000073 techn ical amd review comments united sta te s … · techn ical amd review comments of...

D R A F T

000073 TECHN ICAL AMD REVIEW COMMENTS

of UNITED STA TE S ENV I RONMENTAL PROTECTION AGENCY

and MAS SACHUSETTS DEPARTMENT of ENVIRONM ENTAL PROTECTION

GENERAL ELECTRIC COMPANY lt - bdquo - S i i v lU id R a o u sC Pitlslield Massachusetts C [ | fr n bdquo

EPA I D MAD002084093 Area 6 ~ - mdash-pound~--~-MCPSiteNo 1-0147 v -------shy

0 1 I 1 L K

REVISED WORK PLAN FOR THE ECOLOGICAL RISK ASSESSMENT

OF THE HOUSATONIC RIVER SITE Submitted May 24 1997

INTRODUCTION

The US Environmental Protect ion A u e n c v New England Region (EPA) and the Massachusetts Department of Environmental Protec t ion (DtP) ( t o g e t h e r the Agencies ) have compiled the fo l lcmuv general and specific comments relating to completeness and technical validity of the Work Plan for ic Ecological Risk Assessment of the Housalonic River Site prepared by ChemRisk and submit ted to the Agencies on May 24 1997 This Work Plan is a revised version of a previously submitted Work P lan dated February 28 1995 The Agencies reviewed the February 28 1995 Work Plan and issued comments to General Electric (GE) by letter dated March 26 1997

In preparing these comments on the revised Work Plan the Agencies have considered input from the following Agencies Connecticut Department of Environmental Protection I) S Fish and Wi ld l i f e Service National Oceanic and Atmospheric Administration and Massachusetts Division of F isher ies uvl W i l d l i f e

The Agencies comments are divided into two major sections General Comments and Technical Comments General comments address the overall approach purpose and objectives of Che r i s k assessment The technical section contains the Agencies specific comments on the field studies and modeling GE has proposed to evaluate risk to the environment from PCBs

The revised Work Plan represents a significant improvement over the Work Plain submitted lo the Agencies by GE in February 1995 GE has been responsive to many of the Agencies1 comments issued on March 26 1997 However the revised Work Plan needs addi t ional revisions in several areas in order for t he Agencies to consider it an acceptable Scope of Work for an ecological risk assessment The specific revisions that the Agencies believe are necessary are detailed in the Technical Comments Sect ion (Section II)

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I GENERAL COMMENTS

Page I-2 of the linitroduiction includes the following statement The purpose and objectives of the tasks outlined in this work plan will be to determine whether releases of chemicals from line GE facility to the Mousatonic River S ite have or could be expected to adversely affect terrestri all or aquatic populations with polenlial for exposures to releases Tine Work Plan later states that the reproducing population is the smallest unit that we can meaningfully protect

These statements misconstrue the Agencies regulatory objectives The Agencies concerns are not limited to observable deleterious effects on entire populations or communities Rather than focusing oni entire populations the risk assessment should address impacts on the subsets of organisms or local subpopulations that are more likely to be exposed to contamination a t and from the site

The Agencies agree that the kinds of effects that are relevant for hazardous waste site management are those that could adversely effect a population the entire population were exposed E x a m p l e s are reduced reproduction prey depletion or direct toxic effects However at most sites i n c l u d i n u this one the extent of contaminat ion is small when compared to the classic d e f i n i t i o n for I he geographical range of wildl ife populations of concern Thus measurable changes in a population as a whole are u n l i k e l y Therefore the risk assessment s h o u l d focus on the s u b p o p u l a t i o n s ol o r g a n i s m s that are exposed in the c o n t a m i n a t e d area This is c l ea r ly stated as a r e q u n e r n e n i i n M bull Massachusetts Contingency Plan at 310 C1VIR 40 0995 ( 4 ) ( b ) ( l )(a))

The Agencies note that adverse effects on subpopulations may be difficult to measure by f i e ld studies Moreover the World Health Organization recent ly published a document suiting thai harmful effects (eg effects on survival growth and reproduction) of PCBs and other d ioxin-hke chemicals are difficult to detect at the population level Therefore methods to assess and predict effects on individuals are required (WHO 1997)

Further by assessing the wildlife that are actually exposed the risk assessment evaluates whether the contaminated habitats are functioning as would normal heal thy habitats i n the absence of contaminants Vital funct ions include p rov id ing adequate food and shelter and s u s t a i n i n g normjI reproductive success The cen t r a l question for purposes of this assessment is whe the r (he exposed sub-populations are thr iving in the contaminated habitat not whether t h e larger regional population is surviving in spite of it

GE has cited a number of compensatory mechanisms that can enable populations to survive in spite of the loss of individual organisms from toxic effects One example cited is migration Organisms thai have moved from clean areas may be observed in a contaminated area in apparently normal numbers clue to migration In the Agencies view though the mere presence gt l a normal number of animals in a contaminated area does not demonstrate that the population is unaffected or that the habitat is providing normal support funct ions If com arm riant l e v e l s are su h that organisms could not reproduce normally or t h r i v e in an affected area without being replenished then the Agencies wou ld view those levels as harmful

Chemical adaptation is another compensatory mechanism w h i c h a l though not emphas i sed by i i l is likely to be a factor at this site part icularly for fish populations This mechanisms leads to the selection of genotypes that are resistant to a chemical as a result of the elimination of ind iv idua l organisms that are more sens i t ive The result is a population wi th an al tered generic makeup

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D R A F T 11(598

generally with a less diverse geinc pool It s yd to be determined whether such alterations reduce the populations resilience making it more susceptible to other stresses in the long term In addition adapted organisms will continue to mobilize contaminants in soils and sediments nicking them more available to higher trophic levels For these reasons the Agencies would not conclude that an adapted population represents a healthy condition or indicates no significant risk Uncertainty about the tiealth of an adapted population would be considered by the Agencies when weighing the merits of population study data against other measure of toxicity

2 The Agencies previously expressed concern that field studies can in principle provide important direct measures of adverse effects while in practice they are frequently insufficiently rigorous to detect biologically important adverse changes against a background containing other interferences If a field study lacks the sensitivity to detect effects of concern its results can not provide a reasonable basis for risk management decisions I n order for a field study to provide a mean i n g full measure of effects the investigators must be able to show the fol lowing

bull The study measures re la t ive ly sensitive effects in species that are known or expected to be re la t ive ly sensitive to exposure to PCBs

ltbull The design and implementation of the study accounts for and can distinguish responses tha i are clue to contamination from those clue to natural variabil i ty andor non-PCB stressors

The reference areas are comparable to the study area

laquobull The proposed methodologies are consistent with established methods

bull The study design particularly the sample size assures sufficient statistical power to detect effects if they exist

In reviewing GEs revised Work Plan the Agencies have given GEs proposed field studies fu l l consideration In some cases the Agencies have determined that field studies proposed by GE are not sufficiently rigorous to produce conclusive results The Agencies recommend e l iminat ing from the risk assessment studies that are l ikely to produce ambiguous results and w i l l not consider such studies when weighing the lines of evidence at the conclusion of I he risk assessment The technical comments in the following section identify the specific studies which the Agencies have determined should not be included in the risk assessment

3 For several proposed field studies (for example the invertebrate community and fish reproduction studies) GE states that if an effect is observed further evaluations wi l l be conducted to determine whether the field study data shows a correlation between PCB concentrations and effects The implication is that evidence of harm or baseline risk observed in the basic field study (comparison of exposed biota to reference organisms) could be refuted if a dose-response relationship cannot be discerned from the field data Assuming this interpretation of GEs in ten t is accurate the Agencies disagree with the proposed approach The Agencies have reservations regarding the establishment of a definitive and useful dose-response relationship from field studies The

1Agencies will not view the absence of a dose-response re la t ionsh ip as evidence that PCBs are mcaus ing adverse effects

4 In previous comments the Agencies emphasized the importance of a balanced consideration of ihc uncertainties associated wi th v a r i o u s types of measurements The Agencies have stressed the

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D R A F T 11698

utility or benchmark comparisons andtoxicity tests These measures involve measuring effects under more controlled conditions tliam field studies nuncl cam provide more sens itive measures of effects iiri particular dose-response relationships

The Work Flam proposes lo employ a phased approach whenever predliclivc techniques (such as benchmark and toxicity tests) are used Specifically GE proposes lo use population-level modeling andor collection of field data to determine whether predicted effects cam be verified in the field GEs proposal appears to mean that toxicity tests and benchmark comparisons wil l carry essentially no weight when a field study does not verify an effect I f t h i s is GEs intent then GEs phased approach is not acceptable to the Agencies

GEs phased appiroach does not satisfy the Agencies regulatory objective that the strengths and weaknesses of all measurements should be evaluated in a rigorous and balanced manner and that all measures should be considered in the risk characterization process The Agencies intend to weigh the results of predictive techniques along w i t h the results of f ield studies regardless of whether field studies ver i fy the predictive studies

