consolidated agency comments on

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CONSOLIDATED AGENCY COMMENTS ON “DRAFT PHASE 2A SEASONAL BIOLOGICAL DATA WORKPLAN”

(April 26, 2016)

GENERAL COMMENTS (these apply to multiple sections of the draft workplan) 1. The draft workplan states that the data collection efforts described are “needed to complete the

baseline ecological risk assessment”. The Agencies agree that this is the proper criterion by which data needs may be identified, but does not agree that the bird survey identified as a data need meets this criterion. More detailed comments are provided below for Section 4 of the draft workplan.

2. The draft workplan includes a placeholder (Appendix A) for why egg data were not collected. As discussed previously, while the Agencies agree that the egg data collected previously are likely to be relevant and useful for risk assessment purposes, ERM has not evaluated whether the egg data are sufficient to support the baseline ecological risk assessment. Thus, it is currently uncertain whether additional egg data are needed or not. However, if it were determined that additional egg data are needed, because of ERM’s failure to adequately plan for this effort, it is no longer feasible to obtain permits in time to allow egg collection this spring. Hence, the issue is moot. Because none of the wildlife species planned for evaluation in the BERA include eggs as part of the diet, egg data are not needed to develop site-specific food web exposure models. Consequently, the Agencies recommend that all mention of egg data and all discussion of why additional egg data are or are not needed simply be deleted from this workplan. Once the workplan for biotic food web modeling is approved, ERM should then promptly proceed to determine if the existing egg data are adequate for the BERA.

3. Objective 1 of the workplan has been divided into two sub-parts. The first stated goal is to obtain information of the location, taxa composition and abundance (mass) of prey species, and the second stated goal is to obtain paired measurements of COPC levels in abiotic and biotic media such that site-specific uptake models can be developed. The Agencies believe the second objective is the primary purpose of this effort, and that the first goal can simply be subsumed into the second goal, thereby substantially simplifying the workplan. Specifically, the workplan can state that a description of whatever biotic material was collected at each location (taxa composition, mass collected, sampling effort required) will be reported. This information will serve to identify where biotic samples were easy and difficult to obtain, but avoids the assertion or implication that such data constitute a reliable ecological characterization of the taxa composition or abundance in the area.

4. In several locations, the purpose of developing site-specific uptake models is stated to be the development of site-specific PRGs. In all cases, the purpose of the site-specific uptake models should include estimation of exposure and risk in locations where site-specific prey concentrations have not been measured as well as in the development of PRGs (as is done on the top of page 13.)

5. Nowhere in the SAP or the SOPs are the shape and size of sampling areas clearly stated, but it appears that each area is envisioned as a circle with a radius of 5 meters. The size and shape of planned sampling areas should be presented explicitly. In addition, an area this size and shape may

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not be optimal in all cases, depending on the quality and extent of habitat. The Agencies recommend that a distinction be made between upland/terrestrial and lakeshore/playa sampling areas. Consider defining an upland/terrestrial sampling area as a shape that is approximately circular with a radius of 5 to 15 meters, depending on habitat quality and extent. Consider defining a lakeshore/playa sampling area as an approximately rectangular zone along the edge of a water body, with the length and width of the zone depending on habitat quality and biota abundance at the time of sampling.

SPECIFIC COMMENTS (not already covered under general comments above) Section 2.1 This section lists a number of studies that have been performed which contain data that may help inform the optimal design of the biotic tissue sampling and analysis plan. However, none of the data are described or utilized. In particular, available data on the concentration of contaminants in several different types of biotic tissue from site locations and reference locations available in the Parametrix report are not reviewed or used to evaluate which analytes appear to be higher in on-site samples than in reference samples. This information should be considered as a potential addition (or alternative) to the proposed approach of using abiotic data to identify target analytes in biotic tissues. Section 3.1.1 Pg. 12. The text states that there are concerns regarding the quality of historic tissue burden data. Provide a brief description of the data quality concerns identified by ERM. Section 3.1.3 Pg. 14. The need for evaluation of metals in prey items is listed as “TBD”, depending on a comparison of concentrations measure in abiotic site samples compared to reference samples. As noted above, information on the need to evaluate metals may be inferred from an assessment of available biotic data as well as abiotic data. Based on a preliminary evaluation by the Agencies, several metals do tend to be higher in site samples than reference, and hence the Agencies conclude that metals should be included in the target analyte list. Pg. 14. The analyte list presented shows lipid content as a target metric to be measured when sufficient mass is available. The Agencies understand that normalizing measure tissue concentrations to a lipid basis may help minimize variability in an uptake model, but application of a lipid-based uptake model to predict concentrations in wildlife prey items requires a selected value for the lipid content of the prey. This results in an essentially circular calculation where the final predicted concentration in the prey is equal to what was measured divided by the lipid and then multiplied by the lipid. The Agencies feel that the objective should be to develop either wet-weight or dry-weight based uptake models, and that lipid normalization is unlikely to be essential.

