RISK ASSESSMENT FOR THE SHEBOYGAN RIVER, SHEBOYGAN COUNTY,

EPA Region 6 Records Ctr.

224694 RISK ASSESSMENT FOR THE SHEBOYGAN RIVER, SHEBOYGAN COUNTY, WISCONSIN •i J

-j "1 Prepared for

^ Teciunseh Products Company I Sheboygan Falls, Wisconsin

.^ Prepared by i ENVIRON Corporation *: Princeton, New Jersey ~.J

August 1995 CONTENTS

Page

I. EXECUTIVE SUMMARY 1

II. INTRODUCTION 9 A. Objective 9 B. Background 9 C. Monte Carlo Simulation 12

HI. HAZARD IDENTTFICATION 13 A. Analytical Information Regarding the Sheboygan River Site 13 n 1. Fish 13 2. Floodplain Soil 15 B. Characteristics of PCBs 15

_^ IV. TOXICITY ASSESSMENT 21 A. General Considerations 21 "1 B. Carcinogenic (Non-threshold Toricity) 23 - i 1. Differential Carcinogenic Potency Estimates Based on Chase et al. (1989) 25 ~1 2. Revisions to the Chase et al. Approach Based on Recently i Proposed Scaling Factor 28 ~~ 3. Revisions to the Chase et al. Approach Based on Reevaluation "" I of the Liver Histopathology 29 - i 4. Revision to the Chase et al. Approach Based on Consideration of Data from All Appropriate Bioassays 30

V. ESTIMATE OF HUMAN EXPOSURE 32 A. Receptors and Exposure Routes 32 ^_ 1. Recreational Fishing 32 J 2. Floodplain Soils 36 B. Intake Calculations 36 C. Exposure Assumptions 43 "^ \. Generic Assumptions 43 2. Recreational Fishing 46 3. Flood Plain Soil 51

VI. RISK CHARACTERIZATION 56 A. Risk Calculations 56 B. Potential Cancer Risks 56

ENVIRON CONTENTS (continued)

Page

VII. UNCERTAINTY 60 A. Estimation of Human Exposure 60 1. Ingestion of Fish 60 2. Exposure to Floodplain Soil 61 B. Monte Carlo Analysis 62 C. Fish Sample Preparation 62 D. Evidence of Human Toxicity from PCB Exposure 63

Vffl. CONCLUSIONS 65

IX. REFERENCES 66

APPENDICES -n Appendix A: Hmong Survey Appendix B: Fall Creel Survey Appendix C: Spring Creel Survey Appendix D: Monte Carlo Simulation Appendix E: Sheboygan River Smallmouth Bass Population Estimates

TABLES

Table 1-1: Lifetime Tumorigenic Risks for Hypothetical Receptors from Ingestion of Fish from the Sheboygan River (50th and 90th Percentile) 6 Table 1-2: Lifetime Tumorigenic Risks for Hypothetical Adult and Child Receptors Exposed to Floodplain Soils (50th and 90th Percentile) 7 Table n-1: Comparison of Nomenclature Used to Describe Locations Along the Sheboygan River 11 Table ffl-1: Summary of PCB Concentrations Detected in Fish from the Sheboygan River 16 Table ffl-2: Summary of PCB Concentrations Detected in Floodplain Soils 18 Table IV-1: Relative Cancer Slope Factors (CSFs) for PCBs Based on Chase et al. (1989 and Updates of Chase et al.) 27 Table V-l: Cumulative Distributions of LADDs Due to Exposure to Soils for Hypothetical Child Receptors (mg/kg-day) 38

ENVIRON CONTENTS (continued)

Page

TABLES (Cont'd)

Table V-2: Cumulative Distributions of LADDs Due to Exposure to Soils for Hypothetical Child Receptors (mg/kg-day) 39 Table V-3: Cumulative Distributions of LADDs Due to Ingestion of Fish from Area 3 (mg/kg-day) 40 Table V-4: Cumulative Distributions of LADDs Due to Ingestion of Fish from Area 3 (mg/kg-day) 41 Table V-5: Intake Assumptions for Fish Consumption 42 Table V-6: Intake Assumptions for Incidental Soil Ingestion 44 Table V-7: Intake Assumptions for Dermal Contact with Soil 45 Table V-8: Cumulative Distributions of PCB Concentrations in Fish (mg/kg) 47 Table V-9: Cumulative Distributions of Exposure Parameters for Fish Ingestion 50 Table V-10: Cumulative Distributions of PCB Concentrations in Soil (mg/kg) 52 Table V-ll: Cumulative Distributions of Exposure Parameters for Soil Ingestion and Dermal Contact for Hypothetical Adult Receptors 53 Table V-12: Cumulative Distributions of Exposure Parameters for Soil i Ingestion and Dermal Contact for Hypothetical Child Receptors 54 Table VI-1: Cumulative Distributions of Total Cancer Risk Ingestion of Fish from the Sheboygan River 57 Table VI-2: Cumulative Distributions of Total Cancer Risk Soil Ingestion and Dermal Contact 59

FIGURES

Figure ffl-l: Sheboygan River Fish Consumption Study Survey Sites 14 Figure III-2: Sheboygan River Floodplain Soil Sampling Sites 17

ENVIRON I. EXECUTIVE SUMMARY

This risk assessment, prepared on behalf of Tecumseh Products Company (Tecumseh), evaluates the potential human health risks associated with exposure to polychlorinated biphenyls (PCBs) at current conditions in the Sheboygan River and the floodplain soils adjacent to the Sheboygan River. This report evaluates the potential for long-term health-related effects, specifically the carcinogenic risk, posed to hypothetical receptors exposed to PCBs through ingestion of fish caught in the Sheboygan River as n well as through incidental ingestion of, and dermal contact with, floodplain soils. The — ' results presented in this report indicate that, based on site-specific information for fish ™n consumption and on current PCB levels in fish, that the risks associated with either fish _ consumption or direct contact with flood plain soils are acceptable according to USEPA guidelines. The U.S. Food and Drug Administration has established a tolerance level of 2.0 \J mg/kg (2.0 ppm) total PCBs hi fish fillets for interstate commerce (USFDA 1988). According to the Agency for Toxic Substances and Disease Registry's Toxicological Profile ' for Selected PCBs (199 la), the mean concentration of PCBs in whole freshwater fish throughout the United States is 0.5 mg/kg (0.5 ppm). A study published by Humphrey (1988) reported that the median (50th percentile) concentrations of PCBs in cooked Lake Michigan fish (trout, salmon, pike, perch, walleye and whitefish) ranged from 0.17 ppm (pike, perch, walleye and whitefish) to 3.0 ppm (lake trout). The 50th percentile values used to evaluate potential risk associated with ingestion of fish (i.e., uncooked fillets from the Sheboygan River) were generally below 3.0 ppm, indicating in a qualitative sense that fish in the Sheboygan River have not bioaccumulated PCBs to any greater extent than fish in other parts of the United States. The levels of PCB in fish that are consumed are reduced by customary removal of _ fat and dark tissue and by cooking. The recently-released Health Guide for People Who