An example of weighing pred ic t ive results along wi th field study results is the Sediment Qua l ih Triad approach (Chapman in EPA 1992) All three components of the Triad sediment l ox i c i t v testing sediment chemistry compared to benchmarks and benthic community measurements in1

evaluated together t ommems I I 13 I and II B 3 d i s c u s s e s h o w G K s h o u l d use the S e d i m e n t Qua l i t y T r i a d approach

5 GE should use assessment enclpomts that are worded in a more general manner rather than rhe narrow endpoints previously suggested Attachment A to th i s comment letter contains a revised Table 2- i (S ummary of Select ed A ssessment and Mea su rement E ndpoin ts) Revi sed Table 2 bull 3 contains broadly-defined assessment endpoints 1 hat GE should use in the risk assessment and also reflects changes in receptors and endpoints that the Agencies are asking GE to make in th is comment letter

6 -3 of the Work Plan states that the Ecological Risk Assessment wi l l attempt where f ea s ihk to evaluate mul t iple lines of evidence for the same assessment endpoint and to use all re levant data Though it may be he lp fu l to evaluate mul t ip l e l ines of evidence for 1 lie same assessment endpoint it is important not to flood the list of measurement endpomis w i t h i r re levant or insen siti ve measures which could dilute or obscure the more pert inent me asures Flue tec h n ic all comments w h i c h follow identify specific measurement endpoints which are not sensit ive measurements and therefore should be eliminated from the risk assessment

7 The EPA Wildlife Exposures Handbook (EPA I993a) should be the primary reference for dietary intake model parameters Deviations from the assumptions in EPA1 Handbook should be explained and alternative references should be ci ted

One-hundred percent absorption of PCBs should be assumed in all dietary mode I m p performed unless measured published values for appropriate species are cited

r-PAs Wi ld l i f e Exposures Handbook (EPA 1993a) should be consulted for in format ion on the percent soil in the diet of vaiious organisms of concern especially robin (refer to values for the Amer ican woodcock) small mammals and red fox

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D R A F T lr ) 11698

8 I n previous comments on the Work Plan the Agencies stated that Ifie risk assessment must evaluate cumulative impacts from PCBs and other contaminants in the Housatonic Rivcir 11 GE elects to focus tine risk assessment on PCBs and exclude other contaminants adequate documental ion nnuisl be provided lo support such a decision GE should be aware that without adequate data on other contaminants in the River it may not be possible to discern adverse biotic responses related to PCBs from those of other contaminants I n the absence of in formation on other contaminants the Agencies will assume lhal all observed effects are attributable to exposure to PCBs

9 After reviewing GEs protocols for sampling and analysis of prey items for use in dietary mod el ing the Agencies have determined that congener-specific analyses should IK performed for prey items I n addition data on homologs wil l be necessary to obtain more accurate estimates of total PCBs for biota samples For purposes of these comments homologs are groups of congeners wi th the same number of chlorine atoms Finally su f f i c ien t Aroclor data should be obtained to facilitate the evaluation of relationships between previously obtained Aroclor concentrations and new homolog and congener concentrations Thus combinations of analytical protocols may be needed for prey items To ensure that plans and protocols wi l l meet cur rent Agency data requirements as e f f i c i e n t l y as possible GE should work in consu l ta t ion with the Agencies to develop appropriate combinations of analyses for each prey i tem target lists of congeners and s a m p l i n g plans to obtain c o n g e n e r d a l a in representative C a m p l e s

I he Agencies note that congener-specific analysis and homolog data also may be needed for other environmental media to supp lement previously obtained data For example congener-specific data may be needed for sediments in conjunction with henthic community structure studies GE should work in consultation with the Agencies to develop t a rge t lists of congeners and sampl ing plans to obtain congener data in representative envi ronmenta l samples

10 EPA is currently ireevaluating body scaling factors and has reservations about the use of a factor of 34 For this reason the Agencies recommend the use of a straight weight ratio in dietary models r a the r than use of a body s c a l i n g fac tor of 34

1 1 In all biota ana ly se s GE is proposing to conduct for the r isk assessment GE should follow the U S Fish arid Wildlife 1988 Q AQC Guidelines for Contract Laboratories inc lud ing the use of certified re fe rence ma te r i a l Data should be validated using tPA s Protocol for Nonstandard Data

12 In response to previous Agency comments GE used s ta t i s t ica l methods to ident i fy nunibers of samples needed to ensure that the field studies wil l have sufficient power to detect effects of PCBs on exposed subpopulations Nevertheless the Agencies continue lo have concerns about the statistical methods presented in the Work Plan Prior to approval of the proposed field study designs GE should discuss the equations for calculating sample number with the Agencies i n greater detai l

13 GE should consu l t the US Geological Survey report of metals and organic compounds i n stream bed sediments (USGS 1997) for information t h a t cou ld be he lpfu l i n selecting reference areas

14 GE should develop its f i e l d v raquo o r k schedule in consultation with the Agenc ie s so that appropriate oversight can be provided

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D R A F T 11698

15 All contractors and subcontractors G E nisei foir conducting the Ecological Risk A ssessment an expected to be able to demonstrate previous relevant expertise nn tine anas of-work they will be responsible loir performing

16 All raw data firom the field studies performed as part of the risk assessment should be provided to the Agencies in electronic formal

LI

A PROBLE M FORMU L AT I ON

1 The Agencies disagree with GEs content ion (page 2-2) that the Housatonic Val ley Wildl i fe Management Area is already stressed because it is act ively managed to promote hunt ing and trapping and because mowing is regularly conducted there Leghold traps became il legal in December 1996 Moreover according to the Massachusetts Division of Fish and Wildlife (personal communica t ion Torn Keefe Western Distinct W i l d l i f e Supervisor Massachuse t t s Division of Fisheries and W i l d l i f e August 1997) the sale of trapping licenses in Massachuse t t s has slowly declined over the past ten years This decline is not clue to the lack of forbearing species but due to furmarket p r i c e s trap restrictions and sociological impacts

Mowing takes place on loss than 12 of the Housatonic V a l l e y W i l d l i f e Management Area - i gt mass It is done in the form of s tnp cutting to maintain former horse pastures that have ex is ted since the 1 950s The mowing is done in the fall not d u r i n g the nest ing season The goal of t h e mowing is to improve habitat diversity and increase species diversi ty and numbers

2 On page 2-1 1 of the revised Work Plain GE states that the Housatonic floodplain forest shrub stratum is dominated by arrowwood and sugar maple Sugar maple is not the d o m i n a n t maple species Silver maple is the dominant maple species along the edge of the River and backwaters with red maple following Sugar maple is considered an upland species

3 On page 2-23 the last sentence of the second paragraph stales t h a t communi ty structure is a reasonably sensitive endpomt based on McDonald ( 1994) a mar ine communi ty s t u d y of P c l l contaminated sediments The Agencies note that there is not a consensus on that point A n opposite finding is reached in the extensive work by Long and Morgan ( 11990) and Long et ut ( 1995) Long et a (1995) evaluated an enormous base of studies that examined t h e effects of PCBs in sediments on benthic invertebrates No gradients could be found in PCB concentrat ion m the rivers and bays assessed They found that there was very little to no concordance between the abundance of benthic invertebrates and PCB concentrations in nearly all the studies they evaluated

More recent work by Canf ie ld et al (1996) which assesses the Sediment Quality Triad Appiroiu h in the Great Lakes concluded that laboratory sediment toxicity tests may better iden t i fy e f f e c t s f chemical contamination in sediments than many commonly used measures of benthic mver teh i iNshycommuni ty conn pos ition

Because of the unce r t a in t i e s associated w i t h c o m m u n i t y studies b e n t h i c s t u d i e s proposed bv lt i t would be stronger if be rich in ark comparisons and sediment toxicity tests were also included I IP approach is the Sediment Qual i ty Triad approach and it is considered a more robust a p p r o a c h i eva lua t ing risks to b e n t h i c organisms than s i m p l y u s i n g communi ty s t r u c t u r e measu remen t s

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7 D R A F T 11698

Iliere fore GE should include benchmark comparisons anid seel inn ant toxicity tests in (lie benthic comraunity studies (refiir lo comments 1 and 3 inn Section IIB)

4 GE slates oni page 2-24 of the revised Work Plant that PC Bis less than I ugL in wateir do not affect adult fish survival oir their offspring The Agencies disagree The literature shows that 0 32 ugL of FCBs is the 4-day lethal concentration (LC50) for rainbow trout Salmo gairdneri (Onchoryknchus mykiss) and 053 ugL is the 4-day LCSO for redear sunfish Lepomis microlophus (Birge 1978) Brook trout Salvelinusfonlinalis experienced mortality after 497 days in as little

as 001 ugL of Aroclor 1254 Vitellogenin levels in brook t rou t are affected by concentrations of Aroclor 1254 less than I ugL(Mauck etal 1978) Fathead minnow Pimephales promelas were shown to experience mortality at 052 ugL Aroclor 1254 in a 240-day exposure (Nebeker 1974)

