NCD991278540_20000512_Weyerhaeuser Company_FRBCERCLA RI_Response to Comments and Revised Ecological Risk Assessment Study Design Landfill No. 1 Area-OCR

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May 12, 2000
!1ttegrated
E11viro11me11tal
Solutions
Ms. Jennifer Wendel
Remedial Project Manager
USEP A Region IV
Waste Management Division
61 Forsyth Street, SW
Atlanta, GA 30303-3104
Subject: Response to Comments and
Revised Ecological Risk Assessment Study Design
Landfill No. 1 Area, Weyerhaeuser Martin County Facility
State Road 1565, Martin County, North Carolina
Dear Ms. Wendel:
100 Verdae Blvd. 29607-3825
P.O. Box \6778 29606-6778
Greenville, SC
Telephone, 864-28\-0030
Fax, 864-28\-0288
P.r-r-,~ -''"=D
. .
MAY 15 2000
~PERFUND SECTION
As requested in your correspondence of September 23, 1999, this letter transmits written responses to
United States Environmental Protection Agency (USEP A} review comments on the Ecological Risk
Assessment Study Design for the Landfill No. 1 area at the Weyerhaeuser Company Martin County
facility.
Our previous correspondence of October 12, 1999, documented discussions and resolution of
technical review comments that most immediately affected the biological tissue sampling activities
conducted at the Landfill No. 1 area in October 1999. USEPA approval of the October 12, 1999,
response to comment document was received on October 14, 1999, to allow initiation of biological
sampling activities. For completeness, responses to selected technical review comments addressed in
the October 12, 1999, correspondence are repeated herein.
The enclosed attachments provide written responses to the general technical comments and the
specific technical comments on the Ecological Risk Assessment Study Design provided by USEPA on
September 23, 1999. The responses to USEPA review comments are presented in Attachment A and
Attachment B of this letter. For ease of review the original comment is presented in bold typeface
with the accompanying response following in normal typeface.
A revised Ecological Risk Assessment Study Design for the Landfill No. 1 area incorporating
responses to specific agency review comments is provided concurrent with this submittal.
G: \ WI'GVL \l'JT\00-05100\25\2000510025-00B.DOC
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Ms. Jennifer Wendel
Remedial Project Manager
USEP A Region IV
May 12, 2000
Page 2
We truly appreciate your flexibility in addressing selected technical review comments on the Landfill
No. 1 area documents in an effort to allow the biological sampling to be completed in 1999. Please call
if you have any questions during your review of the enclosed information.
Sincerely,
RMT, Inc.
/ 'Cyff) ! J/4r!lf'eGI~ ;kt::~ R. Huibregtse £f
Principal in Charge
Attachments
~d~
aren C. Saucier, Ph.D.
Risk Assessment Coordinator
cc: Jeff Stamps and Steve Woock, Weyerhaeuser Company
Kris Krause, RMT, Inc.
G: \ WPGVI.\PJT\00-05100 \25 \2000510025·008, lX)C
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Attachment A
Response to General
Comments on Both Documents
Ecological Risk Assessment Study Design Addendum
G:\ WPGVL \PJT\00-05J00\25\Z000510025-00S.00::
Weyerhaeuser Company
Mny 12, 2000 Attnclunent A
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General Comments
Screening Ecological Risk Assessment and Ecological Risk Assessment Study
Design and Sampling and Analysis Plan
1.
Landfill 1 Area, Weyerhaeuser, Martin County Site
Phase I groundwater data was collected to assess the potential transport of COPCs from the
Landfill. The Screening Ecological Assessment should present the results of the
groundwater investigation, and discuss the relationship between groundwater and adjacent
wetlands surface water. If contamination exists in the groundwater, it may represent a
source of contamination to the wetlands sediments and surface water. The potential for the
landfill to be a chronic source of pollutants needs to be assessed through a combination of a
thorough understanding of the nature and extent of contamination and the potential
migration of contaminants from the landfill over time. The groundwater pathway should
be included in the conceptual site model and any detected contaminants should be
screened appropriately as Contaminants of Potential Concern (COPCs).
This comment was disc11ssed and resolved as documented in our October 12, 1999,
correspondence.
Consistent with Agency guidance, the Screening Ecological Risk Assessment is not the
appropriate document to present in detail the Remedial Investigation (RI) results for
environmental media, including groundwater. Guidance considers that the Screening
Ecological Risk Assessment steps occur in the project scoping phase where it is likely that site-
specific information on nature and extent of contamination is limited. In the project scoping
phase, USEPA determined that there were no existing chemical analyses of sufficient quality
with which to complete the preliminary ecological risk assessment for the Landfill No. 1 area
concurrent with the RI/Feasibility Study (FS) work planning process. As a result, the
approved RI/FS Workplan identified data to be collected for use in completing the
preliminary ecological risk assessment for the Landfill No. 1 area. The Screening Ecological
Risk Assessment for the Landfill No. 1 area is based on the Task 1 RI data.
However, the comment requested review of the identified constituents of potential concern
(COPCs) for groundwater to identify if additional constituents required consideration in the
planned biological sampling. To respond, a table was prepared that compared the maximum
observed groundwater to the surface water constituent concentrations and a brief summary of
their potential impact on ecological COPC selection. Attached Table A-1 confirms that no
additional COPCs are identified based solely upon groundwater observations
Ecological Risk Assessment Study Design Addendum
G:\ WPGVL \PJT\OO--OS\00\25\7J)(){)510025-008.DOC
1 We1Jerltaruser Company
Mny 12, 2000 Attachment A
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2.
Finally, the Agency will note that a comprehensive presentation and interpretation of the
nature and distribution of COPCs in cover soil, groundwater, wetland soil, and wetland water
will be provided in the Preliminary Site Characterization Summary (PSCS) and RI reports for
the Landfill No. 1 area. The potential for the Landfill to affect underlying groundwater and
adjacent surface waters was investigated as a component of the RI activities.
The assessment and measurement endpoints for both documents should be amended to
include insectivorous and carnivorous birds and carnivorous mammals in the wetland soils
portions of the risk assessments. These taxa are likely .it higher risk for bioaccumulative
contaminants than those proposed and their exclusion is a significant limitation of both
·documents. The assessment endpoints proposed emphasize herbivores and birds. The
chemicals of most concern, dioxins/furans, mercury, selenium, and PCBs, will
bioaccumulate in prey species. They may even biomagnify up the food chain. Herbivores
would probably not be the most exposed to bioaccumulative constituents.
In the case of the Ecological Risk Assessment Study Design and Sampling and Analysis
Plan, the omission of the assessment endpoints inappropriately limits the scope of
additional site assessment. These assessment endpoints should be added, measurement
endpoints defined, and additional sampling to support their evaluation proposed. Because
insectivorous and carnivorous birds and carnivorous mammals are known to use the
wetlands adjacent to the landfill, the exposure pathway is complete, rather than
hypothetical.
The assessment endpoints and representative species for the Ecological Risk Assessment
should be selected after a meeting is held with EPA and the other stakeholders at the Site.
Appropriate biological tissue sample collection for each will also be refined. More specific
suggestions are included in the comments on the Ecological Assessment Study Design
document.
This comment was discussed and resolved as documented in our October 12, 1999
correspondence.
The assessment endpoints for the upland portion of the Landfill No. 1 area were not modified
from those proposed in the Ecological Risk Assessment Study Design. The assessment
endpoints for the wetland portion of the Landfill No. 1 area will be modified as documented
below.
Ecoloiical Risk Assessment Study Design Addendum
G: \ WPG VL \ PJT\00-05100 \25\ Z000510025-008.DOC
2 Weyerhaeuser Company
May 12, 2000 Attachment A
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The Assessment Endpoints for the wetland portion of the Landfill No. 1 area in both the
Screening Ecological Risk Assessment and Ecological Risk Assessment Study Design currently
includes insectivorous birds (American woodcock). This endpoint is referred to as an
omnivorous avian species, but the exposure modeling conducted in the screening risk
evaluations and proposed for the Baseline Ecological Risk Assessment reflects dietary
exposure to invertebrates and insects. Modifications have been made to the text of the revised
Ecological Risk Assessment Study Design for the Landfill No. 1 area to clarify this issue.