-I- ENVIRON Eat Sport Caught Fish from Wisconsin Waters (WDOH 1993) emphasizes the point that "PCBs and many pesticides usually build up in a fish's fat deposits and just beneath the skin rather than in muscle tissue. By removing the fat before you cook and eat these fish..., you can reduce PCB and pesticide levels..." The guide further advises removal of all skin, the dark flesh on the top of the fish along the backbone, the fat belly meat along the bottom of the fish and the V-shaped wedge of fat along the lateral line of the fish. Cooking preparation, especially baking or broiling trimmed fish on a rack or grill further decreases the concentration of PCBs in the fish (WDOH 1993). These recommendations are further supported by the Great Lakes Sport Fish Advisory Task Force's (GLSFATF) Protocol for a Uniform Great Lakes Sport Fish Consumption Advisory (GLSFATF 1993). The PCB concentrations for Sheboygan River fish presented in this report were obtained from the analysis of uncooked fillets from which the dark flesh had not been removed. Had the fillets been trimmed as recommended by the Wisconsin I Health Guide and cooked, the analytical data would have yielded substantially lower PCB levels in the fish species, and, as a result, the potential risk associated with ingestion of the fish would be lower than calculated. This analysis considers the most recent sampling data available for each species of fish. Data from 1992 were used for salmon and steelhead trout, while 1993 data were w I used for bass and carp. These analytical data best represent current exposure concentrations for fish ingestion, without taking into account reductions associated with preparation. Although PCB concentrations in fish decreased markedly following land- >- based removal activities in 1979, they increased somewhat following dredging in 1989 and 1990. Since that time, the PCB concentrations have tended to decrease and, absent intervening activities, are likely to continue to decrease, although existing fish may live for some time and contain PCB concentrations near current levels. The current exposure concentrations in fish were used to estimate future concentrations for this risk assessment. This assumption will also overestimate the carcinogenic risk posed to hypothetical receptors in the fish ingestion scenario, as PCB levels in the Sheboygan River are expected to decrease, not remain constant, in the future. The organization of this report is based on the individual steps of the risk assessment process as described by the National Research Council of the National Academy of

-2- ENVIRON Sciences in a report by its Committee on the Institutional Means for Assessment of Risk in Public Health (NRC 1983). The chemicals detected in environmental media are identified and the analytical data are summarized in the Hazard Identification section (Section III). The lexicological properties of the detected chemicals are discussed and health-effects criteria used in the quantitative risk assessment are summarized in the Toxicity Assessment section (Section IV). The Exposure Assessment section identifies populations that may be exposed to the chemicals, and exposure pathways are selected for further evaluation (Section V). The magnitude, frequency and duration of exposure are estimated and the potential chemical intakes are quantified in Section V as well. The Risk Characterization section integrates human exposure information and toxicity criteria to develop estimates regarding the nature and magnitude of potential risk to human health (Section VI). This risk assessment was conducted using Monte Carlo simulation techniques to quantify risks and provide an analysis of uncertainty in exposure assumptions (USEPA 1992a). Monte Carlo analysis uses probability density functions or cumulative frequency distributions instead of single point estimates as input variables for the risk calculations. In this analysis, single values from within these distributions are selected at random based on their probability (frequency of occurrence) and are used to calculate risk. After these calculations are repeated several thousand times, the results can be presented as distributions of risk that reflect the overall uncertainty in the input values. This approach estimates the ranges of risks for the potentially exposed population, and permits easy identification of risk values that correspond to reasonable worst-case estimates. The USEPA (1992a) has defined the reasonable worst-case scenario as the lower portion of the high end of the risk distribution, or the range above the 90th percentile, but below the 98th percentile. The results presented in this report represent the 90th percentile, selected to reflect worst-case estimates. For this analysis the Sheboygan River was divided into three sections: Area 1, Sheboygan Falls to the River Bend Dam; Area 2, River Bend Dam to the Waelderhaus Dam; and Area 3, Waelderhaus Dam to Sheboygan Harbor. The dams limit the access of migratory fish species, salmon and steelhead, to the upper stretches of the river system. Tecumseh commissioned a survey of the Sheboygan Hmong population

-3- ENVIRON (presented in Appendix A) and two creel surveys (presented as Appendices B and C) to investigate the fishing patterns and fish-ingestion habits of anglers along the Sheboygan River. Since there was no documented fish consumption from Area 2, this section of the river was not included in the fish ingestion exposure scenario for this risk assessment. Potential carcinogenic risks associated with ingestion of bass and carp in Area 1 and salmon, steelhead, bass and carp in Area 3 were evaluated. The Hmong survey (Hutchinson 1994) and the creel surveys (Mead and Hunt 1994a,b) emphasized several issues. Fishing is seasonal, with the majority of the fishing in the Sheboygan River occurring during the spring and fall runs of salmon and trout migration. The Hmong survey indicated that, in general, the Hmong population does not fish to any great extent in the Sheboygan River; in fact, the preferred fishing location for these peoples is Lake Winnebago (Hutchinson 1994). In fact, the vast majority of , _ >—- anglers fish in Area 3 for the migratory species (salmon and steelhead), which live most ~j of their lives in Lake Michigan (Mead and Hunt 1994a,b). The resident species (bass and carp) were found to be represented in only a small proportion of the creels of the | anglers in Area 3, while in Area 1 bass are reportedly eaten very much more frequently ~" than are carp. i { Floodplain soil samples were collected by Blasland, Bouck & Lee, Inc. These samples, too, were divided into Areas 1, 2 and 3 (as defined for the surveys, above). Potential adult and child receptors were assumed to contact floodplain soils while participating in recreational activities near the river where the soil is not covered with - vegetation. Since most of the areas along the floodplain are actually well vegetated, using this assumption in the evaluation of the soil exposure pathways is very conservative. Exposure to PCBs in the soils was evaluated using the incidental ingestion and dermal contact pathways. The PCBs that have been identified in floodplain soils and fish include Aroclor 1242, 1248 and 1254. Aroclor 1260 was identified in one carp sample and in samples taken from the migrating species (salmon and steelhead). A cancer slope factor (CSF) of 7.7 (mg/kg-day)'1 has been derived by the USEPA only for Aroclor 1260 (Norback and Weltman 1985, USEPA 1994a). Because there is no information regarding which constituents in the PCB mixture might be carcinogenic, in the past it was simply assumed