B PROPOSE D DATA COL LECT [ON AN D AN ALYSIS ACTIVTTIES

Benthic Invertebrates

1 The risk assessment should inc lude comparisons of PCB concentrations in sediment with publli shed criteria (benchmarks) The benchma rks should inc lude

raquo CPA Sediment Q u a h t v C r i t e r i a developed u s i n g the e q u i l i b r i u m p a r t i t i o n i n g a p p r o a c h (EPA 1993b) and

raquo Ontario Ministry of the Environment sediment qual i ty guidel ines (Persaud et a 1992 I

The Agencies believe these benchmark comparisons are necessary to include in the risk assessment loir the reasons described previously in comments I 4 and II A3

2 GE has proposed a study to examine whether benthic invertebrate communi ty structure at five target sites in the flousatonic River between the Pirtsfield facility and the Connecticut border is significantly different from tha t at five reference sites The study proposes to focus on depositional sites with fine-grained substrates Co-located sediment sampl ing w i l l be used fo quant i fy PCBs in the sediments from which each communi ty structure sample is de r ived Concentrations of PCBs in invertebrates will also be measured GE should make the fol lowing mod if ii cat ions to the proposed benthic invertebrate community study

a) GE should also add two target deposilional sampling stations in Connecticut One should be in the profundal sediments of Lake Zoarand one should be in the profundal sediments of Lake Lillinonah As a reference area for the two depositional stations in Connecticut GE should ulaquoc Lake McDonough in the Farmington River

GE should add a target sampling station for riffle hab i ta t in the trout management area in Connecticut The trout management area is located in the towns of Salisbury Canaan Sharon and Cornwall As a reference area the Agencies recommend that GE use the Farmington Rn rr Tro ut M ana gem enl A irea

With the addition of three target sampling stations in Connecticut the total number of target sampl ing stations in the h c n t h i c communi ty study w i l l be eight

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b) GE has proposed to focus on depositional ureas iim Massachusetts Of the five target sampling stations GE has proposed in Massachusetis one site shouild IK in Woods Pond For tine remaining four target sampling stations im Massachusetts GE should propose specific sampling stations amd a rationale for selecting each station GE should also include a description of substrate type PC 11 sediment concentration and generic habitat description fbir each sairnpling station (Connecticut and Massachusetts stations)

As a possible target sampling station GE should consider the area immediately above New Lenox Road which consists ofsilty meanders wiith medium and high PCB concentrations

c) The acceptability of benthic invertebrate community structure as a measurement endpoint hinges on matching habitats of the target areas with like habitats in reference areas GE has stated thai it will consult with the Agencies on the selection of reference areas The Agencies stress that they want to be consul ted on reference area selection

The Agencies believe tha t one reference area loir the four depositions I target areas in the main si em of the river in Massachusetts is sufficient A separate reference local ion loir Woods P o n d should also be proposed by LiE

The total number of reference s t a t ions in the benthic community s tudy should be fou r ( r e f e r e n c e s t a t ion for Woods Pond reference si EH ion for deposi l ional areas in Massacrmû^ Lake McDonough in t h e r -a rmington R i v e r and t h e ranrnirigton Rive r Trout Management Area)

d) Because sampling for benthic invertebrates will be a one-time event and because of seasonalitgt issues such as rainfall a i r temperature and snowmelt the Agencies recommend that sampling of benthic invertebrates take place at a t ime that would maximize the number of species and individuals t h a i would be retained on the 500 micron mesh sieve This would mean a t i m e of maximum use of the deposition al area by later in stars (P la fk in 1989)

e) Page 9 of Protocol B-1 suggests a final rinse of stream water for al l field equipment The Agencies suggest that the sieve forceps and pan receive a deionied water r inse to reduce cross com am i rial ion pot ent ial

f) Protocol B-1 includes a general discussion about the use of species composition as a metric GE states that species composition evaluation is based on professional judgement The Protocol should include a more complete discussion of this metric Klernrn (1990) discusses species composition and its relationship to species d ivers i fy In particular a reference is made to the use of the term equitibility coined by Lloyd and Ghelardi (1964) This same reference is found in Table 2 of Protocol B-1 as an index based on species abundance The Agencies recommend that Protocol B - l provide a discussion of species composition evaluat ion in a manner similar to that by Kle rn rn (1990) relating equi tabi l i ty a comparison between the expected number of species and the number of species (bund at the sampl ing location k v i i h species composition

On a s i m i l a r point the Protocol slates that c o m m u n i t y popula t ion parameters are assessed u s i n g var ious metrics based on species density The Protocol should inc lude a more comple t e description of the use of the metrics proposed

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D R A F T 11(598

g) The Agencies agree witln GE that itlnlt use of llic HilsenhofT s Index of Biioitk Integrity (HB1) as found ini EPAs Rapid lilioassessnienl Protocol (RBP) is not appropriate Ibir the benthic community study ait depositional locations because it was designed loir use primarily in steams containing a luge percentage oiriflkiun zones The MBI compiles and compares taxa among sites bmed oin tolerance values and was developed to delineate those areas containing a higher percentage of pollutant-tolerant species reflecting degraded conditions The Agencies recommend application of an index that is modified for use m deposilional areas GE should consider the utility of the HBI modification employed by Canfield et a (1996) In this way the HBI could be used as another tool to assist in the identification of depositional areas that are biologically unpaired

h) For the location the Agencies have asked GE to add in Connecticuts trout management area GE should use appropriate metr ics for rifflerun zones

i) Page 15 of Protocol B-l states that regression analysis w i l l be used to compare the concentrations of PCBs i n the composite benthic invertebrate tissue samples that were analysed for PC Els with PCB concentrations in the co-located sediment composites The Protocol also states that regression analyses w i l l be used to examine the ab i l i t y to predict benthic rnacroinvettebrate body burdens from whole sediment concentra t ions It is l i ke ly t h a t bioaccumulation of PCBs from sediments to the benthic macroinvertebrate community w i l l also depend in part on to ta l organic carbon (TOC) content and hpid concent r a t i o n Consequently the Agencies recommend that the r e l a t i o n s h i p s between TOC l ipid concentration PCB body burden and sediment concentration be evaluated

j) In Section 62 of Protocol B-1 GE stales that it w i l l use immunoassays in the pre-screening procedure for selecting sampling locations to determine if PCB concentrations are consistent with historical data consistent with the goals set for the target sites or be low detection l i m i t s for reference sites The Agencies do not support the use of immunoassays without a strong correlation study

Rather than using immunoassays for screening potential target and reference sampling locations the Agencies recommend that GE use a laboratory Gas Chromalography method modified to abbreviate c l eanup procedures (e g EPA modi fled Method 808 1) This method wil l provide more accura te and precise screening results than immunoassay methods

At each of the eight target sites and each of the lour reference sites in the benthic invertebrate community study GE should conduct a long-term subchronic sediment loxiciry test with the amphipod Hyallela azteca and a chirononnid species using methodology currently under development by the American Society for Testing and Materials and EPA GE should analyze sediment from all target and reference areas for sediment particle size total organic carbon and inorganic carbon pH and ammonia of the pore water and percent water content Results of t h e toxici ty l e s t should be used to evaluate survival reproduction and growth of benthic invertebrates

Sediment toxicity tests are one component of the Sediment Qua l i t y T r i ad approach As stated p rev ious ly the Agencies cons ider the Sediment Quality Triad approach to be a more robust approach to evaluating r isks 10 b e n t h i c o rgan isms than s imply using c o m m u n i t y s t ruc ture measurements

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D R A F T 11(598

4 As part of the benthic invertebrate collection activities GE should collect crayfish from each of (lie sampling stations selected loir benlhic iiinrverlebrate sampling Total PCB levels and selected congeners (refer to comment 10 in Section ][) should be quantified in line crayfish PCB concentrations in crayfish should be used for modeling tine diets of mink great blue heron and kingfisher Crayfish tissue1 concentration) may also be used along with macroinveirtebirale concentration for generating an esl imate of sediment levels that pose a risk based on adverse effects to fish

Emergent Insects

5 GE proposes to use primarily aerial traps rather than emergence traps to collect emergent insects Several reasons are given for this approach including that emergence traps are unlikely to provide sufficient biomass for PCB analysis In the Agencies view aerial traps have proven to be relat ively unsuccessful Therefore the Agencies recommend that GE place a greater emphasis on emergence traps The Agencies have researched available techniques for sampling emergent insects and found thai the most sue cess (ill colled ion technique has not been documented in the literature Based on personal communicat ion (Andrew Major US Fish and Wi ld l i f e Service Concord NH June 26 19971 emergence traps have been recently constructed and successfu l ly used by the Central Maine Power Company The Agencies recommend that GE consult with B i l l Hanson of Central Maine Power Company (phone number 207-626-9600) about us ing their co l l ec t i on technique for c n r i c i i j i i i l i n s e c t s in the Housa ton ic R i e r