Alternate carnivorous assessment endpoints were identified as replacements for the
herbivorous avian and reptilian endpoints (Canada goose and Eastern box hlftle, respectively)
for the wetland portion of the Landfill No. 1 area. Two carnivorous avian species were
identified as replacements based on being potentially more sensitive to bioaccumulating
chemicals. One is the barn owl, a carnivorous avian which is more sensitive to
bioaccurnulating constituents than a carnivorous mammal based on sensitivity of avian
species to a broader range of site-related CO PCs. The second is a wading bird (green heron)
which will eat frogs and other small invertebrates or amphibians. Both represent sensitive
species to the COPCs. Modification to life history tables for receptors, in addition to
associated tissue sampling tables are included in the revised Ecological Risk Assessment Study
Design for the Landfill No. 1 area. Modifications have been made to the text of the revised
Ecological Risk Assessment Study Design for the Landfill No. 1 area to reflect the
modifications to the Assessment Endpoints for the wetland portion of the Landfill No. 1 area.
The addition of a carninvorous mammalian endpoint for the wetland portion of the Landfill
No. 1 area was also discussed. The resolution of the discussion was that additional follow-up
with local mammalian experts was required to discern the nature of the mammals supported
by the habitat and then follow-up to establish their sensitivity to the COPCs. Following a
review and sensitivity analysis of preliminary hazard quotients for carnivorous avian versus
mammalian endpoints, it was agreed that a carnivorous mammalian endpoint should be
included in the Baseline Ecological Risk Assessment based on potential increased sensitivity to
selected individual COPCs. The red fox is included as a carnivorous mammalian endpoint for
the wetland portion of the Landfill No. 1 area. The red fox is assumed to eat small mammals
and the planned small mammal tissue collection as defined is sufficient and appropriate to
model a carnivorous mammalian endpoint for the wetlands.
Attachment A-2 presents updated screening ecological risk calculations. spreadsheet for the
wetlands portion of the Landfill )'Jo. 1 area. The updated spreadsheets reflect the revised
endpoints and the preliminary h~zard quotients, as requested.
Ecological Risk Assessment Study Desig11 Addendum
G: \ WPGVL \ PJT\00-05100\25\l..00051002.'MXIB.IXX
3 Weyerhaeuser Company
May 12, 2000 Attachment A
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3.
Modifications have been made to the text of the revised Ecological Risk Assessment Study
Design for the Landfill No. 1 area to reflect the modifications to the Assessment Endpoints for
the wetland portion of the Landfill No. 1 area.
The Screening Ecological Risk Assessment presented a calculation of the Preliminary
Hazard Quotient (pHQ) for the assessment endpoints which were picked. These pHQs
were then used to further refine (limit) the COPC lists for each assessment endpoint.
Because EPA believes that additional assessment endpoints are appropriate for the Landfill
1 area, we can not approve a more limited COPC list for the Site. If the calculations of
pHQs for the additional assessment endpoints are not performed (as per Section 5 of the
Screening Ecological Risk Assessment), then the COPCs for these endpoints would default
to those presented in Appendix B of the Screening Ecological Risk Assessment (plus any
found in groundwater, per comment 1).
This comment was discussed and resolved as documented in our October 12, 1999
correspondence.
The assessment endpoints for the upland portion of the Landfill No. 1 area were not modified
from those proposed in the Ecological Risk Assessment Study Design for the Landfill No. 1
area. Attachment A-1 presents updated screening ecological risk calculation spreadsheets for
the upland portion of the Landfill No. 1 area inclusive of the preliminary hazard quotients, as
requested.
For the wetland portion of the Landfill No. 1 area, it was agreed that the screening risk
estimates be expanded to reflect the alternate endpoints proposed in response to Comment
No 2. Preliminary hazard quotients as requested have been provided in Attachment A-2. As a
result of additional screening risk estimates for the barn owl, the green heron, and the red fox,
no additional constituents are added to the COPCs to be evaluated in the Baseline Ecological
Risk Assessment.
Several specific constituents were identified as those that may also impact the final list. Three
metals were considered due to their prevalence and concentrations: nickel, vanadium and
chromium. Upon further scrutiny, nickel concentrations did not exceed any published
criteria. However, based on additional discussions relative to use of alternate conservative
screening values, chromium and vanadium will be considered ecological COPCs for surface
water. Consistent with the approach for Welch Creek, trivalent and hexavalent chromium will
be modeled separately in the dietary exposure modeling. Chromium will be speciated in
selected environmental media samples. Based on speciation and properties of chromium in
tissues, chromium in tissues will be assumed to be trivalent.
Ecological Risk Assessment Study Design Addendum
G: \ WPGV L \ PJT\00-05100\ 25\ZOOOS I 0025-008. OCX:
4 Weyerhaeuser Company
May 12, 2000 Attachment A
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4.
5.
The documents do not adequately summarize the toxicological data for cores to support
the TRVs and overall assessment. Toxicity profiles are needed in more detail than the
general description provided in either document. This omission is critical because it leaves
the current risk assessment plan without justification of the selected TRVs. A section
should be added which summarizes toxicological effects data for fish, birds and mammals
for each core. The review should discuss the most pertinent data, and select or derive a
defensible TRV (rather than default to others). We never received this detail for the series
of Welch Creek documents which had similar cores. It should be developed and
circulated for review.
Another TRY-related issue is the definition of adverse effects as impacts to survival and
reproductive rate. The TRV derivation should include consideration of other adverse
effects, such as damage to organs (e.g., liver or kidney lesions, dysfunction). Damage to
organ systems will likely drive the TRV for some of the metals.
For the purposes of the Screening Ecological Risk Assessment, screening ecotoxicity values
were selected from literature to represent a No Observed Adverse Effect Level (NOAEL) for
long-term (chronic) exposure studies.
Full toxicity profiles for the Landfill No. 1 area COPCs for use in the Baseline Ecological Risk
Assessment for the Landfill No. 1 area are provided in the revised Ecological Risk Assessment
Study Design for the Landfill No. 1 area submitted concurrent with this response.
Additional detail on the environmental setting should be provided in both documents. The
specific vegetation composition and the results of a jurisdictional wetland delineation (for
compliance with wetland ARARs) should be provided.
Additional detail on the environmental setting is important information for understanding
ecological risk, and will be provided in the Baseline Ecological Risk Assessment report for the
Landfill No. 1 area. However, revision of the Screening Ecological Risk Assessment to include
this additional information would not change the outcome of the screening assessment.