-4- ENVIRON that Aroclor 1260 is representative of other PCB mixtures (USEPA 1988). In light of the questionable scientific validity of applying the CSF derived for Aroclor 1260 to all PCB mixtures, an independent review has been conducted to evaluate the available data on the carcinogenic potential of PCB mixtures (Chase et al. 1989). In addition, the Institute for Evaluating Health Risk (IEHR 1991) has more recently reevaluated the studies which had previously been used for PCB carcinogenic risk assessment. The IEHR report concluded that Aroclors with less than 60% chlorine should not be evaluated as carcinogens and, further, would support that if these lower chlorinated Aroclors are evaluated as carcinogens, that a significantly lower CSF should be applied. Based on the recommendations of the IEHR report and the Chase report, relative carcinogenic potencies for Aroclor 1254, 1248 and 1242 were used to estimate the potential carcinogenic risk in this report. As shown in Table 1-1, the total excess lifetime cancer risk estimates for exposure to * ~1 PCBs in fish caught in the Sheboygan River were within the less than 1 x 10"* to 1 x 10"* benchmark range deemed acceptable in the National Contingency Plan.1 The 90th j percentile total cancer risks to individuals eating fish caught in the Sheboygan River ~ were 4 x 10"5 for migratory species from Area 3 and 5 x 10"* and 4 x 10"5 for the resident -» species from Areas 3 and 1, respectively. The estimated 50th percentile excess lifetime 4 cancer risks in both Areas 3 and 1 were also within the USEPA's acceptable range of •^ •) 10"6 and 10^ (USEPA 1990). The 50th percentile total cancer risks to individuals eating fish caught in the Sheboygan River were 4 x 10"* for migratory species from Area 3 and 5 x 10"7 and 8 x 10"* for the resident species from Areas 3 and 1, respectively. A fish census performed recently by Blasland, Bouck & Lee, Inc., demonstrated that only an estimated 21 legal-size bass are in Area 1 (see Appendix E). Therefore, there is an insufficient supply of bass in Area 1 to match the conservative exposure assumptions used to evaluate fish ingestion in Area 1. The 90th percentile total cancer risks associated with incidental ingestion of and dermal contact with floodplain soils, shown in Table 1-2, were 9 x 10"*, 9 x 10"8 and

Scientific notation presented as 1x10"* or lc-06, for example, is equal to 0.000001 or one in one million.

-5- ENVIRON TABLE 1-1 Lifetime Tumorigenic Risks for Hypothetical Receptors from Ingestion of Fish from the Sheboygan River (50th and 90th Percentile) Fish Species Area 3 Area 1 Migratory 50th percentile 4e-06* NA 90th percentile 4e-05 NA Resident 50th percentile 5e-07 8e-06 90th percentile 5e-06 4e-05 Notes:

* Scientific notation presented as 4e-06, for example, is equal to 0.000004 or 4 in one million. NA: Not Applicable. Salmon and steelhead trout are not found in Area 1.

-6- ENVI RON TABLE 1-2 Lifetime Tumorigenic Risks for Hypothetical Adult and Child Receptors Exposed to Floodplain Soils (50th and 90th Percentile) Hypothetical Receptor Area 3 Area 2 Area 1 Adult 50th percentile 5e-09* 8e-09 le-08 90th percentile 9e-08 9e-08 2e-07 Child 50th percentile 2e-08 3e-08 4e-08 90th percentile 2e-07 2e-07 4e-07 Note:

* Scientific notation presented as 5e-09, for example, is equal to 0.000000005 or 5 in one billion.

-7- EN VI RON 2 x 107 for adult receptors in Areas 3, 2 and 1, respectively. The 90th percentiL total cancer risks associated with incidental ingestion of and dermal contact with floodplain soils were 2 x 107, 2 x 107 and 4 x 10"7 for child receptors in Areas 3, 2 and 1, respectively. These risk levels for exposure to floodplain soils were below the benchmark range deemed acceptable. Each of the estimated 50th percentile excess lifetime cancer risks were below the USEPA's acceptable benchmark range. The 50th percentile total cancer risks associated with incidental ingestion of and dermal contact with floodplain soils were 5 x 10"', 8 x 10"' and 1 x 10s for adult receptors in Areas 3, 2 and 1, respectively. The 50th percentile total cancer risks associated with incidental ingestion of and dermal contact with floodplain soils were 2 x 10"*, 3 x 10"* and 4 x 10"* for child receptors in Areas 3, 2 and 1, respectively. Therefore, no unacceptable cancer risk is expected to occur from exposure to PCBs in fish caught in the Sheboygan River or from exposure to floodplain soils near the Sheboygan River. In addition, the GLSFATF (1993) protocol summarizes that "your risk of cancer from eating contaminated fish cannot be predicted with certainty... Exposure [to] contaminants in the fish you eat may not increase your cancer risk at all."

