices?

(b)	Were the GE studies and analyses performed outside of the framework of the
ERA and EPA review (e.g., field studies) appropriate under the evaluation
criteria, based on accepted scientific practices, and incorporated appropriately in
the ERA?

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(c)	Were the estimates of exposure appropriate under the evaluation criteria, and was
the refinement of analyses for the contaminants of concern (COCs) for each
assessment appropriate?

(d)	Were the effects metrics that were identified and used appropriate under the
evaluation criteria?

(e)	Were the statistical techniques used clearly described, appropriate, and properly
applied for the objectives of the analysis?

(f)	Was the characterization of risk supported by the available information, and was
the characterization appropriate under the evaluation criteria?

(g)	Were the significant uncertainties in the analysis of the assessment endpoints
identified and adequately addressed? If not, summarize what improvements
could be made.

(h)	Was the weight of evidence analysis appropriate under the evaluation criteria? If
not, how could it be improved?

(i)	Were the risk estimates objectively and appropriately derived for reaches of the
river where site-specific studies were not conducted?

(j) In the Panel members' opinion, based upon the information provided in the ERA,
does the evaluation support the conclusions regarding risk to local populations of
ecological receptors?

4.	Are the summary discussions and conclusions in the ERA supported by the information
provided in the report, and did the conclusions describe the risks in an objective,
reasonable, and appropriate manner?

5.	To the best of the Panel's knowledge, is there other pertinent information available that
was not considered in the ERA? Is so, identify the studies or data that could have been
considered, the relevance of such studies or data, and how they could have been used in
the ERA.

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ATTACHMENT A

List of Relevant Ecological Risk Assessment Guidelines. Guidance, and Policy Documents

Menzie, C., M.H. Henning, J. Cura, K. Finkelstein, J. Gentile, J. Maughan, D. Mitchell, S.,

Petron, B. Potocki, S. Svirsky, and P. Tyler. 1996. Special report of the Massachusetts
Weight-of-Evidence Workgroup: A weight-of-evidence approach for evaluating
ecological risks. Human Ecol. Risk Assess. 2(2): 277-304.

U.S. Environmental Protection Agency (EPA). 1991. Ecological Assessment of Superfund Sites:
An Overview, ECO Update, \olume 1, Number 2. Washington, DC. U.S.

Environmental Protection Agency (EPA).

U.S. Environmental Protection Agency (EPA). 1992. The Role of Natural Resource Trustees in
the Superfund Process, ECO Update, Volume 1, Number 3. Washington, DC: Risk
Assessment Forum.

U.S. Environmental Protection Agency (EPA). 1992. Framework for Ecological Risk

Assessment. EPA/630/R-92/001. Washington, DC: Risk Assessment Forum. February.

U.S. Environmental Protection Agency (EPA). 1993. Wildlife Exposure Factors Handbook,
Volumes I and II. EPA 600/R-93/187a and 187b. Washington, DC: Office of Research
and Development. December.

U.S. Environmental Protection Agency (EPA). 1994. Using Toxicity Tests in Ecological Risk
Assessment, ECO Update, Volume 2, Number 1. Washington, DC: Office of Solid
Waste and Emergency Response.

U.S. Environmental Protection Agency (EPA). 1994. Catalogue of Standard Toxicity Tests for
Ecological Risk Assessment, ECO Update, Volume 2, Number 2. Washington, DC:

Office of Solid Waste and Emergency Response.

U.S. Environmental Protection Agency (EPA). 1994. Field Studies for Ecological Risk
Assessment, ECO Update, Volume 2, Number 3. Washington, DC: Office of Solid
Waste and Emergency Response.

U.S. Environmental Protection Agency (EPA). 1994. Selecting and Using Reference

Information in Superfund Ecological Risk Assessments, ECO Update, Volume 2, Number
4. Washington, DC: Office of Solid Waste and Emergency Response.

U.S. Environmental Protection Agency (EPA).
EPA/630/R-94/009. Washington, DC:
November.

U.S. Environmental Protection Agency (EPA).

1994. Ecological Risk Assessment Issue Papers.
Office of Solid Waste and Emergency Response.

1996. Ecotox Thresholds, ECO Update, Volume

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3, Number 2. Washington, DC: Office of Solid Waste and Emergency Response.

U.S. Environmental Protection Agency (EPA). 1997. Ecological Risk Assessment Guidance for
Superfund: Process for Designing and Conducting Ecological Risk Assessments. Interim
Final. EPA 540-R-97-006. OSWER 9285.7-25. Washington, DC: Office of Solid
Waste and Emergency Response. June.

U.S. Environmental Protection Agency (EPA). 1997. Guiding Principles for Monte Carlo
Analysis. EPA/63C/R-97/001. Washington, DC: Risk Assessment Forum. March.

U.S. Environmental Protection Agency (EPA). 1998. Guidelines for Ecological Risk

Assessment. EPA-630-R-95-002F. Washington, DC: Risk Assessment Forum. April.

U.S. Environmental Protection Agency (EPA). 1999. Memorandum to Superfund National

Policy Managers re: Issuance of Final Guidance: Ecological Risk Assessment and Risk
Management Principles at Superfund Sites. OSWER Directive 9285.7-28 P.

Washington, DC: Office of Solid Waste and Emergency Response. October.

U.S. Environmental Protection Agency (EPA). 2001. RAGS, Volume 3, Part A: Process for
Conducting Probabilistic Risk Assessment. EPA 540-R-02-002. Washington, DC:

Office of Solid Waste and Emergency Response. December.

U.S. Environmental Protection Agency (EPA). 2002. Guidelines for Ensuring and Maximizing
the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the
Environmental Protection Agency. EPA/260R-02-008. Washington, D.C. Office of
Environmental Information. December.

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ATTACHMENT B
Assessment Endpoints for the Housatonic "Rest of River" ERA

1.	Survival, growth, reproduction and structure of the benthic invertebrate
community.

2.	Reproductive success, development, maturation, and condition of the
amphibian community.

3.	Survival, growth and reproduction of fish.

4.	Survival, growth, and reproduction of insectivorous birds.

5.	Survival, growth, and reproduction of piscivorous/carnivorous birds.

6.	Survival, growth, and reproduction of omnivorous/carnivorous mammals.

7.	Survival, growth, and reproduction of piscivorous mammals.

8.	Survival, growth, and reproduction of threatened and endangered species.

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