Ecological Risk Asst·ssment Study Design Addendum
G: \ wrcv L \ PJT\00-05100\ 2'>\ zooos 10025-008. DOC
5 Wn;erllaeuser Company
May 12, 2000 Attachment A
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Table A-1
Comparison of Phase 1 Surface Water and Groundwater Observations
Landfill No. 1 Area
Volatile Organics
Acetone ND 0.009
1, 1-Dichloroethane 0.001 ND
Semivolatile Organics
bis(2-Ethylhexyl)phthalate 0.004
4-Methylphenol 0.001
Phenol 0.005
2,3,7,8-TCDD TEQ 0.000000012
Aluminum 11.9
Arsenic . 0.007
Barium 0.545
Beryllium 0.002
Calcium 265
Chromium 0.036
Cobalt 0.028
Copper 0.D15
Iron 64.8
Lead 0.010
Magnesium 47.2
Manganese 3.7
Mercury ND
Nickel 0.017
Potassium 68.2
Selenium 0.00055
Sodium 212
Thallium 0.00086
Vanadium 0.049
Zinc 0.084
Ecological Risk Assessment Study Design Addendum
G: \ WPGVL \PJT\00-05 IO'J\ 25\ 2000510025-008. DOC
0.002
ND
ND
0.0000001
Inorganics
32.S
0.039
0.75
0.0013
268
0.095
0.014
0.082
115
0.062
55.8
3.73
0.00032
ND
80
0.0004
133
ND
0.38
0.34
6
Yes
No
-
-
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
-
Yes
-
Yes
No
No
-
Yes
Yes
No
No
Already a SW COPC
No
No
Already a SW COPC
Already a SW COPC
No
Already a SW COrC
Already a SW COrC
Already a SW core
Included as a SW COrC
Already a SW COrC
Already a SW core
Already a SW COPC
Already a SW COrC
No
Already a SW COPC
Already a SW COPC
No
Already a SW COPC
No
No
No
Included as a SW COPC
Already a SW COrC
Weyerhaeuser Company
May 12, 2000 Attac/Jment A
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Attachment A-1
Updated Screening Ecological Risk Calculations for the Upland Portion of
the Landfill No. 1 Area
Ecological Risk Assessment Study Design Addendum
G: \ Wl'GVL \ PJT\(J0-05100\25 \200051002.'i-OOB.DOC
Weyerhaeuser Company
May 12, 2000 Attachment A
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-TableG-1
Screening Level Hazard Quotient for the Short-tailed Shrew
bis(2-ethylhexyl)phthalate NA 0.002 1.00E+00 NA
Benzo(a)pyrene 0.14 NA 1.ooE+oo l.40E--01
Benzo(g,h,i)pcrylene 0.14 NA 1.ooE+oo 1.40E-01
2-Mcthylphcnol 0.068 NA 1.00E+00 6.S0E--02
Fluoranthenc 0.32 NA 1.00E+00 3.20E-01
Phenanthrene 0.32 NA 1.ooE+oo 3.20E-01
Phenol 0.092 NA 1.ooE+oo 9.20E--02
Pyrene 0.4 NA 1.ooE+oo 4.00E--01
Polychlorinated Biphenyls 0.25 NA 4.57E+0l
2,3,7,8-TCDD TEQ 0.0015 0.0000001 4.21E+0t 6.31E--02
Aluminum 52,700 32.5 1.ISE--01 6.22E+03
Barium 198 0.75 1.60E--01 3.17E+01
Beryllium 1.6 0.0013 1.18E+00 1.89E+00
Chromium 684 0.095 3.16E+oo 2.16E+03
Cobalt NA 0.014 2.91E-01 NA
Copper 113 0.082 1.66E+01
Cyanide 1.4 NA 1.00E+00 ' 1.40E+00
Iron 22900 115 1.41E+00
Lead 97 0.062 1.52E+00 1.48E+02
Manganese 514 3.7 1.41E+00
Mercury 2.4 0.00032 4.19E+00
Nickel 73.4 NA 4.73E+00 3.47E+02
Selenium 11.6 NA 1.00E+00 1.16E+0l
Silver 2.6 NA 1.53E+01 3.99E+01
Vanadium 312 0.376 8.S0E-02 2.75E+01
Zinc 347 0.34 2.81E+02
I The e:,.posure point concenlriltion i5 thf' maximum df'l,:.:ted conn,Tltriltion for eilCh constituent in landfill co,·rnoil and WPtland surface water.
2 lbe Iola! e,posul"t' of the short-ta.iled 5hrew is bawd on the ingestion of soil in .. ertebrates (earthwonns) and wetland surfacr Wilt~.
3 Jlaz.i.rd Quotient• ConstituentConcenlration/To:,.kitv Value.
4 Upta.ke factor.; from [kr..-/01"11e11/ and Validali011 ofBioa~nmmlntio,r MCldrl~ for [a,1/111)(11"1115, unless otherwise noted.
5 95'\ upper Prediction Limit (UPI.) Calculated Consistent with Reference noted in footnolP #4
6 Profe,;sional judgement ul«I where litrralul"I' not available. 50'\, uptake for \'OCs; 100'\. uptake for 5\'0Cs and inorganics.
7 2,3,7,8-TCDD uptake factor repn>seols ma:,.imum report uptaJ...p factor from ORNLdatil compilation.
g: \ dilla \ h\'dro \ 5100\ e .... -.,J\ l~ndfill\ Cs_risk I
4.40E--03
9.33E-02
9.33E-02
4.53E-02
2.13E--01
2.13E-01
6.13E-02
2.67E-01
2.98E+01
4.llE--02
4.96E+03
1.6SE+00
1.26E+00
1.42E+03
3.0SE-02
1.28E+0l
9.33£--01
3.67E+02
9.77E+01
1.73E+Ol
2.77E+00
2.27E+02
7.73E+00
2.60E+01
2.29E+0l
1.89E+02
-
18.3
NTX
NT)(
50
125
1.28
60
1.2
0.14
0.000001
1.93
5.10
0.66
3.28
Nn<
11.7
68.7
NTX
8
88
0-015
40
0.2
0.0014
0.21
160.0
-
0.00024
NC
NC
0.0009
0.0017
0.17
0.001
0.22
213
41083
2570
0.32
1.9
432
NC
1.09
0.014
NC
12
0.20
184
5.7
39
18564
109
1.2
-

-
<1
NC
NC
<1
<1
<1
<1
<1
>1
>1
>1
<1
>1
>1
NC
>1
<1
NC
>1
<1
>1
>1
>1
>1
>1
>1
Short-trlil Shn·w
n~/12/21100
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-- - ----- ---Table G-2
Screening Level Hazud Quotient for the Canada Goose
~ -•..:, ... ..: ' , .. · ~ ::'; ·-~~~~l,'oin:,. :'j"7 ~--~--·,. Benthic Invertebrate -~ "";...: : .. :,:-·. ;; . '.uptak Factor' " Estimate({,TisiUiConcentnition. ~~Jt::< CoS?ilituent ~ '.<l· .t.J. «Concentrahon,,.,_~;-,. .. ... ,.-' LindfiU ""' ~: i.. -~··· ' -... . -~':t~ __ :J,:·~t? ... --~. . eo-:efSoll Wetland W$ier __ '-/:r: .. ,_ .. ;~-;::•:· ' (m.;"h,,;.\,i ..
·:;_·
-·-a._, .. ,_. :,·.:,(m<>IL) · · . ;',, .,._/_,, ,(mo1j. .. ,-.--~-,. • •
bis{2-eth ylhe,yl) phthalate NA 0.002 1.00E+OO NA
Renro(•)pyrene 0.14 NA 1.00E+OO 1.40E--Ol
Benzo(g,h,i)peryleiY 0.14 NA l.OOE+OO 1.40E-01
2-M<'thylphenol 0 068 NA 1.00E+OO 6 S0E--02
Fluor•nthene 0.32 NA 1.00E•OO 3.20E--OI
Phenanthrene 0.32 NA 1.00E+OO 3.20E--01
Phenol 0.092 NA \.OOE+OO 9.20E--02
Py~= 04 NA l.OOE+OO 4.00E--01
Polychlonnated Btphenyls 025 NA 6.41E+0I 1.60E+ot
2,3,i,8-TCDDTEQ 0.0015 0.0000001 4.21E+0I 6.31£--02
Aluminum 52,700 32.5 l.OOE+OO 5.27£+04
Barium 108 0.75 1.00E+OO 1-98£+02
Beryllium 1.6 0.0013 1.00E+OO 1.60E+OO
ChromJum 684 0.095 4.68£-01 3.20£+02
CoNlt NA 0.014 \.OOE+OO NA
Copper 113 0.082 6.02E+OO
C)•anide 1.4 NA l.OOE+OO 1.40E+OO
Iron moo 115 2.87E+OO 6.57£+04
L,od ., 0.062 7.l0E-02 6.89E+OO
Manganese 514 3.7 1.00E+OO 5.14£+02
Mercury 2.4 0.00032 2.87E+OO 6.BBE+OO
Nickel 73.4 NA 2.32E+OO l.70E+02
SelPmum 11.6 NA 1.00E+OO l.16E+0l
Si]\"eT 2.6 NA 1.00E+OO 2.60£+00
Vanadium 312 0.376 1.00E+OO 3.12E+02
Zinc 347 0.34 4.20E+OO
1 n.-nr'""" r"™ c,;,.,. . ..,,,,.....,n ,.11,e mo'lmum dc-1<-,t,,.l c,,.,....,,.,~,ion f<>, , ... h roMUl...-nj ,n J.ndhll co...., ,...1 onJ ..-... L,,nd ,u,fac~ ""•WI'.