•M«

'I

-8- ENVIRON II. INTRODUCTION

_ A. Objective The objective of this report, prepared on behalf of Tecumseh Products Company i (Tecumseh), was to evaluate the potential human health risks posed by exposure to polychlorinated biphenyls (PCBs) found in the Sheboygan River and the floodplain soils adjacent to the Sheboygan River. This risk assessment uses current scientific principles, risk assessment guidance and analytical results of sampling performed by Blasland, n Bouck & Lee, Inc. (BBL) and Mead and Hunt, Inc. This report evaluates the potential long-term health risks to hypothetical receptors possibly exposed to PCBs through ~] ingestion of fish caught in the Sheboygan River or through incidental ingestion of or _ dermal contact with PCBs in floodplain soils. -1 *".. B. Background '".' The Sheboygan River and Harbor site includes the Sheboygan River extending from """.. Sheboygan Falls down river 22 kilometers (14 miles) to Lake Michigan. This Superfund site also includes the 38-hectare (96 acre) Sheboygan Harbor at the mouth of the river. The Sheboygan River averages approximately 37 meters in width and ranges from 30 to 120 centimeters deep. In its course from Sheboygan Falls to Lake Michigan, the river ""'- flows past a diverse array of shore features. Rochester Park in Sheboygan Falls is directly downstream of the Tecumseh plant In the Village of Kohler the river flows past the Kohler Company Landfill Superfund site. The river flows past several parks, residences, and commercial and industrial areas in the City of Sheboygan. ~~ In 1977, as part of its statewide program for monitoring contaminants in sport-caught fish, the Wisconsin Department of Natural Resources (DNR) analyzed fish from the Sheboygan River. The results of these analyses showed that fish 5 kilometers upstream of the harbor contained PCBs at levels which exceeded the U.S. Food and Drug

-9- ENVIRON Administration's tolerance level. The DNR and the Wisconsin Department of Health -._ issued a fish consumption advisory at that time. This advisory was still in effect as of October 1994. Upon further sampling of the river sediments and effluents from area industries and sewage treatment plants, relatively high levels of contamination were found in river -._ sediments near the Tecumseh facility. Between about 1966 and about 1971, Tecumseh used hydraulic fluids containing PCBs. Materials containing PCBs were inadvertently released into soils near the facility. These materials contained Aroclor 1248 and Aroclor 1254. In September 1979, Tecumseh excavated and replaced 2,050 cubic meters of PCB- J containing soils. The Sheboygan River and Harbor site was placed on the U.S. Environmental Protection Agency's National Priority List in 1986. As part of the Superfund effort, Tecumseh signed a consent order in 1986 to conduct a remedial investigation and feasibility study of ways to clean up the site. The final report of remedial investigation studies was published in 1990. In keeping with an "alternative specific remedial investigation" (ASRI) begun in 1989, pilot studies of removing and armoring river ** sediments were conducted by BBL on behalf of Tecumseh. As part of this project, Tecumseh removed a total of 2,500 cubic meters of sediment containing the highest PCB concentrations and placed it in the confined treatment facility in 1989 and 1990. Also in 1990, Tecumseh armored approximately 1,200 square meters of sediments containing PCBs which remained in the river. In 1991, Tecumseh removed another 2,000 cubic - i •x_ meters of sediments from the river and placed these sediments in the sediment management facility. These rounds of sediment removal and armoring were done in the section of the river extending from the Tecumseh property to an area downstream of the River Bend Dam. For the purposes of this risk assessment, the Sheboygan River was divided into different "Areas" based on various landmarks present on the River. As shown in Table EM, Area 1 extends from Sheboygan Falls Dam downstream to River Bend Dam, Area 2 extends from River Bend Dam to Waelderhaus Dam, Area 3 extends from - Waelderhaus Dam downstream to the mouth of the Sheboygan River, and Area 4 is Sheboygan Harbor. Also listed in Table II-1 are terminologies used by Blasland, Bouck

-10- ENVIRON & Lee (BBL 1992) in the Alternative Specific Remedial Investigation Report: Sheboygan River and Harbor and by the Wisconsin Department of Health (WDOH 1994) in the Public Health Assessment: Sheboygan River and Harbor, Sheboygan County, Wisconsin. The BBL and WDOH nomenclatures are included for comparison purposes when referring to either of these documents.

TABLE II-l Comparison of Nomenclature Used to Describe Locations Along the Sheboygan River

Location Along ENVIRON BBL WDOH Sheboygan River Risk Assessment ASRI Public Health Assessment

Sheboygan Falls Dam Included Included to "Area 1" in in River Bend Dam "Upper River" "Section A" River Bend Dam Included Included to "Area 2" in b Waelderhaus Dam "Upper River" "Section A" Waelderhaus Dam Included to in "Middle River" "Section B" C&NW Railroad Bridge "Area3' 'i C&NW Railroad Bridge Included Included to in "Lower River" in Pennsylvania Avenue Bridge "Area 3" "Section C" Pennsylvania Avenue Bridge Included Included to in "Inner Harbor" in Mouth of Sheboygan River "Area3' "Section C" Mouth of Sheboygan River to "Area 4" "Outer Harbor" "Harbor Mouth" Outer Breakwaters in Sheboygan Harbor

The risk assessment is organized as follows:

• Hazard Identification: The chemicals detected in environmental media sampled by BBL are identified, and the analytical data is summarized. • Toxicity Assessment: The lexicological properties of the detected chemicals are discussed, and health-effects criteria used in the quantitative risk assessment are summarized. • Exposure Assessment: Populations that may be exposed to the substances are identified, and exposure pathways to these receptors are selected for further

-11- ENVIRON evaluation. The magnitude, frequency and duration of exposure are estimated, and the potential chemical intakes are quantified. • Risk Characterization: Human exposure information and toxicity criteria are integrated to develop estimates regarding the nature and magnitude of the risk to human health. • Uncertainty: Sources of uncertainty in the risk calculations which may lead to overestimation or underestimation of risks are discussed.