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Pg. 15. The soil or sediment sample that is collected at a biotic sampling area should be a multi-point composite that seeks to characterize the average concentration in the entire collection area rather than a single grab sample or a small-scale composite located near the center of the collection area. Section 3.1.4 The text states the spatial boundary includes areas adjacent to the facility, but sampling is only proposed for locations in PRIs 1-12. However, it is not clear what is meant by “adjacent to the facility”. That term should be clearly defined and then used consistently. Next, the logic for why sampling is not needed either in buffer areas or in reference areas is not clearly presented. Available data from the Phase 1A and Phase 1AB studies indicate that concentration values of key indicators (e.g., PCB-209, OCDF, HCB) are higher in the inner PRIs than in the buffer areas, and that concentrations are higher in the buffer areas that in the reference area. Thus, in order for the uptake model to have the maximum span of concentration ranges, the Agencies require that two or more additional sampling areas be established in buffer areas and two or more be established in a reference area. These data will help define and constrain the uptake models at the low end of the concentration range, which is likely to be the most important part of the range for calculating PRGs. Section 3.1.5. Pg. 16-17. The workplan should add more detail (either here or in Step 7) as to how regression modeling of each paired abiotic-biotic data set will be performed. This should include a discussion of the structural equations that will be tested, the statistical method for model parameterization, and how the preferred model will be selected. This discussion should follow the basic concepts and techniques that are described in EPA’s Benchmark Dose Software (BMDS) guidance. Section 3.2.1.1 Pg. 19. The text indicates that the number of sampling locations was based in large part on estimates of the level of effort needed. Level of effort is not a proper basis for deciding how many samples are needed. Rather, the decision should be based on an evaluation of how many samples are required to provide a data set that will be adequate for the intended purpose. Revise the text to explain why a set of 15 samples is expected to be adequate. Section 3.2.1.2 Pg. 19. The first paragraph and the three following bullets are repeated in Section 3.2.2.2 and should be deleted from Section 3.2.1.2. Section 3.2.2.1.

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Pg. 20. Previous drafts provided an explanation that concentration ranges (low, intermediate, upper) would be defined based on percentiles of the Phase 1AB data. This description should be retained in the final version of the SAP. In addition, Table 3-1 should present the numeric concentration ranges for each target COPC that are classified as low, intermediate or upper. Section 3.2.2.2. Figures 3-2 and 3-3 are of very low quality and are not readable. Provide these figures in proper format, and accompany each map with a table that briefly describes each sampling location and gives the observed or expected concentration levels of key COPCs at each location. All measured and estimated (e.g., by kriging) concentration values used for mapping and to classify concentrations at proposed sampling areas should be based on currently available data from the Phase 1AB study rather than historic data. Section 3.3 Pg. 23. As noted above, the soil or sediment sample collected at each area should be a multi-point composite that represents the average of the biotic collection area, not a grab sample or small-scale composite located in the center of the collection area. Section 3.3.2.1 Pg. 25. Delete the final sentence in the second paragraph. It is irrelevant whether other agencies have used this method or not. Section 3.3.3 Pg. 27. Specify how many pitfall traps will be deployed in each collection area. Specify how a decision will be made as to whether or not additional plastic cups will be deployed, and how many. Also, describe conditions that will be selected for the placement of pitfall traps, such as under bushes, along trails that are evident by tracks in sand, etc. Section 3.3.6. Pg. 32. Specify how many small mammal traps will be placed in each collection area. Specify the units of temperature (C vs F) used to define conditions when trapping will not occur. Section 4

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After review of the goals and the study design, the Agencies do not believe that an on-site bird survey performed as proposed will provide data that are important for completion of the BERA. This is because:

1. Several studies which determined the types of bird that utilize the site have already been performed, and the avian species that will be evaluated quantitatively in the BERA have already been selected. Additionally, ERM has recently characterized the habitat on the Site, and this information can further refine avian species likely to be present. The Agencies do not believe that an additional bird survey will provide any new information that will significantly alter the current ecological conceptual site model.