2 T!,r ""-"! ~'f'<"""'"f tt,,,C,.rw,JoC,,,,..." N,..,J on lhe mf':'"$'ton <>f planl m&h'ndl, ond l,,...,th..: onvert~ra!.-,; onJ w"'!•nd ,urlace "'ftl<'fO
2-J0E-03
6.00E-03
6.00E-03
2.65E+OO
3.70£--02
8.BOE--02
5.62F.+OO
4.20£-02
6.60£-03
5.60£-03
5.00E-03
4.77£-01
1.00E+OO
6.39£-01
246E-01
1.00E+OO
2.34£-01
2.34£-01
3.67£-01
9.70E-03 ·,
NA
6.40£-04
8.40£-04
l.94E-Ol
l.18E-02
2.82£-02
5.17£-01
1.68£--02
1.70£-03
8.40£..()6
264E+02
9.44E+0l
l.60E+OO
5.74E+02
NA
1.03E+01
1.40E+OO
5.36E+03
6.09E+OO
l.20E+02
4.59E+OO
3.60E+OO
6.24E+OO
9$4£-01
3.03E+OO
1.38E+OO
-
~ Huatd Quc,t,..... •Con!tJt...-nlCon.-/To'loly Val"" ~ U~air r .. ~.,,. from f"'J'<""'I Jl-l-.1,/•fi-" ti..-Urf•l<ofl••,,.g••n< d,,n,1<•/sfro"' .<.xi loy f'lonr, and /hot• ,<,,1,-,,1 A<r><modot..,,, f...-r,.-, Jo, /NVm,l,ro/r, R,..,,.,,,,..,J R,,:,,,.,nm,1.1,.,,,, }" d..-0111 Rulg, Rn<mot.-,no, unle-uott..-rw,.., not.,J
5 115'1. uppr, p,...t.._~_, l,m,l (UPU Cal....,IAteJ Con., .. ..,, ..,,th R--f<"tft"■.~ .,.....,,J m f<,u1""'-" H
6 Profes,~•nal 1u<lge-mrnl u...J wt,,.,-, 1,te.alu,.. nut ava,l•M~. ,._1'1. ur•ke fo, l.'OCo. mn; uru,kr fo,SVOC, an.J ,,..,,gom,·,; ,1.1)\. uptak,• for 2.3,7,~,TCDD TEQ
1 2.3.1.ll,TCDD urta,k fa,.tc,,-..,...,,...,,h ma>1mum r,-r•n uptol..,, la..t.o, fron,ORNLJ..._. «•mpol,,t.,n.
--- ---
l.06E-0-1 1.1 0.0001 <I
4.48E-0-1 NTX NC NC
4.48E-O-I NTX NC NC
6.56£-03 NTX NC NC
l.JSE-03 NTX NC NC
1.BBE-03 1.28 0.0015 <I
1.nE-02 NT)( NC NC
1.75£-03 1.2 0.0015 <I
6.0SE-03 0.18 0034 <I
2.52E-05 0.000014 1.8 >l
1.69E+02 109.7 1.5 >l
3.98E-02 20.60 0.002 <l
5.73E-02 NTX NC NC
208E+01 20.8 >I
7.43£-04 NTX NC NC
6.46E-01 33.2 0.019 <I
5.0lE-02 NTX NC NC
2.59E+02 NTX NC NC
4.64£-01 1.13 0.4 <I
5.68E+OO m 0.006 <I
1.59£-01 0.0064 24.9 >l
3.71£-01 77.4 0.005 <I
2.39£-01 0.5 05 <I
3.9JE-02 NTX NC NC
1.04E+OO 11.4 0119 <I
9.92£-01 14.5 0,07 <I
----· -

-
----

-
-Table G-3
Screening Level Hazard Quotient for the American Robin
bis(2-ethylhexyl)phthalate NA 0.002 1.00E+OO NA
Benzo(a)pyrene 0.14 NA 1.00E+OO 1.40E-Ol
Benzo(g.h,i)perylene 0.14 NA 1.00E+OO l.40E-Ol
2•Methylphenol 0.068 NA UlOE+00 6.80E-02
Fluoranthene 0.32 NA 1.00E+OO 3.20E-01
Phenanlhrene 0.32 NA 1.00E+OO 3.20E-Ol
Phenol 0.092 NA 1.00E+OO • 9.20E-02
Pyrene 0.4 NA 1.00E+00 4.00E-01
Polychlorinated Biphenyls 0.25 NA 4.57E+0l
2,3,7,8-TCDD TEQ 0.0015 0.0000001 4.21E+01 6.31E-02
Aluminum 52,700 32.5 1.18E-01 6.22E+03
Barium 198 0.75 !.60E-01 3.17E+Ol
Beryllium 1.6 0.(XJ13 1.18E+OO 1.89E+OO
Chromium 684 0.D95 3.16E+00 2.16E+03
Cobalt NA 0.014 2.91E-01 NA
Copper 113 0.082 1.66E+Ol
Cyanide 1.4 NA 1.00E+OO 1.40E+OO
Iron 22900 115 1.41E+OO
Lead' 97 0.062 1.52E+OO 1.48E+02
Manganese 514 3.7 l.41E+OO
Mercury 2.4 0.00032 4.19E+OO
Nickel 73.4 NA 4.73E+OO 3.47E+02
Selenium 116 NA 1.00E+OO 1.16E+01
Silver 2.6 NA 1.53E+0l 3.99E+01
Vanadium 312 0.376 8.S0E-02 2.75E+01
Zinc 347 0.34 2.81E+02
1 The e>.posure point concentration is the m.u.imum detected concenlution for each constituent in landfill cover soil and wetland surface water.
2 Tht> total e,posure of tht> Ameriran Robinls based on the ingestion of Earthworms and wetland surface waten.
3 lla;-__,.,d Quotient • Constituent Concentralion/T o,icity Value.
4 UpL!l-.e facton lrom Dei.,/opmrnt 11nd \'11/id11tion of Bimcnrnmlation l,.lo,.te/s for &ullm.,,ms, unl<"!.s olher,,,•ise noted.
5 95'1. upper Predidion Limit (Ul'L) Calculated Consistent with Reforence noted in footnote #4
6 Professional judgt>menl used where literature not available. 50'):. upL!ke for \'OCs; 100'):. uptal-.e for S\'OC:s and inorganirs.
7 2,3.7.B·TCDD uptal-.e factor rep~nts ma>.imun,· report uplal-.e factor from ORNI. dat.i compilation.