6 It is unclear whether corn po su ing of emergent insects across sampling locations is p lanned by GK The Agencies would disagree s t rongly with any compositing of samples across sampling stations because the food source wil l not be representative of PCB contamination in a particular river reach

7 GE has proposed to analyze insects by laxonomic group It is not clear how this in formal ion would be used in the risk assessment Unless GE can locate a study of tree swallows w h i c h reports the relative dietary proportions of various insect populations for tree swallows (which is comparable to insect populations in the Housatonic R i v e r ) the Agencies do not ant ic ipate tha t order-spec if lie PCB concentrat ions wi l l be useful in reducing uncertainty i n dietary mode l ing to tree s w a l l o w s

8 Page 9 of Protocol B-2 states that insect sampling wil l extend over a period of six nights contingent upon weather conditions The Agencies note that sampling should continue for as long as necessary to collect adequate biomass for analysis

9 A schematic of how the stratified random sampling for emergent insects will be done should be provided so that the Agencies can confirm that the selected areas are appropriately representative of sediment contamination dis t r ibut ion

10 The Agencies are concerned that insect sample integrity may be compromised because GE has proposed to use hand held insect vacs (aspirators) to collect insects from the traps and has proposed to preserve insect samples by freezing In order to ensure t h a t the samples are not damaged before taxonomy is conducted GE should cons ider us ing a l t e r n a t i v e methods of collecting and preserving samples

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D R A F T 11698

11 GE slum Id add sampling stations loir emergent insects in the trout management area in Connixticul GE should propose location(s) loir such sampling

If GE lt lects iriolt to sample emergent insects in Connect icut then GE shou Id use existing benthic invertebrate data from Connecticut in the dietary model for tree swallows GE should not estimate PCB concentrations in emergent insects in Connecticut using biota-sediment accumulation factors derived from Massachusetts data because such airi approach may significantly underestimate the body burden data foi emergent insects in Connecticut

Terreslria I In vertebrates

12 GE plans not to restrict sampling plots to a specific area in order to collect as much biomass as possible The Agencies understand that collection of adequate biomass is critical However GF should collect invertebrates and co-located soil samples from reasonably proximale areas

13 GE should report if recovery of invertebrates lor a given plot is zero or less than adequate to at tain sample mass

14 GE should analyze soil samples for gtoil temperature moisture and pH

Ftsfi

] 5 The risk assessment should i n c l u d e comparisons of PCB levels in adult fish tissue ( f rom the fish reproduction study) young-of-the-year fish tissue (from trend analyses) and fish eggs (from ihe fish reproduction study) with appropriate maximum acceptable tissue concentrations (MATCsl GE should propose the MATCs i t intends to use

16 On page 3-16 the revised Work Plan states that the Agencies position on using congener-specific data was discussed in some detail in aJanuary 8 1996 le t te r from DrFinkelstem of the Na t iona l Ocea n ic and At mosphe r ic Adm im stir at ion (NOA A) I o Dr Je n k ins of IS A E n v iron rnenta I The Agencies note tha t the January 8 letter from Dr Finkels tem did not include any discussion of NOAAs posit ion on using congener-specific data

17 The Agencies disagree with GEs reasons for not including bullhead Bul lhead should be numerous in the Housalonic River accord ing to Massachusetts Division of f i sh and Wildl ife Massachusetts Department of Environmental Protection US Geological Services Biologica l Resources Division (formerly the National Biological Service) and the Housatonic River I n i t i a t o r Unt i l or unless night sampling of bullheads and use of al ternative methods such as baited traps lt gt ( trot lines has been conducted and demonstrated to be ineffect ive bu l lhead should not be eliminated from the fish reproduction study Bullhead are a bottom feeder and thus they have different opportunities for exposure to PCBs than species such as perch or large mouth

18 In the fe r t i l i za t ion process GE should track the p e r c e n t of males found to have i n a c t i v e sperm This should be included as a me as Lire rnent endpoinf

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19 GE should track the percent of gravid female fish they collect in the fkld (just as they are doing loir frogs in the frog reproduction study) This should be included as a measurement endpoint GE should also document Uhe percenit of failed fertilization thai occurs in the initiation of (lie test

20 GE shou Id age the fish they col led

21 The Agencies believe that the laboratory environment proposed by GE does not reflect actual field conditions as closely as it might Better simulation of field conditions dur ing laboratory exposure should provide more realistic fish larvae exposure data beyond exposure attributable to maternal transfer

Ideally this would involve using field-collected sediment as a substrate i n the aquarium and PCB-contaminated larval food The Agencies are unable to c i t e an appropriate laboratory protocol for using contaminated food If GE elects not to use contaminated larval food in the fish reproduction study it should address in the uncertainty section of the r isk assessment how using uncontaro mated food versus PCB- contaminated food may underestimate exposure to the fish

At a min i mum GE should use field-collected sediment as a substra te in the aquaria A s tandard laboratory protocol for using field sediment in the laboratory is available (EPAA COE 1991) and involves the transfer of frv to vessels containing field sed iment and laboratory water d u r i n g the second phase of the studgt Gf shou ld also inc lude a c o n t r o l u s i n e laboratory s e d i m e n t to determine whet her other factors may be contributing to toxicity

22 In order to increase the statistical power of the study to detect differences and to reduce the potential impact of handling the larvae GE should increase 1 he number of fry observ eel from 20 fry (ie 5 fry in 4 replicates) to 80 fry (ie 10 fry in 8 replicates) per spawning pair Since the fish responses from the contaminated areas will be compared to those off i sh from a reference area using hypothesis test ing minimum significant difference wi l l be inversely proportional to the number ofireplica1es Eight repl ica tes are recommended for t h i s type of test Since this t e s t methodology is extremely labor -intensive and uses field -collected fish species not commonlv used as laboratory test organisms it is recommended that the number of fish eggs observed be increased to at least 80 per spawning pair to help ensure test success Greater than 20 mortal i ty in the control e g g s may inval ida te the test Since t h i s is a nons t anda rd iêd method u s i n g u n c o r u c n i n i i l test species there are no documented measures of va r iab i l i ty to use to assess power of the tesi The Agencies believe that doubling the number of organisms and using the recommended eight replicates will yield a mote rigorous test (EPA 1994) Consult EPA ( 1994) for a detailed disc u ssion of e xperimenta I design

23 The Agencies are concerned about loss of PCBs from the fish via depuration GE should propose and provide justification for a maximum acceptable t ime for fish to be held before being strip spawned

24 GE states that the measurement endpoint for the fish reproduction study w i l l i n i t i a l l y be eva using A NOVA statistical test Data from all target and reference sites w i l l be combined to p r lt gt i )ltbull for maximum statistical p o w e r GE stales tha t if s t a t i s t i c a l l y s i g n i f i c a n t d i f fe rences are not observed it wi l l conclude tha t PCB concentrations i n fish I is sue and e^gs from t a r g e t a reas aic i bull causing reproductive impairment in fish species evaluated

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If however statistically significant differences are observed using the ANOVA lest then GE will evaluate differences among sampl ing stations using paired comparison in oinlerlo identify the specific locations with significant differences

The Agencies wanil GE to present result of paired comparisons so that (lie magnitude of differences can be seem among sites A paiirwise comparison test Uial maintains tlie experiment-wise alpha at 003 should be chosen A nonpararnetric test cam be used if line data quantity and quality do not allow for a parametric pairwise comparison test

25 Reference sites loir Ilie fish irepricxluctiiom study should be selected such lliat tlicre is no possibility of immigration oir emigration of fish between contaminated and uncontaminaled areas GE should consider the Farmington River and the Swift River as possible reference areas

26 The fish reproduction study does not address the possibility that fish from the Housatonic River may have adapted to PCBs in the uncertainty section of the risk assessment GE should discuss genetic selection for tolerance to PCBs and how il cou ld affect the results of the fish reproduction study

27 In Section 31 317 of the revised Work Plan GE presenls a lengthy discussion supporting i t s decision that there is no jus t i f i ca t ion for conducting congener-specific analyses on fish as part of t h e f ish reproduction study Hie Agencies disagree ^ nh the reasons GE has presented for A I congener-specific analyses are not warranted In the bu l l e t s below the Agencies have presented their response to each of GEs reasons for concluding that there is no jus t i f i ca t ion for conduct ing congener-specific analyses on f ish as part of the fish reproduction study

a) GE states that a number of recent studies have evaluated the use of Toxic Equivalency Factors (TEFs) in predicting the toxicity of PCBs to fish GE stales that the results of these studies show that total PCB concentrations provide more accurate measures of PCB toxic i ty to f ish than do dioxin Toxic Equivalency Quotients (TEQs)