2. Any survey of mobile receptors such as birds has high variability, both within and between years, so a single survey does not provide sufficient data to derive a reliable characterization of bird numbers or species that utilize the site for nesting or feeding. Moreover, the DQOs state that “Information from this study will be qualitatively used to characterize the breeding bird population...”. In general, qualitative information does little to help develop quantitative estimates of hazard or to reduce uncertainty in the baseline ecological risk assessment.

3. While information on the expected (as opposed to observed) density of bird species may be useful in final risk management decision-making, such information is not necessary to characterize risk and cannot be determined by field surveys of a potentially impaired population.

In accord with the finding that the bird survey will not provide data that are important for completion of the BERA, the Agencies require that this section be removed from the workplan. If it is retained in the workplan, the Agencies will not approve this section. Section 5.1 The electronic data package should include one or more data files that present analytical results on a sample by sample basis. Is that what intended by item 4 on the bottom of page 44? Appendix A As noted above (see general comment 2), this appendix is now moot and may be deleted. Appendix B Appendix B refers to box plots that indicate COPC concentrations are similar in buffer areas and in reference areas. However, no box plots were included. These must be included to allow evaluation of the data. Appendix C

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Appendix C provides box plots that compare mercury concentrations in abiotic samples, both for site, buffer and reference areas. The text states that mercury concentrations appear similar in PRI areas and reference areas, and hence no analysis for mercury is needed. The Agencies have several concerns with this evaluation, as follows:

• Visual comparison of box-plots is not the most reliable way to compare data sets. Rather, whether two data sets are the same or different should be determined using appropriate statistical techniques that account for sample size and variability. Even so, based on simple visual inspection of Figure C-1 (which displays data for only some of the PRIs), the range of data values is substantially wider for site samples (both upland and lake bed) than for the Bear River reference location. For example, the maximum value observed in Bear River samples appears to be about 0.035 ppm, while lakebed samples range up to about 0.17 ppm.

• Visual inspection of Figure C-2 (which is log-scale, and includes PRIs not included in Figure C-1) reveals a clear elevation in mercury in PRI 3 compared to reference, and it seems likely that PRI 4 is also elevated.

Accordingly, the Agencies recommend that mercury be included in the list of target analytes. Comments on Appendix D (SOPs) General 1. None of the SOPs for collection of biotic samples include the normal level of detail that is expected

and optimal. According to EPA guidance found in EPA QA/G-6 Guidance for Preparing Standard Operating Procedures (SOPs) – “SOPs should be written with sufficient detail so that someone with limited experience with or knowledge of the procedure, but with a basic understanding, can successfully reproduce the procedure when unsupervised.” Each SOP should be reviewed and modified to include all needed details.

2. None of the SOPs for collection of biotic samples include a scale in the equipment list. The agencies recommend that a portable electronic scale with gram accuracy capable of weighing samples in the field be included in the required equipment list of each SOP, so that field crews can estimate the mass of sample that has been collected in order to judge whether additional sample mass is needed.

3. The term “dry ice” is used in multiple SOPs. Clarify if this means solid carbon dioxide or if it means frozen packets of “blue ice” designed to maintain samples near 32 degrees F during shipment in a cooler.

4. Each SOP has a section on deviations. The second paragraph contains two typographical errors that require correction, as follows:

In cases where a deviation is considered to be “minor,” if both ERM and USEPA agree in “real time” that the deviation is appropriate, then it may be implemented and subsequently documented (e.g., later that day) by completion of a Field Modification Form. Note that agreement must be reached before implementation of any such deviation; this may be

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accomplished by a consultation between the field team leader and an EPA oversight representative present at the Site or by calling the EPA Remedial Project Manager designee. In the event that an EPA representative cannot be reached, or if an EPA representative cannot issue a decision in “real time,” then no deviation shall be implemented until authorization is granted.

5. Delete all statements that a method has been used by other “reputable” groups or agencies. Whether or not a method is used by other agencies is irrelevant, and it is not for ERM to assign a quality adjective such as “reputable” to any such group or agency.

6. Each SOP states that collection will be performed by ERM staff who have experience with the sampling method. Does ERM have individuals ready to implement the SAP who have experience with each collection method?