C. Monte Carlo Simulation Risk assessments are based, in part, upon hypothetical exposure scenarios. In developing these scenarios, it is important to employ exposure assumptions that singly and collectively, are realistic. This risk assessment employs Monte Carlo simulation techniques to quantify risks in a realistic manner. This approach is justified scientifically and is within the parameters of the applicable federal regulation, the National Contingency Plan, 40 C.F.R. 300. Moreover, recent USEPA guidance has emphasized the need for uncertainty analysis in risk assessment, and recommends the Monte Carlo technique as one possible approach to reduce uncertainty (USEPA 1992a). A more detailed discussion of the Monte Carlo technique is presented in Appendix D. The @RISK program Version 1.55 was used for the Monte Carlo analysis. Five thousand iterations were sufficient to achieve stable results. Input variable distributions for media concentrations and exposure parameters were developed based on site-specific information where data were available and USEPA-recommended values. Otherwise, point estimates or professional judgment was used. USEPA (1992a) has defined the reasonable worst-case scenario as the lower portion of the high end of risk distribution, or the range between the 90th percentile and the 98th percentile. The results presented in this report represent the 90th percentile, selected to reflect reasonable worst-case estimates of risk consistent with the National Contingency Plan.

-12- ENVIRON . HAZARD IDENTIFICATION

A. Analytic Information Regarding the Sheboygan River and Harbor Site

1. Fish At the request of regulatory agencies and as part of the ASRI, since 1989 BBL has conducted a fish monitoring program. This program involved the collection of four species of fish from the Sheboygan River for subsequent PCB and lipid content analysis (BBL 1992). As discussed in the ASRI, the fish species included two migratory sport fish (chinook salmon and steelhead trout), a resident sport fish (smallmouth bass) and a resident bottom-feeding species (carp). Chinook salmon and steelhead trout were selected because they are migratory salmonids which are targeted by anglers. Smallmouth bass were selected because they are a sport species, but also because they reside in the River on a year-round basis. Finally, a sucker species was chosen for its bottom-feeding habits, which would suggest that these fish are likely to be maximally exposed to PCBs in sediment (BBL 1992). This analysis considers the most recent sampling data available for each species of fish: 1992 data for salmon and steelhead and 1993 data for bass and carp. Based on locations of these species in the river, and on fishing patterns of anglers in the Sheboygan River (discussed in Section V), the fish sampling data was separated into three distinct groups: Area 1, Sheboygan Falls to River Bend Dam; Area 2, River Bend Dam to Waelderhaus Dam; and Area 3, Waelderhaus Dam to Sheboygan Harbor (Figure ffl-l). The dams in the Sheboygan River limit the access of the migratory species, salmon and steelhead, to the upper stretches of the river; therefore, in Area 1 only bass and carp are represented in samples. Due to

-13- ENVIRON ARE* 1 10 - JAYCEE RIVER WALKWAY 2o - ROCHESTER PARK AREA 2 Jo - RIVER BEND DAU - WAELDERHAUS DAW AREA 3 4o - WAELDERHAUS DAM - GOLF CART BRIDGE - WAYSIDE - CTH TA 60 - KIWANIS PARK AREA « 7o - SOUTH BREAKWATER H^nft SITES AREA 1 It - ACROSS FROM UTILITY BUILDING AREA } 2b - GOLf CART BRIDGE - WEEDENS CREEK Jg - 1-43 - CTH PR INTERSECTION 4b - NEW JERSEY AVENUE BRIDGE 56 - 8lh STREET BRIDGE et> - PARK AREA 4 7U - NORTH BREAKWATER

Figure DIVTD Akin Cl ID\/rv CITt-r- I in i extremely limited fishing in the section of the river between the two dams (Mead and Hunt 1994), Area 2 was not included in the fish ingestion exposure scenario for this risk assessment. Sampling data from Area 3 included data for salmon, steelhead, bass and carp. Summary statistics for the fish data used in this risk assessment are presented in Table ffl-1. Bass were found to contain Aroclor 1248 (0.4-3.8 mg/kg) and Aroclor 1254 (0.4-6.5 mg/kg). Carp contained Aroclor 1242 (0.2-19.0 mg/kg) and Aroclor 1254 (03-29.0 mg/kg). Aroclor 1260 was detected in only one of 50 carp samples (1.5 mg/kg); otherwise Aroclor 1260 was detected only in the migratory species. Salmon were found to contain Aroclor 1242 (0.3-0.7 - mg/kg), Aroclor 1254 (0.7-2.6 mg/kg) and Aroclor 1260 (0.4-1.3 mg/kg). Steelhead trout contained Aroclor 1242 (0.2-1.9 mg/kg), Aroclor 1254 (0.2-1.3 mg/kg) and -^ Aroclor 1260 (0.1-0.4 mg/kg).

••"* 2. Floodplain Soil ~ BBL collected samples of soil from the Sheboygan River's floodplain in 1990, 1991 and 1992, as part of the ASRI. As with the fish data, soil samples were divided ^ into three groups based on location (Figure ni-2). Area 1 includes samples from FPH through FPI^7 and FPR-1 through FPR-6. Data from sampling locations ~ FPR-7 and FPR-8 are used for Area 2. Area 3 is comprised of samples from FPLr 10 through FPL-21 and FPR-10 through FPR-21. """ Concentrations of Aroclors in floodplain soil samples are summarized in Table in-2. The only Aroclors detected in soil samples were Aroclor 1248 and ~~ Aroclor 1254. Detected concentrations of Aroclor 1248 ranged from 0.08-120 mg/kg. Aroclor 1254 ranged from 0.06-130 mg/kg. _>

B. Characteristics of PCBs Polychlorinated biphenyls (PCBs) are a class of synthetic organic compounds that share the same basic biphenyl structure (12 carbons arranged into 2 rings) with a varying number of chlorine atom substitutions. Up to 10 of the carbon atoms of the biphenyl molecule can chemically bond to chlorine atoms. PCBs usually occur in mixtures that