- A possible explanation for the studies f i nd ings that to ta l PCBs correlate more closely uh toxicity than TEFs is noted by GE The studies GE cites used mammalian-derived TEf-s which may not accurately ref lect PCB tox ic i t y in fish

Furthermore the studies cited by GE determined total PCBs by summing ind iv idua l congener concentrations not Aroclor totals Thus it can not be determined from these studies that total PCBs are a better measure of toxicity

One of the same studies cited by GE (Mac et at 1993) points out the inaccuracy of representing PCB residues as Aroclors and states that whet heir one is interested in residue trends of PCBs or in their lexicological significance complete congener a n a l y s i s is necessary Furthermore Eganhouse and Gossett ( 1 9 9 1 ) in a comparison of the congener shyspecific method of PCB analysis with the t radi t ional Aroclor approach found that the b i a s i n Aroclor determinations of total PCBs in env i ronmen ta l samples was poten t ia l ly large (greater than 200 percent ) and highly va r i ab le

b) GE states that a major problem in collecting congener data is the l a ck of re l i ab le TEFs for u-lt w i t h fish GE notes tha t most of the fish TEFs ate derived from studies of ra inbow t rou t and

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provide link insight into variability among fish species GE also motes that the TEFs ibir rainbow ttout show substantial variation] within and among studies

bull TEFs based am direct measurement of early life-stage effects should be used in preference to those derived from enzymatic activity measurements If this is done there is very little variability in the rainbow trout-based TEF for PCB 126 Furthermore TEF measurements eliminate the problem of extrapolating total PCB effects concentrations found in t he literature to the totally different mixture found in the Housatonic River The assumptions concerning interspecies extrapolation exist using e i the r method

c) GE also notes thai another problem with the TEF studies is the lack of an additive response of the rainbow trout-based TEFs in mixtures GE states thai various pairs of PCB congeners have produced both grealer-lhan-addilive responses and lies5-than-additive responses Calculation of dioxin TEQs is based on the assumption that the toxic effects of individual congeners are additive

- In response 1o the a d d i t i v i l y question the use of1 hFs no rma l ly assumes that i n d i v i d u a l congeners act additively (Zabel ei at 1995b) Two studies by Xabel (Zabell el al 1995a 1995b) support both t h e use of rainbow trout TEF-s in lake trout r i sk assessment and the assumption that these congeners act addilively al e n v i r o n m e n t a l l y relevant rat ios The a u t h o r po in t s o u t sonn i d a t i v e l y m i n o r v a r i a b i l i t y in a d d i t i v i t v S imply pu t a d d m v i u i -an imperfect assumption but shows reasonable precis ion For example Newsfed ei ul (1995) showed that whi le interactions among PCB congeners and TCDD were somewha t equivocal they did not great ly differ from predicted additive response

d) GE asserts that in order for congener-specific toxicnty reference values for fish to be used in developing a remediation strategy an entire database of congener-spec He data would need to be acquired loir fish and sediments in the Housatonic River

- The Agencies do not agree that an entire database of congener data would necessarily need to be collected in order to develop remedial goals GE would need only to collect enough data to develop a ratio between total PCBs (based on Aroclots) and congener concentra t ion- a s suming t h a i t h e PCHs have weathered in a s i m i l a r manner th roughout the mer

In summary the Agencies have concluded that congener data wi l l provide a more accurate measure of PCB toxici ty and wil l allow better interpretation of the results of the fish reproduction study The Agencies believe tha t the TEFs available for fish will provide a reasonable basis for interpreting congener data The Agencies also intend to use fish congener data in dietary modeling to piscivorous mammals and birds Therefore GE should collect congener data (in addi t ion to total PCBs derived from hornologues) as part of the fish reproduction study As stated i n c o m m e n t 10 in Section I of this letter the Agencies have also asked GF to collect congener data in of heir organismsto support food chain modeling

28 GE has stated on page 2-44 of the revised Work Plan that a fish reproduction s t u d y for b iown l u u t in Connecticut is not l ike ly to be feasible Based on th i s r a t i o n a l e Gh has not inc luded brpvun t r o u t as a receptor species for t h e r i s k assessment The Agencies a^ree that i t is not feasible to conduct a fish reproduction stud) on brown trout in Connecticut However t h e Agencies be l ieve that brown ( t o u t should be eva lua ted as a receptor species in the r i sk assessment

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To evaluate potential risks to brown trout in Connecticut GE should collect brown trout from the trout management area in Connecticut andi should conduct analyses for total PCBs and for appropriate congeners (congeners quantified should x the same congeners quantified as part of (lie fish reproduction study) GE should compare PCB levels in brown trout to appropriate MATCs published iiri the scientific literature GE should propose the MATCs it intends to use

9 As stated in previous comments the Agencies have serious concerns about using population- and community-level studies in fish to evaluate potential effects of PCBs on fish populations in the Massachusetts portion of the Housatonic The Agencies have previously expressed several key concerns about fish community studies Those key concerns are restated here

bull For relatively small populations of mobile organisms (such as fish) change in community or population structure may not be sufficiently sensitive as assessment or measurement endpoints to detect the presence or absence of PCB effects against the background of natural variabil i ty or effects caused by non-chemical stressors and other environmental factors (e g habitat differences) even when such measurements are compared with a suitable reference area Natural var ia t ions in ecosystems can make it d i f f icul t to detect stressor-relaled perturbations Natural f luctuat ions in fish populations are often large wi th mterannual a r i a b i l i t y in popula i ion leds covering seve ra l orders of magni tude P r e d i c t i n g the cltiv of anthropogenic stressors against this background can be d i f f i c u l t

EPAs Interim Ecological Risk Assessment Guidance states that fish generally are not sensitive measures of the effects of sediment contamination because they are usually more mobile than benthic macroinvertebrates Although population- and community-level studies can be valuable several factors can confound the interpretation of the results Many fish and small mammal populations normally cycle in relation to population density food availability and other factors It is important that the noise of the system be evaluated so that the impacts attributed to chemical contamination at the site are not actually the result of different na tura l fact or s The level of effort required to resolve some of these issues can make populationcommunity evaluations impract ical in some c i rcumstances

In order for a fish community study to have any possibility of detect ing the presence or absence of PCB-re Hated effects against the normal fluctuations in community and population structure measures caused by factors other then PCBs the study would have to be a rigorous and extensive study inc lud ing at least several years of measurements

bull The selection of a suitable reference area is of critical importance In order for a fish community study to have any credibility it needs to have a reference area of the same s i z e and in the same ecoregion as the study area The Agencies have researched possible reference areas and have come to the conclusion that there is no reference area wi th comparable habitat for the target area GE has proposed to study for fish community structure (GE facility to down stream of the Glendale Dam) Even if a comparable reference area could be located i t would not be possible to control for the effects of rec ru i tment of fish at the site from u n c o n t j i n i i i a i e d t r i b u t a r i e s

The Agencies have carefullv evaluated GEs proposed new fish community structure study In us evaluation the Agencies h a v e considered the criteria l isted in comment I 2 of t h i s comment letter

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Tine Agencies have determined that the new fish community study Lhat GE has proposed lo conduct lacks the sensitiv ilty to detect effects of concern and wnl I produce am biguous results A study which produces ambiguous results will not provide a reasonable basis for risk manage merit decisions and should not lgts conducted If GE chooses lo conduct another fish community tincture study the Agencies will not include the results i n the weight of evidence evaluation

Amphibians

30 The number of frog larvae observed posthatch should be increased from 20 to 80 for the same reasons discussed in corn merit 21 for the fish reproduction study

Reptiles

3 1 The revised Work Plan states on page 3-28 that i f after f ive days of searching for turtle nests it appears un l ike ly thai a suff icient number of nesls or eggs can be located GE w i l l contact the Agencies to discuss the feas ibi l i ty of proceeding further w i t h ihe study

Gb should adequately document i t s systematic search for turt le nests and should discuss dens i ty oi turtle nests The Agencies note that 5 days may not be a sufficient period of t ime to f ind t u r t l e nest s If GE cont ac t s Ih e A p enc les to disc u ss the feasi b i l it lt gtf procee d ing w il h Ih e st ud v Ihi f A e c n c i e s m a v r e q u i r e G L to c o n t i n u e its s e a reh d e p e n d bull 1 1 1 o n 1 i e I d c o n d 1 1 1 o n s

32 In addition to conducting a reproduc t ion s tudy on snapp ing turtles GK should evalua te the presence of painted turtles Based on consultation with Torn Tyning a regional w i l d l i f e expert painted turtles are expected in the Housatonic River but have not been observed in I h e n u m b e r s that are expected

GE should propose a methodology for conducting a trend analysis on painted turtles Such methodology should be submitted to the Agencies as part of supplemental Phase IIRCPLA Fac 1 1 1 1 Investigation activitieslong term monitoring GE should conduct reconnaissance v i s i t s to the impacted h a b i t a t and a re (ere nee area(s) and compare n u m b e r s of painted turtles among i m p a c t e d and reference areas