7. All SOPs state that sampling locations are shown in Figures 3-2 and 3-3. However, several SOPs are specific to sampling that will occur either in the terrestrial/upland zone (Figure 3-2) or along the mud flats/shoreline (Figures 3-3). When sampling locations for a method are shown in only one of the maps, delete reference to the other map.

Soil Sampling SOP This SOP describes collection of a five-point composite from within a one-meter square. As noted above, this SOP should be modified to allow for collection of a multi-point composite that covers the entire area of a sampling location. Small Mammal SOP 1. Section 2. There is no mention or references of animal safety or welfare considerations with these

procedures. The Agencies recommend that the following be cited and the guidelines therein be followed:

Animal Care and Use Committee. 1998. Guidelines for the capture, handling and care of mammals as approved by the American Society of Mammalogists. Journal of Mammalogy 79:1416-1431.

2. Section 6.2. A State permit is required from the Division of Wildlife Resources for small mammal trapping. The SOP should include a section about acquiring this permit before field work begins. [Note: there may be a substantial lag between application for and receipt of such a permit. Has ERM planned for this?]

3. Section 6.4. Does placing bait in waxed paper and twisting the corners like a Hershey’s Kiss make the bait less attractive than if it were open to the air? Should the bait be partially unwrapped when placed in the trap?

4. Section 6.4. The text establishes guidelines for when temperature becomes too cold for trapping (note...specify if temperature is in units of F or C). However, no mention is made of limitations to trapping if temperature becomes too hot. Add guidelines that define air and/or trap temperatures that are considered dangerous. Exposed traps start heating quickly from radiant heat as soon as

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they are hit by sunlight. For traps that not set in a shaded location, the trap should be provided with a weather-resistant cover that provides shade.

5. Section 6.5. Specify how many traps will be placed in a sampling area. If this is not a constant, specify how the number of traps will be determined.

6. Section 6.5. Why must traps be set on a transect? Why not allow traps to be set in any optimal locations within the sampling area?

7. Section 6.5. The text indicates traps should be set within 2 meters of the [soil] sampling point. As noted above, it is unlikely that it will be appropriate to set all traps in a sampling area as small as a 2 meter circle. In addition, as noted above, the soil sample should be a multi-point composite that represents the entire collection area, and the collection area may be larger, depending on habitat quality.

8. Section 6.5. The Agencies recommend that all traps be uniquely marked with pin flags. When an animal is captured, the unique trap identifier can be easily collected from the pin flag. This is also helpful in ensuring that all traps have been checked for capture for each trap session – recording capture/non capture status on data sheet will ensure that no animals are accidentally left in traps during the heat of the day.

9. Section 6.6. The text states that traps should be checked every 8 hours for four consecutive days. While frequent checking of the traps is definitely appropriate and desirable, a frequency of once every 8 hours does not seem realistic, even for one sampling area, let for alone multiple sampling areas. The schedule for checking traps should be realistic and implementable. As noted above, the Agencies have special concerns about trapping that may leave captured animals exposed to the heat of the day.

10. Section 6.6. The text is silent on the treatment of any non-target organisms that may be captured. Add a statement that non-target species will be released whenever possible.

11. Section 6.8 – The agencies do not believe that sacrifice by “asphyxiation followed by cervical spine dislocation” is needed, and euthanasia by CO2 asphyxiation only is adequate. If cervical dislocati0on is considered necessary, provide a reference for the use of these two methods together. If needed, cervical spine dislocation should only be performed by someone who has experience with this technique.

Brine Fly SOP 1. Section 1.1. The text states that the brine flies collected will be used to “infer the ecological health

and conditions”. This is not correct. The brine flies will be used only to establish an uptake model for aerial insectivores. Delete this assertion.

2. Section 3.5. The text states that sampling will begin with collection of field environmental data, including records of precipitation, wind speed, percent cloud cover and presence of any potential predators. Recognizing that each of these parameters is highly variable, and recognizing that sampling will occur over four days, is it actually important to collect such data? If so, how would these data be utilized?

3. Section 3.5. The text states that five arrays of four bowels each will be set out in parallel. Section 1.2 states that there will be six arrays. Clarify which is correct. Brine flies are very (very) small, and

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an array of 24-bowls may not be adequate to collect enough mass. Modify the SOP to allow for use of additional arrays of bowls, if needed.