-15- ENVIRON TABLE III-l Summary of PCB Concentrations Detected in Fish from the Sheboygan River Minimum Detected Maximum Detected Mean Frequency of Concentration Concentration Concentration" Area/Species/Chemical Detection (rag/kg) (rag/kg) (rag/kg) Area 1 - Bass Aroclor 1242 0/12 NA NA NA Aroclor 1248 11/12 0.42 3.80 1.64 Aroclor 1254 12/12 1.40 6.50 3.09 Aroclor 1260 0/12 NA NA NA Area 1 -Carp Aroclor 1242 22/25 0.19 19.00 5.24 Aroclor 1248 0/25 NA NA NA Aroclor 1254 25/25 0.26 29.00 9.40 Aroclor 1260 1/25 1.50 1.50 0.81 Area 3 - Salmon Aroclor 1242 13/29 033 0.69 038 Aroclor 1248 0/29 NA NA NA Aroclor 1254 29/29 0.69 2.60 130 Aroclor 1260 27/29 0.35 130 0.66 Area 3 - SUelhead Aroclor 1242 15/15 0.19 1.90 0.42 Aroclor 1248 0/15 NA NA NA Aroclor 1254 15/15 0.22 130 0.61 Aroclor 1260 12/15 0.12 038 0.20 Area 3 • Bass Aroclor 1242 0/12 NA NA NA Aroclor 1248 12/12 0.51 230 1.21 Aroclor 1254 12/12 037 3.70 1.82 Aroclor 1260 0/12 NA NA NA Area 3 - Carp Aroclor 1242 25/25 036 4.50 2.42 Aroclor 1248 0/25 NA NA NA Aroclor 1254 25/25 0.64 5.40 3.64 Aroclor 1260 0/25 NA NA NA Notes:

1 Mean concentrations were calculated using one-half the detection limit for samples in which a chemical was not detected NA = Not applicable. Chemical was not detected in this species in this area of the river.

-16- ENVI RON MjiMiiiP.._v*_ _••';; V, _ J_ _ .'^j _ _ _ •_ _ —UL: — I

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FLOODPLAIN SOIL SAMPLING LOCATIONS TABLE III-2 Summary of PCB Concentrations Detected in Floodplain Soils Minimum Detected Maximum Detected Frequency of Concentration Concentration Mean Concentration* Area/Chemical Detection (mg/kg) (mg/kg) Areal Arodor 1248 48/71 0.10 120.00 11.00 Aroclorl254 64/71 0.07 72.00 8.70 Area 2 Arodor 1248 14/23 0.10 8.60 1.90 Arodor 1254 22/23 0.06 14.00 4.10 Area 3 Arodor 1248 23/35 0.08 96.00 5.40 Arodor 1254 32/35 0.07 130.00 7.40 Note:

1 Mean concentrations were calculated using one-half the detection limit for samples in which a chemical was not detected.

-18- ENVIRO N vary according to the numbers of chlorines on each biphenyl molecule as well as the position of the chlorine. There are 209 possible individual chlorobiphenyls (congeners) that can be subdivided by degree of chlorination (homologs), and further characterized by specific chlorine substitution patterns (isomers).2

PCBs Categories Category Number of Compounds Congener (entire set of PCB forms) 209 Homolog 10 homologs e.g., trichlorobiphenyl (TCB) (mono- through deca-) Isomer e.g., 3,3',5-TCB and 2^,4-TCB (2 of 24 TCBs) 1-46 per homolog

Various mixtures of PCBs have been sold under trade names such as Aroclor (United States), Clophen (Germany), and Kanedor (Japan). Aroclors are identified by a four-digit numeric code in which the first two digits (12) indicate that the product is a biphenyl (Le., 12 carbon atoms) and the last two digits indicate the percent chlorine content by weight. For example, Aroclor 1254 is a biphenyl with an average chlorine content of 54%. Aroclor 1016 is the exception to this numeric system; it retains the original 1016 designation under which it was developed. Aroclor 1016 is very similar to Aroclor 1242, with an average chlorine content of 41.5%, but the former contains a greater percentage of the lower-chlorinated congeners (di-, tri- and tetrachlorobiphenyls) than does the latter. PCBs have a low dielectric constant and high heat capacity, which made them useful in electrical capacitors and transformers. In addition, PCBs were used in carbonless duplicating paper, as extenders for pesticides and paints, and as hydraulic fluids. The U.S. production of PCBs peaked in 1970 and was terminated in 1977. Many

There is much inconsistency in the PCB literature with regard to the use of the terms "congener," "homolog," and "isomer." For the purposes of this risk assessment, these terms are defined as presented in Erickson (1986).

-19- ENVI RON transformers and capacitors that were produced with PCBs and contain PCBs are still in service. PCBs have low solubility in water, and the solubility generally decreases as the degree of chlorination increases, with the exception of the decachlorobiphenyl which is about twice as soluble as the octachlorobiphenyl. Furthermore, the degree of solubility varies between chlorobiphenyls with the same degree of chlorination. The position of the chlorine on the biphenyl ring influences the solubility; for example, 4,4'- dichlorobiphenyl is approximately 20 times less soluble than 2,2'-dichlorobiphenyl. Solubilities of commercial mixtures range from 25 ppb to 200 ppb for Aroclor 1260 and Aroclor 1242, respectively. These solubilities are influenced by the dissolved organic substance content of the environmental medium. Sorption of PCBs to soils and sediments increases with increased chlorine content of the chlorobiphenyl and with increased surface area and organic carbon of the sorbent. The chlorobiphenyls with higher chlorine content are not only sorbed in larger quantity, but are also held more tightly on sorbent surfaces (ATSDR 1991b). PCBs have very low vapor pressures, which decrease with increased chlorination. Vaporization rates decrease approximately 200-fold from Aroclor 1221 to Aroclor 1260. Sorption of PCBs on soil or sediment surfaces affects the rate of PCB vaporization. The vapor loss decreases with increasing organic matter content Possible routes of environmental breakdown include photochemical degradation, biodegradation and thermal degradation. Biodegradation of PCBs can occur under both aerobic and anaerobic conditions, with the PCBs containing chlorines in the para3 positions being preferentially biodegraded compared to PCBs containing chlorine in other ring positions. Generally, the persistence of PCBs increases as the degree of chlorination increases (USEPA 1983).

"Para" indicates that substitutions are present at opposite positions on the 6-carbon ring (two intervening unsubstituted carbons); "ortho" refers to the presence of substitutions at adjacent carbons; "meta" refers to the presence of substitutions at two carbons, with an intervening unsubstituted carbon.