r,:\d.ita\hydro\5100\t>",•I\ landfill\Cs_risl-1
2.84E-04
2.13E-01
2.13E-Ol
l.04E-01
4.88E-01
4.88E-Ol
1.40E-Ol
6.IOE-01
6.SOE+Ol
8.98E-02
l.43E+ot
!.07E-Ol
2.85E+OO
3.14E+03
l.99E-03
3.52E+01
2.13E+OO
2.37E+03
2.20E+02
5.57E+0t
6.20E+OO
5.01E+02
1.77E+01
5.69E+01
7.13E+0l
4.36E+02
-----
1.1 0.00026 <1
NTX NC NC
NTX NC NC
NTX NC NC
NTX NC NC
1.28 0.38 <1
NTX NC NC
1.2 0.51 <1
0.18 361 >1
0.000014 6417 >1
109.7 130 >1
20.80 0.0051 <l
NTX NC NC
1 3144 >1
NTX NC NC
33.2 1.06 >1
NTX NC NC
NTX NC NC
1.13 195 >1
977 0.057 <l
0.0064 969 >l
77.4 6.5 >1
0.5 35 >1
NTX NC NC
11.4 6.3 >1
14.5 30 . >1
,\m,,ri,,.n ll<1hin
(IC,/ 1201100
----

-

-
-------Table G-4
Screening Level Hazard Quotient for the Red-tailed Hawk
bis(2-ethylhexyl)phthalate NA 0.002 1.00E+OO NA
Benzo(a)pyrene 0.14 NA l.OOE+OO 1.40E-01
Benzo(g,h,i)perylene 0.14 NA 1.00E+00 1.40E-01
2-Mcthylphenol 0.068 NA l.OOE+OO 6.80E-02
Fluoranthene 0.32 NA l.OOE+OO 3.20E-01
Phenanthrene 0.32 NA 1.00E+OO 3.20E-01
Phenol 0.092 NA 1.00E+OO 9.20E-02
Pyrene 0.4 NA 1.00E+OO 4.00E-01
PolychlorinateJ Biphenyls 0.25 NA 3.00E+OO 7.SOE-01
2,3,7,8-TCDD TEQ 0.0015 0.0000001 2.lOE+OO 3.14E-03
Aluminum 52,700 32.5 7.32E-02 3.86E+03
Barium 198 0.75 I.12E-01 2.22E+0l
Beryllium 1.6 0.0013 l.OOE+OO 1.60E+OO
Chromium 684 0.095 3.33E-01 2.28E+02
Cobalt NA 0.014 1.00E-01 NA
Copper 113 0.082 1.0SE+OO 1.18E+02
Cyanide 1.4 NA 1.00E+OO 1.40E+OO
Iron 22900 115 5.87E-02 1.34E+03
Lead 97 0.062 2.86E-01 2.78E+01
Manganese 514 3.7 5.87E-02 3.02E+0l
Mercury 2.4 0.00032 1.92E-01 4.61E-01
Nickel 73.4 NA 2.27E+OO
Selenium 11.6 NA 1.19E+00 1.38E+01
Silver 2.6 NA 5.0lE-01 1.30E+OO
Vanadium 312 0.376 1.79E-02 5.58E+OO
Zinc 347 0.34 1.53E+02
I The e~pc,sure paint coocenh"ation is the ma~imum d,:,t.-.::tt'd concenh"allon for each constituent in landfill co,·er soil and wetland surface water.
2 The tot.al e~rosure of the Red-t.ailed Hawk is based on the ingestion of small mammals and wetland surface waters.
3 I laz.ard Quotient '" Constituent Concenlration/To~il"it:,-Value.
4 Upt.lke factors from Dn'f'lopmrnl 11nd \111/idnlion of Biooff1mm/11fio11 Mo,le/s far 5111111/ Mammals, unless otherwi~ note<.l.
5 95'1:. upper Prediction limit (UPL) Calculated Consi~tent with Refe.-.,nce noted in footnote #4
6 Professional judgement used whert' \ihirature not availahlt'. so, uptake for \'OCs; 100'-upt.al,,e for SVOCs and inorganics.
7 2,3,7,8-TCDO uptake factor l'\'prPSents mnimum report uptake factor from ORNL data compilation.
g: \data\ hydro\ 5100\ e"el\ land fill\ Cs_ ri~k 1
1.17E-Ot
1.54E-02
1.54E-02
7.47E-03
3.52E-02
3.52E-02
1.0lE-02
4.40E-02
8.24E-02
3.45E-04
4.26E+02
4.3SE-02
1.76E-01
2.51E+0l
8.17E-04
1.30E+Ol
l.54E-01
l.48E+02
3.06E+OO
3.53E+OO
5.07E-02
2.SOE-01
l.SIE+OO
l.43E-Ol
6.14E-01
1.69E+01
--
1.1
NTX
NTX
NTX
NTX
1.28
NTX
1.2
0.18
0.00001 4
109.7
20.80
NTX
1
NTX
33.2
NTX
NTX
1.13
977
0.0064
77.4
0.5
NTX
11.4
14.5
-
0.00011
NC
NC
NC
NC
0.027
NC
0.037
0.46
25
3.9
0.0021
NC
25
NC
0.39
NC
NC
2.7
0.004
7.9
0.0032
3.03
NC
0.054
1.2
-

-
<1
NC
NC
NC
NC
<1
NC
<1
<1
>1
>1
<1
NC
>1
NC
<1
NC
NC
>l
<1
>1
<1
>1
NC
<1
>1
11,,,t.t.111 lldW"
(l'i/ 12/2()()!)
-
I
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Attachment A-2
Updated Screening Ecological Risk Calculations for the Wetland Portion of
the Landfill No. 1 Area
Ecological Risk Assessment Study Design Addendum
G: \ WPGVL \ PJT\QO--OS I 00 \25\ ZOOOS IOOZS..008. DOC
Weyerhaeuser Company
May 12, 2000 Attachment A
-------------Table H-1
Screening Level Hazard Quotient for the American Woodcock
.':'.· --0~~. -~1;-Soil/ .Terrestrial liiVCrtebrate ,,;:-;( ~~l.!"f".: -~
upta1<e Fa'ciOI"~. :, ·:-Etiinated/fisSUe Cotlce'TI1faHOri't·
. ~:2r1; ;; !?'J;~?l.;lt~;;ii1llli
Acetone
bis(2-cthylhcxyl)phthalate
2,3.7.8-TCDD TEQ
Antimony
Arsenic
Barium
Beryllium
Chromium
Copper
Iron
Manganese
Mercury
Nickel
Selenium
Vanadium
Zinc
I_· Wl?tiaii(fSoii·
,,:': ·(ri>g/kg)' "-
1.8
NA
0.000044
39.4
11.5
324
0.45
137
29
37500
6680
0.75
21
1.8
154
127
t :c::--.•,1(:·• ·.
Wetlllrid ·Water
;,;'. (fug/L) ~
NA
0.002
0 . 000000 1
NA
NA
0.75
0.0013
0.095
0.082
115
3.7
0.00032
NA
NA
0.376
0.34
5.00E--01
1.00E+00
4.21E+0l
1.00E+OO
5.23E--01
1.60E-Ol
l. lBE+OO
3.16E+OO
4.73E+00
1.00E+OO
8.80E--02
9.00E-01
NA
1.85E-03
3.94E+01
6.0IE+OO
5.18E+01
5.32E--01
4.33E+02
1.66E+01
1.41E+OO
1.41E+OO
4.19E+00
9.93E+0l
1.80E+OO
l.36E+0l
2.81E+02
I The exposure Point concentration is the maximum detected concentration for each constituent in wetland soil ,md wetland surface water.
2 The total exposure of the American \\'oodcocl<. is based on the ingestion of earthwonns and wetland surface wale~.
3 Haz..rd Quotient= Constituent Concentration/Toxicity Value.
4 Uptake factors from De1'l'lopme11t 1111d Validation of Bioommm/11/io,r Modc/5 far Ear//11n:,,.-111s, unless otherwise noted.
5 95,-upper Pn>diction Limit (UPL) Calculated Consistent with Reference not,,d in footnote #4
6 Prof('"!;sional judgement used where literature not available. 50'-uptal,.e for VOCs; 100'4 uptal,.e for SVOCs and inorganics.
7 2,3,7,8-TCDD uptal<.e factor rl'presents maximum report upl.!.ke fa(lor from ORNL data compilation .
g:\datd\ hy,lro\S 100\e\Cd\ landfill\ \\'s_risl.. 1
8.37E--01
2.00E--04
1.43E--03
3.35E+01
5.SSE+OO
6.59E+Ol
4.46E--01
3.45E+02
1.SlE+Ol
3.02E+03
5.36E+02
3.29E+OO
7.82E+0l
1.53E+OO
2.28E+Ol
2.27E+02
--
NTX
u
0.000014
NTX
5.14
20.80
NTX
1
33.2
NTX
977
0.0064
77.4
0.5
11.4
14.5
-
NC
0.00018
102
NC
1.08
3.17
NC
345
0.45
NC
0.55
513
1.01
3.06
2.0
15.6
--
NC
<1
>1
NC
>1
>1
NC
>1
<1
NC
<1
>1
>1
>1
>1
>1
,\nwric,111 \\'omkod.