Ihe Agencies are requesting data on panned turt les as part of a t rend analysis w h i c h w o u l d over a number of years The timeframe for conducting the ecological risk assessment is loo shori for the type of field study thai would be needed to detect differences in population measuremrnu against the back ground of natural variability The presenceabsence of painted tunics in the Housatonic is a topic much betleir suited loir investigation in a trend ana lys i s than in a field s l u d v 1shypart of the ecological risk assessment However to me ex ten t appropriate the Agencies mav qualitatively consider painted turtle trend data colled ed ear ly on to inform ecological r i sk management decisions about the tlousalomc R i v e r

Birds

The Agencies disagree w i t h ( J r - s r a t iona le for e l i m i n a t i n g helled kmc f isher as a r ecep to r oil concern Based on c o n s u l l a l i o n with Torn Tyning a regional w i l d l i f e expert bel ted k i i i E l i s h n r a more appropriate species to evaluate than blue heron because of the kingfisher s sma l l e r t e m r lt and larger number of nests adjacent to the river Despite the low density of belted k ing f i she r s r e l a t i v e to other birds in any hab i t a t they occupy the Housatonic River d o w n stream of P i t i s l i t - M

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does offer suitable habitat Kingfisher nests are present and they art suitably susceptible to PCB contamination through their nesting and feeding habits

GE should include belted kingfisher as amp specie of concern in the risk assessment To evaluate belted kingfisher GE should perform a dietary intaJke model using site-specific fish tissue concentrations such as young-of the year fish Estimated PCB levels in kingfisher should be compared with threshold values on reproductive effects (o the most closely related bird species

34 In the dietary model for tree swallows GE should use bioaccumulation factors and No Effect Levels from recent tree swallow research such as that conducted by Nichols et a 1995 Froese et al 1997 (in press) Ankley etal 1993 and USFWS 1997

35 The Agencies have given fu l l consideration to the additional surveys of great blue heron ha t ch ing success and the additional statistical analyses that GE has proposed to conduct in order to supplement the great blue heron reproduction study The Agencies have concluded thai GE has not demonstrated that the great blue heron study wi l l provide a meaningful measure of effects based on the criteria listed in comment 12 Specifically the Agencies believe that a cr i t ica l f law in the study is the lack of documentation of PCB exposure in the heron thai are be ing observed The Agencies have concluded t l u t tin1 iraquorcat blue heron s t i i d v should not he included i n the i r r I assessment

The Agencies note that they c o n t i n u e to want GE to develop a dietary intake model for great blue heron as GE has proposed in the revised Work P lan As stated in an earlier comment GE should use the assumptions in EPAs Wi ld l i f e Exposures Guidance in developing the dietary model for heron

36 I n the revised Work P lan GE has responded to each of the Agencies concerns on the av ian community structure study (which has already been conducted by GE ) The Agencies appreci bulllt GEs responsiveness to Agency concerns about the avian study However after further consideration of the study design t h e Agencies have concluded that its limitations are too tnrcai provide a reliable measurement Therefore the study should not be included as a l ine of evidence in the risk assessment Furthermore the Agencies would discourage GE from conducting further avian community studies because it is unlikely that GE would be able to demonstrate that such a study meets the criteria listed in comment 12 for a study providing a meaningful measure of effects

37 The Agencies have reviewed the additional information on the insectivorous bird reproduction study provided in the revised Work Plan and in the paper by Hemming el al (1997) and have gi n it ful l consideration However ihe Agencies st i l l believe that there are signif icant l imitat ion1 n the s tudy design in par t icu lar t h e endpoinls tha t were not considered in t h e evaluat ion of reproductive impairment Therefore the study should not be included in the risk assessment

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Mammals

38 The Agencies disagree with GEs proposal to estimate rather than measure the PC 13 body burden of white fooled mice IK a food source to higher organisms FCB con central ions should be measured i n white fooled mice (and otha snrial I mammal s that are prey items of fox mink and great blue heiron) GE should not large specific small mammal species for col led ion and analysis but instead should analyze all small mammals trapped in a given area over a given lime period GE should propose a protocol for small mammal s ampl ing and analysis It would be desirable to segregate I he animals collected in the trapping effort into herbivores and non herbivores With this information biota- sediment factors loir sediment lo soil invertebrates and invertebrates lo small mammals could be evaluated against (lie empirical data derived from analysis of the nonherbivores

As stated previously in comment I 9 a combinat ion of analy t ica l protocols may be needed for prey items ( inc luding congener-specific ariallyses homologs and Airocloir data) To ensure thai plans and protocols w i l l meet cunenl Agency data requirements as eff ic ient ly as possible CJE should work in consul ta t ion with the Agencies to d e v e l o p appropr ia te combinations of analyse for each prey i tem target l i s t s of congeners and sampl ing plans to obtain congener data in representat ive sample s

( i f b h o u l d a l s o o l i S L i v t - a n d doujnuiit morphologica l ab i i o im ih ik s l o r a l l - m a l l m a m m a l s captured

Endangered and Threatened Species

39 Dietary modeling for the wintering population of bald eagles in Connecticut should not use PCB tissue levels i n brown I rout PCB levels in warmwater lake fish species that bald eagles feed on during the winter should be ei ther measured or est imated If GE opts lo measure PCB lissue leve ls in warmwaler lake fis h such data could be col lected as part of (he ongoing t r end monitoring program in Connect icut I f GE opts not to measure PCF1 t i s s u e l e v e l s in l ake f i sh GF s h o u l d estimate level 5 based on the database of PCB levels in fillets available for warm water lake fV-h species

The Agencies stated in previous comments to GE that dietary modeling to bald eagles in Massachusetts was not necessary because Massachusetts eagles are l i k e l y to receive much less PCB exposure due to their transient nature Based on recent information the Agencies have determined that model ing lo eagles in Massachusetts should be included in t h e r isk assessment

According to the Massachusetts Division of Fisheries and Wildl ife the bald eagle population in Massachusetts is increasing at a rate comparable lo gains being seen across the northeastern U S and eastern Canada Numbers of both wintering and nesting bald eagles are up result ing in t h e u^r of new habitats In aireas west of the Connecticut R i v e r i n Massachusetts the lower Housatomc R n c r is expected to serve an i n c r e a s i n g l y s ignif icant role as a w i n t e r i n g area and may even t u i l l i become colonized by nesting eagles Wintering eagles (2) vere confirmed on the Housatonic in Sheffield Massachusetts during the 1997 Midwinter Bald Eagle Survey Other reliable reports were received outside of t h e two-week survey period An A p r i l 199 report of an eagles nest along the Housatonic in Lee Massachusetts was unconfirmed but w i l l be re invest igated i n the

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spring of 1998 A spiring snowstorm is believed la have destroyed what was reported to be a newly-constructed eagles nest Because line Massachusetts |gtortiion of the river has significantly higher PCB sediment concentrations than the Connecticut portion dietary modeling of wintering eagles iiri Connecticut wil l molt adequately characterize potential risks to eagles in Massachusetts Thus in addition to modeling wintering eagles in Connecticut GE should also develop a dietary model for bald eagles in the Massachusetts portion of the Housatonic River from Lee south to the Connecticut border Modeling in Massachusetts should include both nesting and wintering exposures

In developing dietary intake estimates for bald eagles GE should consider the following literature-dietary composition as measured by Welch (1994) and fish to eagle biomagnification factors developed by Bowerman et at (1995) GE should also consider effect thresholds published in (Sprunt 1973 and Wietneyer 1993)

Wetland Communities

40 GE has proposed to use the standard Wetland E v a l u a t i o n Technique (WET) as one step in assess ing -wetland connrn u n il ies Rather 1 nan use WET the Age ncies stron g ly recommend that (i I-use the Army Corps of Engineers method loir evaluating wetlands (U S ACE 1996) because it is more current and regionally-accepted

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A n k l e y GT GJ Nieirni KB Lodge HJ Harris DL Beaver DE Til lent TR Schwartz IP Giesy D Jones and C Hagley 1993 U ptake of Planar Polychloruiated B iphenyls and 2378-substituled Polychlorinated Dibenzofurans and Dibenzo-p-dioxins by Birds Nesting in the Lower Fox River and Green Bay Wisconsin USA Arch Environ Contain Toxicol 24 332-344

Bowerman WJ J P Giesy DA Best and VI Kramer 1995 A Review of Factors Affec t ing Productivity of Bald Eagles in the Great Lakes Region Implications for Recovery Environmental Health Perspectives 103 (Supplement 4) 51-59

Birge WJ JA Black and A G We Merman 1978 Effects oj Polychlormated Biphenyl Compounds and Proposed PCB-Replacement Products on Embryo -Larva Stages of Fish and Amphibians Prepared by Kentucky Water Resources Research I n s t i t u t e Lexington for the U S Envi ronmenta l Protection Agency Office of Waler Research and Technology Washington DC