-20- ENVIRON IV. TOXICITY ASSESSMENT

A. General Considerations PCBs are widespread in the environment and are found in body tissues and fluids of the general population. When evaluating the potential effects of PCB exposure on human health, one must take into account the facts that PCBs found in the environment are far less concentrated than commercial mixtures and that, within the class of chemicals known as PCBs, there are a variety of different congeners and impurities, each with its own characteristics. The PCBs to which the general population is exposed are diluted and are likely to be different from commercial PCB mixtures. Within the environment, changes in congener composition of PCB mixtures result from differential partitioning and transformation of individual congeners, and differential biological metabolism and storage of the congeners. PCBs are lipophilic and tend to accumulate in the adipose tissue or organs with high fat content Serum and adipose PCB levels are indicators of exposure but may not provide accurate estimates of exposure or body burden because the concentrations of PCBs in serum vary with the concentrations of lipids and individual metabolic parameters. In addition, variations in laboratory analytic procedures and methods of data reporting complicate comparing one lab report with another. Much like the behavior of PCBs in the environment, animal and human data indicate that the pharmacokinetics of PCB mixtures are influenced by the degree of chlorination of the PCBs, the position of the chlorine on the biphenyl molecule and the species of animal. In general, those PCBs with higher degrees of chlorination are retained in the body longer. As the number of unsubstituted meta positions or adjacent unsubstituted carbon atoms increases, the percentage of the dose excreted increases. Structural differences among PCBs are associated with differential metabolism, resulting in potentially different physiologic sequelae including preferential

-21- ENVIRON bioaccumulation of metabolism-resistant congeners. It appears that higher-chlorinated PCBs and congeners that lack unsubstituted meta-para-vicinal positions are betu/ candidates for bioaccumulation (ATSDR 199 Ib). An analysis of Aroclor 1254 indicated a predominance of pentachlorobiphenyl isomers, which are relatively rapidly metabolized and excreted. In contrast Aroclor 1260 was primarily hexa- and heptachlorobiphenyl isomers which are more readily retained in adipose and skin storage depots for long periods (ATSDR 1991a). Much of the data on humans exposed to PCBs are from occupational studies. These studies involve PCB mixtures that are more concentrated than those found in the '- environment. The studies generally have many limitations including lack of sufficient information to determine the exposure doses and relative contributions of the inhalation and dermal routes, as well as confounders such as exposure to other substances. Swanson et al. (1995) have conducted a comprehensive review of the scientific literature involving human exposures to PCBs in which each of these studies was evaluated on the basis of a defined set of criteria considered to be standards in epidemiological research. The conclusions from this assessment were that of the 39 occupational studies reviewed ~~ only two provided positive evidence and three provided suggestive evidence for a PCB exposure-related effect, whereas none of the 33 studies where exposure had occurred in the natural environment provided positive or suggestive evidence of an association with "*• "\ adverse effects. Specifically, this review (Swanson et al. 1995) concludes that

7~ "the environmental and occupational studies of human exposure to PCBs performed to date appear to yield results that are not consistent with those observed in laboratory animal research or with effects observed in wildlife. A large number of adverse biological effects including tumor formation, reproductive failure, " developmental effects, immune system deficiencies, and neurological deficits have been observed in lower animals. Those results can be considered to establish the potential of PCBs to cause harmful effects in the human population. The ubiquitous, persistent, and accumulative nature of these chemicals increases the probability for observation of toxicity. Results from the human epidemiologic studies considered to be inconclusive in the present review have been used as evidence to support the claim that present environmental exposures are producing irreversible toxicity in the human population. These claims, in our opinion, should not be considered as being supported by acceptable evidence obtained from humans. The scarcity of reliable reports of human toxicity from PCBs is likely due to the fact that past environmental exposures to these chemicals were not high enough to produce harmful effects.

-22- ENVIRON More information on the relative sensitivities of humans and laboratory animals and the biochemical mechanisms of PCB action is needed to clarify what can be considered a human threshold for observation of PCB effects. The conduct of additional well-planned and -executed epidemiologic studies using newer measures of exposure and health outcomes is required.

Most of the data from PCB-treated animals comes from oral exposure studies using various commercial PCB mixtures for various durations. USEPA (1988) and the Agency for Toxic Substances and Disease Registry (ATSDR 1991a,b) have concluded that the available data are not sufficient to demonstrate that PCBs cause cancer in humans. Many of the effects attributed to PCBs in animals appear to be mediated by a common mechanism that involves a specific molecular receptor (Poland et al. 1976). The specific receptor-mediated mechanism, aryl hydrocarbon (Ah) receptor binding, has led to the development of structure-activity relationships for PCB congeners (Safe 1990). The PCB congeners that exhibit Ah receptor-mediated responses constitute only a small fraction of the total number of possible congeners routinely identified in environmental samples and may be present only as trace components in commercial PCB mixtures. While the USEPA has recognized that the effects of various individual PCB mixtures, if any, vary, in the past it has usually only directly addressed the carcinogenic effects resulting from exposure to a particular PCB mixture (Aroclor 1260).

B. Carcinogenic (Non-threshold) Toricity In assessing carcinogenic potential, USEPA uses a two-part evaluation in which the first step involves evaluating the likelihood that the substance is a human carcinogen (i.e., a weight-of-evidence assessment), and the second step involves defining the quantitative relationship between dose and response (i.e., development of a cancer slope factor (CSF)). In conducting the weight-of-evidence assessment, USEPA classifies a chemical into one of five groups based on the weight of evidence from human and animal investigations. These groups are as follows (NRC 1983):

Group A: Human Carcinogen (sufficient evidence of carcinogenicity in humans)

-23- ENVIRON Group B: Probable Human Carcinogen Bl -- limited evidence of carcinogenicity in humans B2 - sufficient evidence of carcinogenicity in animals with inadequate or lack of evidence in humans

Group C: Possible Human Carcinogen (limited evidence of carcinogenicity in animals and inadequate or lack of human data)

Group D: Not Classifiable as to Human Carcinogenicity (inadequate or no evidence)

Group E: Evidence of Noncarcinogenicity for Humans (no evidence of carcinogenicity in adequate studies).