05/12/2000
-
-- - ------ - -
Table H-2
Screening Level Hazard Quotient for the Barn Owl
.:Z,.L-.i :~:r~,~:-:.SmallMammal~-'.J ·:&.:·,;."~~ ·_..,;-1±,";
.UP~½~ r,c¥~-1::,~-E.stiinate<f.tisstl'eCoricetlt'Fation"'.: ~
'}~;; .2:: ~:-:~;{;'~:;ttft;;r5t;~
Acetone 1.8 NA 5.00E-01 9.00E-01
bis(2-ethylhexyl)phthalate NA 0.002 1.00E+00 NA
2,3,7,8-TCDD TEQ 0.000044 0.0000001 2.l0E+00 9.22E-05
Antimony 39.4 NA
Arsenic 11.5 NA 1.49E-02 1.71E-01
Barium 324 0.75 1.12E--01 3.63E+01
Beryllium 0.45 0.0013 1.00E+OO 4.S0E--01
Chromium 137 0.095 3.33E-01 4.57E+0l
Copper 29 0.082 1.0SE+00 3.03E+01
Iron 37500 115
Manganese 6680 3.7 5.87£-02 3.92E+02
Mercury 0.75 0.00032 1.92£--01 1.44£--01
Nickel 21 NA 2.27E+OO
Selenium 1.8 NA 1.19E+OO 2.14E+OO
Vanadium 154 0.376 1.79E-02 2.76E+OO
Zinc 127 0.34 1.53E+02
1 The exposure pomt concmlTation is the average detA:ted concentration for each constituent in landfill cover soil and wetland surf-water.
2 ll.e total expo,ure of the Barn Owl 1s h,,sed on the mgestion of small mammals and wetland_surface water.,.
3 Hazard Quotient~ Constituent Concentration/Toxic1ty Value.
4 Uptake factors from D1.1:>rfopmrnl and Valida/ion of Bioocrnmulation Modrls for Small Mammals. unless otherwi,;e noted.
S 95'\ upper Prediction Limit (UPL} Calculated Consistent with Reference noted in footnote #4
6 Profeu1onal judgement used where literature not a,·a1lable_ SO'\ uptake for VOCs; 100'\ uptake for SVOCs and inorganics.
7
Time u.e factor umt!ess Food Ingestion Rate
Seeab,we mg/kg or mg/L Soil/Sediment Ingestion Rate
See table kg/day or L/day Water lngf'S!ion Rate
Area u.e factor unitless Small Mammal Ingestion Rate
Gastrointestinal absorp110n unitless
Body\\'eight 0 442 kg
---
3.0SE-01 NTX
1.67E-04 1.1
3.13E--05 0.000014
NTX
5.82E-02 5.14
1.24E+01 20.80
1.53E-01 NTX
1.SSE+0l 1
1.03£+01 33.2
NTX
1.33E+02 977
4.89£-02 0.0064
7.70E-Ol 77.4
7.25E-01 0.5
9.3SE-Ol 11.4
5.20£+01 14.5
0.15 kg/d
kg/d
0.037 L/d
0.15 kg/d
-
NC
0.00015
2.2
0.otl
0.60
NC
15
0.31
0.14
7.6
O.Ql
1.4
0.082
3.6
--
NC
<1
>1
<1
<1
NC
>1
<1
<1
>1
<1
>1
<1
>1
H.un(lwl
0~/12/~(M}(l
-
iiii ----

-
-

-
-

-
-Table H-3
Screening Level Hazard Quotient for the Green Heron
' ._ .. J
:.,'s~;;-_,:-i.t,.-~~:,: ,.,.,. .. . t .,. ......
Acetone
bis(2-ethylhexyl)phthalate
2,3,7,B-TCDD TEQ
Antimony
Arsenic
Barium
Beryllium
Chromium
Copper
Iron
Manganese
Mercury
Nickel
Selenium
Vanadium
Zinc
1.8
NA
0.000044
39.4
11.5
324
0.45
137
29
37500
6680
0.75
21
1.8
154
127
NA 5.00E-01 9.00E-01
0.002 1.00E+OO NA
0.0000001 4.21E+01 1.85E-03
NA U)()E+OO 3.94E+Ol
NA 1.43E-01 1.64E+OO
0.75 1.00E+OO 3.24E+02
0.0013 UXlE+OO 4.SOE-01
0.095 4.68E-Ol 6.41E+0l
0.082 6.02E+OO
115 1.00E+OO 3.75E+04
3.7 1.00E+OO 6.68E+03
0.00032 2.87E+00 2.tSE+00
NA 2.32E+OO 4.87E+0l
NA 1.00E+OO 1.80E+OO
0.376 1.00E+OO • 1.54E+02
0.34 4.20E+OO
I Thee'<posure point concentution is the ma~imum delPded concentration for each constituent in wetland soil and wetland surface water.
2 The total exposure of the Gn-en lleron is based on the ingestion of euthworms and wetland surface waters.
3 llaz.ird Quotient., Constituent Concentration/To-..icit:,-Value.
4 Uptake factors from Biota Sediment Arc,mmfotion F11cl£WS far /,rpf.7"/ebr11t,s:Rt·t1iew 1111d Rero11mrl'ndations far t!U' Oak Ridge Reserooti0115, unless otherwise noted.
5 95'\ upper Prediction Limit (UPL) Calculated Consistent with Reference noted in footnotr. #4
6 Professional judgement used where literature not available. 50% uptake for VOCs; 100% uptake for SVOCs and inorganics.
7 2,3,7,8-TCDD uptake factor represents ma'<imum report uptake factor from ORNL data compilation.
g:\ data\ hydro\ S 100\ e-..cel\ land fill\\\' s _risk I
2.69E-01
2.91E-04
5.SlE-04
l.17E+0l
4.95E-01
9.67E+01
l.34E-Ol
1.91E+0l
1.82E+OO
1.12E+04
1.99E+03
6.40E-01
1.45E+Dl
5.36E-01
4.59E+Ol
1.36E+OO
--
NTX
1.1
0.000014
NTX
5.14
20.80
NTX
33.2
NTX
977
0.0064
77.4
0.5
11.4
14.5
-
NC
0.00026
39
NC
0.10
4.65
NC
19
0.05
NC
2.04
100
0.19
1.07
4.0
0.1
-

-
NC
<1
>)
NC
<l
>I
NC
>)
<I
NC
>1
>I
<)
>I
>I
<l
05 / 12 / 2/lllll
-
------

-
-

-
----Table H-4
Screening Level Hazard Quotient for the Red Fox
Acetone 1.8 NA 5.00E-01 • 9.00E-01
bis(2-ethylhexyl)phthalate NA 0.002 1.00E+OO NA
2,3,7,8-TCDD TEQ 0.()00044 0.()()()()()()1 2.lOE+OO 9.22E-05
Arsenic 11.5 NA l.49E-02 1.71E-01
Antimony 39.4 NA
Barium 324 0.75 1.12E-01 3.63E+01
Beryllium 0.45 0.0013 1.00E+OO 4.SOE-01
Chromium 137 0.095 3.33E-Ol 4.57E+01
Copper 29 0.082 1.0SE+OO 3.03E+0l
Iron 37500 115
Manganese 6680 3.7 5.87E-02 3.92E+02
Mercury 0.75 0.00032 l.92E-01 I.44E-01
Nickel 21 NA 2.27E+OO
Selenium 1.8 NA 1.I9E+OO 2.14E+OO
Vanadium 154 0.376 L79E-02 2.76E+OO
Zinc 127 0.34 1.53E+02
1 The e>.po5ure Point concentration is lhe average dete<:-ted concentration for each constituent in landfill cover soil ;md wetland sud ace water.
2 The total e>cposure of the Red Fo>. is bawd on the ingestion of small mammals and wetland surface waler.;.
3 Hazard Q.iotient., Constituent Concentration/To\icity Value.
4 Uptake factor.; from [>n,.,/ap,m-nt and Validation of Bioocni,1111/11/ion J.loot'ls for Small t,.J1111m1ab, unless otherwise noted.