Can fie Id RJ FJ Dwyer 1 F F a i r c h i l d P S Haverland C G Ingersol l NE Kemble DR Moun t T W LaPoint G A Burton MC Swi f t 1996 Assessing Contamination in Grea t Lakes Sedimenls Using Benthic Invertebiale C o m m u n i t i e s and the Sediment Qual i ty Triad Approach J (treat I uk(- Rc I lt gt ) S 6 5 - X

Chapman P M 1992 Sediment Quaitv Triad Approach in US EPA Sediment Classification Methods Compendium EPA 823-R-92-006

Eganhouse R P and R W Gossett 1991 Sources and m a g n i t u d e for bias associated with determination of PCBs in environmental samples Anal Chem 63 2130-213

Froese KL I) A Verbrugge GT Ank ley GJ Nieirni C P Larson and JP Giesy 199 Bioaccumulation of PCBs from Sediments to Aquatic Insects and Tree Swallow Eggs and N e s t l i n g s in Saginaw Bay Michigan Environ Toxicol Chem In press

Henning M HL 1ES Eber RE Keenan S G Mania and J W Duncan 1997 Assessment of c f f f t t i of PCB- contaminated floodplam soils on reproductive success of insect ivorous songbirds Chemosphere 3 4 1 1 2 1 - 1 1 3 7

Hilsenhof W L 1982 Using a bioiic index to evaluate water qualify in streams Technica l Bu l l e t i n No 132 Department of Natural Resources Madison WI

Hilsenhof WL 1987 An improved biotic index loir organic stream pollution Great Lakes Entomb 2031-39

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K l e m m Donald J P h i l l i p A Lev i s More nee Fluke and James M Laôrchak 1990 Macroinvertebrutt Field and Laboratory Methods For Evaluating The Biological Integrity of Surface Water E PA6004 -90030 Move mbe r 1990

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Long ER McDonald DD Smith 8L and FD Calder 1995 Incidence of adverse biological effects within ranges for chemical concentrations in marine and estuarine sediment Environ Management 1981-97

M ac MJ T R Schwaitx CC Edsall and A M Fra nk 199 3 Polyc h lorin ated B iphenyl s in Great Lades Lake Trout and their eggs Relations to survival and congener composition 1979-1988 J Great Lakes Res 19(4)752-765

Andrew Major US Fish and Wi ld l i f e Service Concord NH June 26 1997

Mauck WI PM Mehrle and FL Mayer 1978 Effects of the Polychlorinated Biphenyl Arocloir 1254 on Growth Survival and Bone Development in Brook Trout ( S a l v e l m u s fontinalis) J Fih Res Board Can 3 5(8) 1084-1088

McDonald DD 1994 Approach to ihe assessment of sediment quality in Florida coastal waters Volumes I and 2 Report prepared for the Florida Department of Environmental Protection Tal la h as gtec FL Nov ember 19 u

Nebeker AV FA Puglisi and D L Defoe 1974 Effect of Po lych lo r ina t ed B ipheny l Compound gt gt n Survival and Reproduction of the Fathead Minnow and Flagf ish Trans Am FishSoc 103(3) ltvshy568

Newsted JL JP Giesy GT Ankley DE Tillit RA Crawford J W Gooch PD Jones and M S Denison 1995 Development of t o x i c equivalency factors for PCB congeners and the assessment lt gt i TCDD and PCB mixtures in r a inbow trout Envi Toxicol and Chem 14(5) 861-867

Nichols J W CP Larsen ME McDonald GJ Niemi GT Ankley 1995 Bioenergetics-based Nisid for Accum u lat ion of PC Bs by Nest I mg Tree Swal lows Taci cineta bicolor En vi Set Tech 2 9 ( 3 ) 6 0 4 - 6 1 2

Persaud D R Jaagumagi and A Hayton 1992 Guidelines for the Protection and Management of Aquatic Sediment Quality in Ontario Toronto Ontario Water Resources Branch Ontario Ministn bull ( the Environment

Plafkin James L Michael T Barbour Kimberly D Porter Sharon K Gross and Robert M Hughes 1989 Rapid Bioassessment Protocols For The Use In Streams and Rivers EPA4444-89-00 Ma 1989

Sprunt A I V WB Robertson Jr S Pos tupalsky RJ Hensel CE Knoder and F J Ligas 11973 Comparative Productivity of Six Bald Eagle Populations Trans N Amer Wildlife Nat Res ( n u t 38 96-106

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US EPA I993a Wildlife Exposure Factors Handbook Volumes land II US Environmental Agency Office of Research and Development Washington EG EPA600R-93187a and b December 1993

US EPA 1993b Technical Basis for Establishing Sediment Quality Criteria for Nonionic Organic Chemicals Using Equilibrium Partitioning Office of Science and Technology Health and Ecological Criteria Division Washington DC

US EPA 1994 Methods for measuring the toxicity and bioaccumulation of sediment -associated contaminants withfreshwater invertebrates EPA 600R-94024 D u l u t h MM

US EPAUS ACOE 1991 Ecological Evaluation of Proposed Discharge of Dredged Material in Ocean Waters US EPA Office of Wa(er Washington DC

US Fish and Wildlife Service 1997 Polychlorinated Biphenyl Contamination of Tree Swallows in the Upper Hudson River Valley New York Effects on Breeding Biology and Implications for Other Bird Species New York Field Office U S Fish and Wildl i fe Service Cortland NY Preparers Anne I Secord and Dir John P McCarty March 1997

US Geological Survey 1997 Geological Distribution and Potential for Adverse Biological Effect I Selected Trace Elements and Organic Compounds in StreambedSediment in Connecticut Housntonic and Thames Rier BIIMH W-9W DSGS-97-4169 Authors R F Breau l t and s I Harris

Welch LJ 1994 Contaminant Burdens and Reproductive Rates of Bald Eagles Nesting in Maine M ^ Thesis Univ of Maine Oirono 86 pp

Wiemeyer SN CM Bunck and CJ Stafford 1993 Environmental Contaminants i n Bald Eagle Eggs 1980 - 1984 and Further Interpretations of Relationship to Productivity and Shell Thickness Arch Envir Contam Toxic 24d 213-227

World Health Organization 1997 Draft Report on she Derivation of Toxic Equivalency Factors fTf-t laquo for PCBs PCDDs PCDFs and other dioxin-like compounds for humans and wildlife June 1 5- X 1997 Stockholm Sweden

Zabel EW PM Cook and RE Peterson 1995a Potency of 33445-pentachlorobiphenyl (PCB 126) alone and in combination with 2378-tetrachlorinated dibenzo--dioxin (TCDD) to produce lake trout early life-stage mortality Environ Toxicol Chem 14(12)2175-2179

Zabel EW PM Cook and RE Peterson 1995b Toxic equivalency factors for PCDDJPCDF PCFh based on early life stage mortality in rainbow trout Aquatic Toxicol 31 3 15-328

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Attachment A

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REVISED TABLE 2-s ASSESSMENT and MEASUREMENT ENDPOINTS

for the ENVIRONMENTA L RISK CHARACTE RIZA T1ON of the HOUSATONIC RIVER

RECEPTOR ASSESSMENT ENDPOINT

Benth ic Survival reproduction In vertebrates growth and indigenous

community structure function and species composition of benlhic invertebrates

Fish Survival reproduction and grovi t h of indigenous fish species

Amphib ians Survival reproduct ion and growth of indigenous 3 m phibians

MEA SU RpoundM E NT ENDPOIN T

Twenty-eight day whole Sediment loxicity test wi th the amphipod Hyal lela azteca and whole sediment toxiciry test using a chironomid species

Comparison wi th EPA SQC and Ontario LEL and S E L s

Communi ty composition biomass species diversity richness species dk-nsiu and total lax a in impacted area compared to comparable reference local i ons ant to co-located PCB concentrations in sediment at one point in time

Egg v iab i l i ty hatching success pos t -ha tch survival larvae morphological a n o m a l i e s number pf eggs per adult female mean egg sie t i m e 10 h a t c h growth and tissue concentration of HCBs in egg arid a d u l t b rown b u l l h e a d largemouth bass

Compare total PCBs and congeners in CT brown trout t issue to Maximum Allowable Tissue Concentrations from literature

Compare total PCBs and congeners in YO Y bullheadbass tissue and bullheadbass eggs with Maximum Allowable Tissue Concentrations from literature

Hatching rate post-hatch survival of bul l frogs fe r t i l i za t ion rate ege and sperm v iab i l i ty number of eggs per adu l t female morphology

Percent giavid females in collected in Held compared to reference area

Reptiles Survival reproduction Clu tch size hatching success and morphology of snapping turtle young and growth of indigenous reptile

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RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals

P i s c i v o r o u s Mammals

Threatened and End angered Species

ASSESSMENT ENDPOINT

Survival and reproduction of carnivorous birds

Surv ival reproduction and growth of insectivorous buds

Survival and reproduction of piscivorous buds

Survival and reproduction of omnivorous mamma Is

Survival ri product ion and growth of piscivorous mammals

Individual survival and reproductive success of threatened and endangered species

MEASUREMENT ENDPOINT

Toxicity Quorienl based on dietary intake of PCiBis by American robins using site-specific PCB levels in earthworms

Toxicity Quotient based on dietary intake of PCB s by tree swallows from emergent aquatic insects using site-specific PCB levels in insects

ToKic i ty Quotient based on dietary intake of PCB s in fish by kingfisher

ToMci ty Quotient based on dietary intake of PCB s in fish by great blue heron

To Mary Quotient based on dietary intake of PCBs by fox using measured PCB leve l s in a variety of small mammal s rolled ed i n the impacted area

n Quo t i en t based on dietary in take c t PCUs b gt m i n k using s i t e - s p e c i f fish t i s s u e concentrations and measuied PCB levels m o ther dietary items (c rav H s h frogs small mammals I

ToMci fy Quotient based on dietary intake of PCBs by bald eagles using si te-speci f ic fish tissue concentrations and site-specific PCB concentrations in other dietary i tems (small mammals birds)

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D R A F T 11698

I GENERAL COMMENTS

Page I-2 of the linitroduiction includes the following statement The purpose and objectives of the tasks outlined in this work plan will be to determine whether releases of chemicals from line GE facility to the Mousatonic River S ite have or could be expected to adversely affect terrestri all or aquatic populations with polenlial for exposures to releases Tine Work Plan later states that the reproducing population is the smallest unit that we can meaningfully protect

These statements misconstrue the Agencies regulatory objectives The Agencies concerns are not limited to observable deleterious effects on entire populations or communities Rather than focusing oni entire populations the risk assessment should address impacts on the subsets of organisms or local subpopulations that are more likely to be exposed to contamination a t and from the site

The Agencies agree that the kinds of effects that are relevant for hazardous waste site management are those that could adversely effect a population the entire population were exposed E x a m p l e s are reduced reproduction prey depletion or direct toxic effects However at most sites i n c l u d i n u this one the extent of contaminat ion is small when compared to the classic d e f i n i t i o n for I he geographical range of wildl ife populations of concern Thus measurable changes in a population as a whole are u n l i k e l y Therefore the risk assessment s h o u l d focus on the s u b p o p u l a t i o n s ol o r g a n i s m s that are exposed in the c o n t a m i n a t e d area This is c l ea r ly stated as a r e q u n e r n e n i i n M bull Massachusetts Contingency Plan at 310 C1VIR 40 0995 ( 4 ) ( b ) ( l )(a))

The Agencies note that adverse effects on subpopulations may be difficult to measure by f i e ld studies Moreover the World Health Organization recent ly published a document suiting thai harmful effects (eg effects on survival growth and reproduction) of PCBs and other d ioxin-hke chemicals are difficult to detect at the population level Therefore methods to assess and predict effects on individuals are required (WHO 1997)

Further by assessing the wildlife that are actually exposed the risk assessment evaluates whether the contaminated habitats are functioning as would normal heal thy habitats i n the absence of contaminants Vital funct ions include p rov id ing adequate food and shelter and s u s t a i n i n g normjI reproductive success The cen t r a l question for purposes of this assessment is whe the r (he exposed sub-populations are thr iving in the contaminated habitat not whether t h e larger regional population is surviving in spite of it

GE has cited a number of compensatory mechanisms that can enable populations to survive in spite of the loss of individual organisms from toxic effects One example cited is migration Organisms thai have moved from clean areas may be observed in a contaminated area in apparently normal numbers clue to migration In the Agencies view though the mere presence gt l a normal number of animals in a contaminated area does not demonstrate that the population is unaffected or that the habitat is providing normal support funct ions If com arm riant l e v e l s are su h that organisms could not reproduce normally or t h r i v e in an affected area without being replenished then the Agencies wou ld view those levels as harmful

Chemical adaptation is another compensatory mechanism w h i c h a l though not emphas i sed by i i l is likely to be a factor at this site part icularly for fish populations This mechanisms leads to the selection of genotypes that are resistant to a chemical as a result of the elimination of ind iv idua l organisms that are more sens i t ive The result is a population wi th an al tered generic makeup

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6 Page 1-3 of the Work Plan states that the Ecological Risk Assessment wi l l attempt where f ea s ihk to evaluate mul t iple lines of evidence for the same assessment endpoint and to use all re levant data Though it may be he lp fu l to evaluate mul t ip l e l ines of evidence for 1 lie same assessment endpoint it is important not to flood the list of measurement endpomis w i t h i r re levant or insen siti ve measures which could dilute or obscure the more pert inent me asures Flue tec h n ic all comments w h i c h follow identify specific measurement endpoints which are not sensit ive measurements and therefore should be eliminated from the risk assessment




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RECEPTOR

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Insectivorous Buds

Piscivorous Birds

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Insectivorous Buds

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Piscivorous Birds

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ASSESSMENT ENDPOINT















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Emergent Insects




8 of Protocol B-2 states that insect sampling wil l extend over a period of six nights contingent upon weather conditions The Agencies note that sampling should continue for as long as necessary to collect adequate biomass for analysis



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D R A F T I A 11698 I J











- 13


D R A F T 116981 H









bull 14 shy

| l6wkpln doc

D R A F T 11698








bull 15shy

jlfiwkpln doc 11698

D R A F T 11698


Amphibians


Reptiles






Birds


- 1 6 shy


D R A F T 11698








- 17 shy

j 6 w k p l n doc 11698

D R A F T 11698

Mammals








- 18


D R A F T II11698



Wetland Communities


- 19shy

j lbwkpln doc 11698

D R A F T 1 j 11698

References C Lied













bull 20

j 1 6wkpln dlcK

D R A F T I1698














- 2 I shy


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 116981 H









bull 14 shy

| l6wkpln doc

D R A F T 11698








bull 15shy

jlfiwkpln doc 11698

D R A F T 11698


Amphibians


Reptiles






Birds


- 1 6 shy


D R A F T 11698








- 17 shy

j 6 w k p l n doc 11698

D R A F T 11698

Mammals








- 18


D R A F T II11698



Wetland Communities


- 19shy

j lbwkpln doc 11698

D R A F T 1 j 11698

References C Lied













bull 20

j 1 6wkpln dlcK

D R A F T I1698














- 2 I shy


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 11698








bull 15shy

jlfiwkpln doc 11698

D R A F T 11698


Amphibians


Reptiles






Birds


- 1 6 shy


D R A F T 11698








- 17 shy

j 6 w k p l n doc 11698

D R A F T 11698

Mammals








- 18


D R A F T II11698



Wetland Communities


- 19shy

j lbwkpln doc 11698

D R A F T 1 j 11698

References C Lied













bull 20

j 1 6wkpln dlcK

D R A F T I1698














- 2 I shy


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 11698


Amphibians


Reptiles






Birds


- 1 6 shy


D R A F T 11698








- 17 shy

j 6 w k p l n doc 11698

D R A F T 11698

Mammals








- 18


D R A F T II11698



Wetland Communities


- 19shy

j lbwkpln doc 11698

D R A F T 1 j 11698

References C Lied













bull 20

j 1 6wkpln dlcK

D R A F T I1698














- 2 I shy


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 11698








- 17 shy

j 6 w k p l n doc 11698

D R A F T 11698

Mammals








- 18


D R A F T II11698



Wetland Communities


- 19shy

j lbwkpln doc 11698

D R A F T 1 j 11698

References C Lied













bull 20

j 1 6wkpln dlcK

D R A F T I1698














- 2 I shy


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 11698

Mammals








- 18


D R A F T II11698



Wetland Communities


- 19shy

j lbwkpln doc 11698

D R A F T 1 j 11698

References C Lied













bull 20

j 1 6wkpln dlcK

D R A F T I1698














- 2 I shy


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T II11698



Wetland Communities


- 19shy

j lbwkpln doc 11698

D R A F T 1 j 11698

References C Lied













bull 20

j 1 6wkpln dlcK

D R A F T I1698














- 2 I shy


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 1 j 11698

References C Lied













bull 20

j 1 6wkpln dlcK

D R A F T I1698














- 2 I shy


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T I1698














- 2 I shy


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 11698












- 22 shy

11(598 II6wkplridoc

D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 11698

Attachment A

Revised Table 2-5

bull 23


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 11698


















24 shy

11698 |16wkpln doc

D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


D R A F T 11698

RECEPTOR

Carnivorous Buds

Insectivorous Buds

Piscivorous Birds

Omnivorous Mammals



ASSESSMENT ENDPOINT















j lbwkpln doc

barcode 42480


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