4. Section 3.5. Clarify why a “parallel alignment” of bowls is called for, especially if the shoreline is not linear. Why not state that the arrays will be placed about x feet apart, and about y feet from the shoreline?

5. Section 3.5. Brine flies are the most active in morning and evening hours, so, while bowls should be out for 24 hours (as specified in the SOP),they should be set before sunset and organisms recovered by mid-morning.

6. Section 3.5. Has the use of surfactant in the bowl arrays been vetted with the laboratory to ensure the surfactant will not pose any analytical problems?

Brine Shrimp SOP 1. Section 3.2. Correct the font. 2. Section 3.5. The text states that information on precipitation, wind speed, cloud cover, and

presence of potential brine shrimp predators will be noted. Either explain why these observations are needed and how the observations will be used, or else delete this text.

3. Section 3.5. The text of the workplan includes an explanation that by using a net with a 500 um mesh size, it is expected that adult Artemia will be captured but that most juvenile life stages will not. This same text should be included in the SOP. However, if sub-adult life stages are captured in the net, all life stages should be retained in the sample, since avian predators do not distinguish between life stages.

4. The text states that organisms collected in the net will be examined for Artemia. If any other species of organisms were captured, clarify if those organisms will be retained or excluded from the sample. If the latter, this implies the sample will be “hand-picked”. If other invertebrate taxa are encountered and included in the sample, the genus and approximate frequency should be recorded.

Terrestrial Invertebrate SOP 1. Section 1 states that tissue analysis (of terrestrial invertebrates) will be used to infer ecological

health and conditions. This is not correct. The data will be used only to establish uptake models. Delete this claim.

2. Section 2.0 (also Section 7). The types of insects and other invertebrates collected by pitfall traps and by beat sheets or sweep nets may not be equivalent, either in terms of the level of contamination or the types of receptors that utilize them for prey. The Agencies recommend that invertebrates collected by different methods be packaged separately. Section 7 suggests this may be the intended approach, but it is not clear. Revise the SOP to state explicitly that samples collected by different methods will be kept separate, with the potential for compositing to be determined by the BTAG at a later date.

3. Section 2 and Section 7.5. Pitfall traps will contain water with a surfactant. Has this approach been vetted with the laboratory to ensure the surfactant will not pose any analytical problems?

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4. Section 7.5, third paragraph. The text refers to “animals” that will be collected using beat sheets. Later in the paragraph, the text refers to “flies”. Change both to “terrestrial insects and other invertebrates”.

5. The size of beat sheet called for in the SOP (3 ft x 3 ft) is not likely to be adequate. A larger sheet would be more effective.

6. Section 7.5, next to last paragraph. The text indicates that field data sheets will record the number of specimens collected, and from how many different plants. Such data will be difficult to obtain, and the value of such data seems to be minimal. Are such data actually needed?

7. Section 9. Because pitfall traps utilize an aqueous trapping medium, the Agencies recommend that this SOP should include a field blank (a sample of the fluid that is placed in the traps) as a QC sample.

Terrestrial Vegetation SOP 1. Section 2. Add a brief explanation for why information on plant taxa is needed. 2. Section 5 refers to data collection and sampling by a biologist or a botanist. The Agencies

recommend that any team performing characterization of the plant community in a sampling area be a qualified botanist. Section 6.2.2.4 refers to a plant biologist (i.e., a botanist).

3. Section 6.2.2.4 lists four alternative methods for estimation percent cover of various taxa. Indicate which method is most likely to be useful in the upland zones and in the playa zones at the U.S. Magnesium site. The Agencies recommend that a single method (not mixed methods) be used for all locations of the same type (upland, playa).

4. Section 6.3.1 states that sampling locations “will be established according to SOPs”. The location and rationale for sampling locations are established in the workplan, not in some unnamed SOP. Correct the text accordingly.

5. Section 8. The text states that field duplicates [of terrestrial grasses and forbs] will be collected based on the availability of terrestrial invertebrates. Correct this error.

Appendix E Include text that explains why Appendix E is not attached and when it will be developed. Appendix F (Field data Sheet) 1. The data form provided is very general, and does not provide a location to record the approximate

mass of sample collected, or the collection effort. The form should be modified to create space for this information.

2. Beginning on page 4, the field form includes a column for “% Composition”. It is not clear what information this field is intending to capture.