S 95,. upper Prediction Limit (UPL} Calculated Consistent with Reference noted in footnote #.f
6 Professional judg<'ment used where literature not available. 50% uptake for VOC:5; 100% uptake for SVOCs and inorganics.
g:\data\ hydro\S 100\,:,>.r<'l\landfill\ \\'s_risl...J
---
l.29E-Ol 10
l.68E-04 18.3
1.27E-05 0.000001
6.70E-02 NTX
0.126
6.22E+OO 5.10
6.28E-02 0.66
6.7IE+OO 3.28
4.22E+OO 11.7
NTX
7.89E+0l 88
2.24E-02 0.015
3.88E-Ol 40
2.96E-Ol 0.2
9.60E-Ol 0.21
2.13E+0l 160.0
-
0.013
0.()()()()1
13
NC
1.22
0.10
2.0
0.36
0.90
1.49
0.010
1.5
4.6
0.13
--
<I
<1
>1
NC
>1
<l
>1
<1
<1
>1
<1
>]
>1
<1
I/Pd 1'<1'
OC,/ 12/20110
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Attachment B
Response to Comments on the Ecological
Risk Assessment Study Design
EcoloKical Risk Assessment Study Design Addendum
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Weyerhaeuser Company
· May 12, 2000 Attachment B
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Comments on the Ecological Assessment Study Design
and Sampling and Analysis Plan for the
Landfill 1 Area, Weyerhaeuser, Martin County, North Carolina
General Comments
1. The Screening Ecological Risk Assessment (ERA) identified several chemicals of potential
concern and the need to proceed with a baseline risk assessment. The exact assessment
endpoints chosen in the Screening ERA are less important than in the study design. The
sampling plan may miss critical information, such as exposures to carnivorous birds and
mammals in the wetlands due to inadequate assessment endpoints. This study design
needs to be revised to augment the assessment endpoints. The following are suggestions
for further discussion:
a. The addition of a piscivorous or frog-eating wading bird as an assessment endpoint
for the wetland is recommended. The green heron would be an appropriate
surrogate species.
b.
c.
d.
e.
The addition of a carnivorous mammal is recommended for the wetland area. Mink
have been identified as most sensitive to PCBs and dioxin.
The addition of a carnivorous bird is recommended for the wetland area. A small
species of owl is appropriate.
The addition of an insectivorous bird is recommended for the wetland area. A
Wood duck would be an appropriate surrogate species.
If the omnivorous reptile is retained as an assessment endpoint, the eastern box
turtle may not be the appropriate choice for the surrogate species for this site. No
information has been provided on the types of turtles or other reptiles present. I
suggest contacting the state non-game wildlife specialist for information on the local
turtle species and their diet. Some turtles are carnivorous when young, becoming
herbivorous as they reach maturity. The diet assumed for the turtle needs
refinement and justification
This comment was discussed and resolved as documented in our October 12, 1999
correspondence.
Ecological Risk Assessment Study Design Addendum
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1 Wet;c-rhaeuser Company
May 12, 2000 Attachment B
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2.
The assessment endpoints for the upland portion of the Landfill No. 1 area were not modified,
however, alternate carnivorous assessment endpoints were identified as replacements for the
herbivorous avian and reptilian endpoints (Canada goose and Eastern box turtle, respectively)
for the wetland areas. Two carnivorous avian species and one carnivorous mammal were
identified as replacements based on being potentially more sensitive to bioaccumulating
chemicals. Please refer to the response to General Comment #2 for additional detail.
Since the WHO TEFs are intended to be used on body burden data and are some of the best
toxicity information available, the risk assessment should use a combination of body
burden data and dietary exposure to assess exposure to wildlife. The WHO report contains
toxicity information for concentrations in bird eggs. The eggs of breeding Canada geese
could be collected to assess actual exposures for the risk assessment.
Based on discussions held to resolve components of the ecological sampling conducted in 1999,
the evaluation of potential for adverse ecological impacts was conducted using direct toxicity
testing for lower trophic levels and dietary exposure models, with measured COPC
concentrations in the dietary components, for the upper trophic level endpoints. Alternate
collection of body burden data for the upper trophic level endpoints, as suggested in the
comment, could be useful in certain sih1ations, but for this study was considered unwarranted
or impractical for a variety of reasons. For example, though Canada geese occasionally feed in
the grassed upland area of the landfill, they have not been observed nesting on the landfill or
the adjacent wetlands. The conservative dietary exposure modeling scenarios, which assume
foraging entirely within the landfill area and no migratory behavior, are likely to result in
maximum estimates of potential exposures compared with direct tissue measurement. Given
that the geese forage and nest in either areas, collection and analysis of eggs would not
represent landfill-specific exposures and could, as a result, confound remedy decision making
for the landfill area.
We concur regarding TEFs, that their designed primary and direct application is for estimating
potential toxicity of the complex mixture of dioxin-like compounds in body burden data, and
note they also are commonly used to approximately characterize the same complex mixtures in
abiotic media. Van den Berg, et al., (1997) specifically references the use of TEF methodologies
for calculation of TEQs for "various environmental samples, including animal tissues, soil,
sediment, and water." The referenced article cautions against assigning biological or
toxicological significance to TEQs calculated for abiotic media without appropriate
consideration of physiochemical processes (uptake, metabolism, bioaccumulation, etc.).
Ecological Risk Assessment Study Design Addendum
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2 Weyerharnser Company
May 12, 2000 Attachment B
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3.
4.
With respect to the WHO TEFs, Van den Berg, ct al. support the use of the TEF approach as a
risk assessment tool with recognition of its limitations. They state that the WHO TEF
methodology was not developed to reflect precise estimates of toxicity, but as a plausible
approach to approximating the toxic potency of exposures to a mixture of dioxin-like
compounds in a risk assessment framework. For example, regarding WHO avian TEFs, most
of the dioxin and furan TEFs were developed based on a biochemical response, induction of
ethoxyresorufin-O-deethylase (EROD) activity, in injected eggs, not on a direct measure of
adverse effect. On uncertainty, Van den Berg, et al. emphasize that the TEF recommendations
represent "an order of magnitude estimate" and TEF application should be tempered with
consideration of appropriate uncertainties. In this study, we are using both the USEPA 1-TEFs
and the WHO TEFs at USEPA's request with these considerations in mind.
Appendix A provides only the results of TCDD TEQ calculation and the Mercury level for
each sampling location. It is difficult to assess whether the concentration gradient for all
COPCs is appropriate based on this limited data set. A summary of the maximum detected
level for each COPC in each of the media should be presented, and additional explanation
of the sample locations which represent a concentration gradient of contaminants should be
included in the text of Section 4.1. Measurement of soil pH should be included. It affects
bioavailability of the metals contaminants.
Revised summary tables of the Task 1 data for the Landfill No. 1 area are provided in the
revised Ecological Risk Assessment Study Design for the Landfill No. 1 area.
The proposed sampling gradient for landfill soil cap material does not include the highest
concentration of mercury; the highest concentration reported (2.4 ppm) is about twice the
concentration of the highest sample location proposed for additional ecological endpoint
sampling (see pages 4-2 and appendix A of the Study Design and Sampling and Analysis
Plan for the apparent discrepancy in defining and sampling across a gradient). Location
FLCS-05 should be added as a sampling location for all assessment endpoints.
This comment was discussed and resolved as documented in our October 12, 1999
correspondence.
To address issues associated with the concentration gradient for both ·the upland and wetland
areas, modifications to the sampling locations were suggested and agreed to. For the upland
portion of the Landfill No. 1 area, the proposed sampling locations were modified. Sample
location FLCS-05 will replace proposed sample location FLCS-03. In addition to representing
the maximum observed mercury concentration in cover soils, the FLCS-05 sample provides
additional coverage of concentration ranges (gradients) for dioxin and other inorganic COPCs.
Ecological Risk Assrssment Study Drsign Addendum
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3 Weyerhaeuser Company
May 12, 2000 Attachment B
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5.
For the wetland portion of the Landfill No. 1 area, an additional sample location in the
wetlands (FLWW /WS-03) was added to provide more complete coverage of concentration
ranges (gradients) for various inorganic COPCs. This location represents the maximum values
in wetland water for aluminum, arsenic, beryllium, barium, cobalt, copper, iron, lead,
manganese, vanadium and zinc. It also represents the maximum values in wetland soil for
aluminum, beryllium, cadmium, copper, cyanide, iron, lead, and zinc.
Modified Section 4 tables, reflecting modified sample locations, were provided in the
October 12, 1999, response and are incorporated into the revised Ecological Risk Assessment
Study Design for the Landfill No. 1 area.
Chemistry data should be collected on the soils at the same time and same place as .
earthworm samples are collected. If a composite sample is used for the earthworms, a
representative composite sample is needed for the soils. The same is true of_ the other
biological data. The soil concentrations may be different upon returning to the field, even
at approximately the same spot. This will help reduce anomalous results.
Cover soil, wetland soil and wetland water samples co-located with planned biological tissue
sampling locations were collected according to the approved workplan and were not
recollected for chemical analysis. The sampling and analysis plan to assess COPC
concentrations for abiotic media and biological tissues was designed to characterize composite
exposure to either the upland or wetland portions of the landfill area. In achieving that
objective the dietary exposure modeling will use the maximum and the mean observed COPC
concentrations as inputs under the conservative scenario, and the mean and the 95 percent
upper confidence limit (95% UCL) of COPC concentrations for the alternative scenario. These
concentrations should bracket the variability expected from multiple sampling events and as
such, additional analytical information is not necessary in this assessment phase to support
remedy decision making for the landfill area.
The Study Design and Sampling and Analysis Plan should include provisions/protocols for
depuration of the earthworms prior to analyses.
This comment was discussed and resolved as documented in our October 12, 1999
correspondence.
The technical comment regarding depuration of earthworms was raised by the technical
review team based on a concern that the dietary exposure_model also contains a dietary factor
for incidental ingestion of soil. The dietary modeling which incorporates both analytical
results for earthworms (with gut contents which are predominantly soil) and an incidental soil
Ecological Risk Assessment Study Design Addendum
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6.
ingestion factor would likely result in an overestimate of exposure to endpoints feeding on
earthworms.
Depuration of earthworms was not proposed for earthworms prior to analysis and will not be
performed. The potential for overestimation of exposure to endpoints feeding on earthworms
will be addressed in the uncertainty analysis of the Baseline Ecological Risk Assessment.
In the event that earthworms are not found at the selected sample locations, landfill and
wetland soils should be collected and a laboratory earthworm toxicity/bioaccumulation
bioassay should be conducted. A split sample of the soil should be analyzed.
This comment was discussed and resolved as documented in our October 12, 1999
correspondence.
With respect to the contingency for earthworm sampling, a 28-day earthworm
bioaccurnulation assay would be used to generate tissue concentrations for COPCs in the
event that native earthworms were not available for collection in the upland and/ or wetland
portions of the Landfill No. 1 area. Table 4-3 (Terrestrial Invertebrate Tissue Sampling
Program) has been modified to reflect that contingency.
Small mammals collected at the site will have integrated their exposure over an area equal
to their approximate home range. However, we have only one data point within that area to
represent the concentration term. I recommend step out samples of soil chemistry in the
vicinity of the traps to better characterize exposure in these areas. I think this will make the
data easier to interpret, allowing it to support a better decision in the risk assessment.
As specified in the Study Design and as discussed on our conference call of October 6, 1999,
small mammal tissues were collected to represent exposure of the broad area of the landfill
and to support dietary exposure modeling of the opportunistic feeding patterns of the
carnivorous endpoints.
The Study Design and Sampling and Analysis Plan should specify the species of small
mammal that will be targeted in the sampling effort.
In lieu of a field reconnaissance prior to tissue collection, it was agreed that small mammal
collection would take place for a minimum of three nights. At the completion of the collection
effort, an inventory of the actual species collected and proposed sample composites for
analysis would be provided to USEPA for review and approval prior to submittal to the
Ecological Risk Assessment Study Design Addendum
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May 12, 2000 Attachment B
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9.
laboratory. The proposed small mammal sample composites were approved for analysis on
November 9, 1999.
7. The Study Design and Sampling and Analysis Plan should employ a 28-day Hyalella
bioassay rather than a 10-day assessment. The sediments used in this assessment should be
analyzed for the CO PCs.
This comment was discussed and resolved as doc11me11ted in 011r October 12, 1999
correspondence.
The test durations proposed in the current Study Design/Sampling and Analysis Plan of
10 days for Hyalella growth and survival will be retained based on the following rationale:
■ To maintain consistency with current and previously approved protocols and procedures
■ To maintain consistency with toxicity testing performed at the Welch Creek area both
during the RI/FS activities and during the 1995 studies.
8. For toxicity tests, regardless of the specifications in the protocol, the number of test
replicates should be selected based on statistical power to detect a toxicological response.
Four replicates is too few. At least eight should be planned.
This comme11t was discussed and resolved as doc11111e11ted in our October 12, 1999
correspondence.
In response to an additional technical comment on the biotoxicity testing, a minimum of eight
replicates is planned for Hyale/la testing. The summary of the testing included in
Subsection 4.3 mistakenly identified the performance of four replicates. The details of the
protocol provided in Appendix C, previously submitted, appropriately reference the
performance of eight replicates per test.
The Canada goose might feed opportunistically on other than vegetation. The dietary
fraction of non-plant food sources to geese and other waterfowl should be researched.
Geese are a surrogate species to represent an entire class of waterfowl, some of whom may
eat a good portion of aquatic and terrestrial insects. The 1 percent terrestrial insects
assumed for ingestion in Table 6-3 is too little to make a difference in the calculation or to
represent opportunistic feeding.
Ecological Risk Assessment Study Design Addendum
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6 Weyerhaeuser Company
May 12, 2000 Attac/rment B
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10.
11.
In the wetland portion of the Landfill No. 1 area, the Canada goose, representing the
herbivorous avian endpoint, was replaced as an endpoint by alternate carnivorous avian
assessment endpoints. The Canada goose remains as a receptor in the upland portion of the
Landfill No. 1 area.
In the conservative analysis, the Canada goose is to be 100 percent herbivorous. In the
alternative analysis, the goose is assumed to ingest plant and insects. The dietary information
for the Canada goose was obtained from the wildlife Exposure Factors Handbook (USEP A,
1993).
There should be a battery of small mammal traps versus one per each location to get the
tissue mass needed for the analyses. A field reconnaissance is warranted (Step 5) to see
what types and amounts of organisms can be collected.
Multiple snap traps will be placed in the vicinity of each designated upland and wetland
sample location.
In lieu of a field reconnaissance prior to tissue collection, it was agreed that small mammal
collection would take place for a minimum of three nights. At the completion of the collection
effort, an inventory of the actual species collected and proposed sample composites for
analysis would be provided to USEPA for review and approval prior to submittal to the
laboratory. The proposed small mammal sample composites were approved for analysis on
November 9, 1999.
Given the fact that there are less than 10 data points to characterize the media, the baseline
risk assessment should be performed on the maximum detected concentrations and not the
95 percent upper confidence limits on the mean concentration. The uncertainty in the mean
concentration is too great.
The conservative scenario will use the maximum and the mean observed COPC
concentrations for environmental media and forage tissues. For the alternative scenario,
exposure modeling employing the mean and the 95% UCL of COPC concentrations in tissues
will be performed. Region.IV Supplemental Guidance (USEPA, 1996) addresses the
uncertainty of 95% UCL for small data sets. Specifically the guidance recommends use of the
lesser of the maximum detected concentration for each COPC or the 95% UCL of the mean
concentration (calculated assuming a log-normal distribution of the data set).
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12. The toxicity profiles should present more studies and should provide justification for the
toxicity reference values used in the risk assessment. The values used for the LOAEL and
NOA EL in the risk assessment should be identified. The toxicity values should be
conservative. Toxicity profiles should contain the most conservative studies. They should
place less emphasis on mortality endpoints.
Toxicity profiles for the Landfill No. 1 area COPCs are provided in the revised Ecological Risk
Assessment Study Design for the Landfill No. 1 area submitted concurrent with this response.
Ecological Risk Assessment Study Design Addendum
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May 12, 2000 Attac/1me11t B