As noted above, the output of the second part of the evaluation is the derivation of a CSF. A CSF represents the upper 95% confidence limit on the linear component of the slope of the carcinogenic dose-response curve in the low-dose (low-risk) region. The CSF is an upper-bound estimate of the probability of a response per unit intake of a chemical over a lifetime, and is derived by applying a mathematical model to extrapolate from the relatively high doses administered to experimental animgk to the lower exposure levels expected for human contact in the environment. A number of low-dose extrapolation models have been developed. Each is based on general theories of carcinogenesis or certain statistical principles rather than on actual tumor data for the specific chemical of interest. USEPA generally uses the linearized multistage model in carcinogenic risk assessment. Other models are available, and they generally predict lower cancer potency estimates than the linearized multistage model. The linearized multistage model does not provide the most "correct" or "accurate" measure of carcinogenic potency, but is used by USEPA in part as a policy matter to provide a high (conservative) estimate of carcinogenic potency. A number of the PCB mixtures have been tested for carcinogenicity in chronic bioassays in laboratory animals. Only PCB mixtures with 60 percent chlorine (Aroclor

-24- ENVIRON 1260) have been shown to be carcinogenic in laboratory animals. Therefore, less- chlorinated PCBs are either not carcinogenic or are substantially less potent than the more highly chlorinated mixtures (Chase et al. 1989). Based on its review of the available animal data for Aroclor 1260, USEPA has concluded that there is positive evidence for carcinogenicity of PCBs in animals and has placed PCBs in category B2 - "probable human carcinogen" based on adequate evidence in animals and inadequate or lack of evidence in humans. USEPA's Integrated Risk Information System (IRIS) describes the evidence for human carcinogenicity of PCBs as "inadequate." Specifically, IRIS (USEPA 1995) characterizes the body of epidemiologic data concerning PCBs by stating that "[although there are many studies, the data are inadequate due to confounding exposures or lack of exposure quantification." Specific limitations of the individual epidemiologic studies are summarized in IRIS. USEPA's CSF for PCBs of 7.7 (mg/kg-day)'1 is based on the bioassay of Aroclor "^ 1260 in rats (Norback and Weltman 1985, USEPA 1995). In this study, rats were fed a single dose of 100 mg/kg Aroclor 1260. Since only a single dose was administered; the dose-response relationship of Aroclor 1260 causing carcinogenic effects cannot be established. Because there is no information regarding which constituents in the PCB "M mixture might be carcinogenic, Aroclor 1260 has been assumed by USEPA to be representative of other PCB mixtures (USEPA 1988). This assumption is highly ' -""i • questionable and conservative. Proposed refinements of the CSF that have been recommended by scientists for less-chlorinated PCB mixtures are described below.

1. Differential Carcinogenic Potency Estimates based on Chase et al. (1989) _. In light of the questionable scientific validity of applying the CSF derived for Aroclor 1260 to all PCB mixtures, an independent review of the available data on the carcinogenic potential of PCB mixtures was prepared. The results of this review are presented in a report entitled Evaluation of the Toxicology of PCBs (Chase et al. 1989). This review was undertaken by an expert panel of physicians, toxicologists, and epidemiologists, including Kenneth H. Chase, M.D.; John Doull, M.D., Ph.D.; Seymour Friess, Ph.D.; Joseph V. Rodricks, Ph.D.; and Stephen H. Safe, Ph.D. Some of the critical conclusions of this expert panel are as follows:

-25- ENVIRON • consistent with the conclusions reached by USEPA (1988), the available epidemiological data do not show a causal relationship between PCB exposure and the subsequent development of any form of human cancer;

• only Aroclor 1260 and mixtures closely resembling Aroclor 1260 (notably Clophen 60) produced an excess of tumors (liver tumors) in long-term feeding studies in experimental animals; and

• the evidence that other (less chlorinated) PCB mixtures produce excess tumors in experimental animals is questionable. If the other (less chlorinated) mixtures are carcinogens, they are certainly of lower carcinogenic potency than Aroclor 1260.

; Building on these critical conclusions and the available lexicological Literature on PCBs, Chase et aL (1989) developed estimates of relative carcinogenic potential for "1 the different Aroclors based on relative chlorine content These estimates of carcinogenic potency are presented in Table IV-1. The CSF for Aroclor 1260 was derived from the same study used by USEPA (i.e., Norback and Weltman 1985) and USEPA's conservative linearized multistage low-dose extrapolation model4 The low-dose extrapolation model was modified, however, by using an interspecies scaling factor5 that was recommended by the expert panel as a more appropriate basis for 7-"' the expression of equivalent doses in rodents and humans. Chase et al. concluded that expression of equivalent doses in terms of body weight had the best empirical support This contrasts with the scaling factor used by USEPA to derive the current

Tccumseh does not endorse the linearized multistage low-dose extrapolation model or the Chase derivation of the cancer slope factor for Aroclor 1260.

The interspecies scaling (i.e., extrapolation) of dose is necessary to compensate for differences between humans and laboratory animals for such factors as size, lifespan, and basal metabolic rate. Previously, the most commonly used measures of dose were milligrams of chemical per kilogram of body weight of the animal per day (mg/kg-day) and milligrams of chemical per square meter body surface area per day (mg/m2-day). Both scaling factors have been used in risk assessment by different federal agencies. Historically, the USEPA has used mg/m2-day, while the Food and Drug Administration (FDA) has used mg/kg-day.

-26- ENVIRON TABLE IV- 1 Relative Cancer Slope Factors (CSFs) for PCBs Based on Chase et al. (1989 and Updates of Chase et al.) Estimates of Estimates Carcinogenic Potency of Carcinogenic as Presented in Estimates of Carcinogenic Potency Based Potency* Chase et al. (1989) on Updates of Chase et al. (1989) Data Set for Norback & Norback & Weltman Norback & Weltman 3 bioassays of 60% Aroclor 1260 Weltman 1985 1985 1985 chlorination formulations" Histopathology original original PWG reassessment PWG reassessment' Scaling Factor surface area body weight body weight to V* power body weight to V* power SF (mg/kg-day)'1 Aroclor 1260 7.7 13 33 13 Aroclor 1254" 7.7 0.8 1.9 0.7 Aroclor 1243d 7.7 0.4 0.8 03 Aroclor 124? 7.7 0.13 02 Oj07 T Notes:

* Based upon Arcdor 1260 and very conservative interspecies scaling, b Norback and Wcfonan (1985); Kimbrough et aL (1975); Schaeffer et aL (1984); SF calculiited as the geometric mean of four data sets Pathology Work Group reassessment presented b Institute for Evaluating Health Risk (1991). 4 Based on interpolating between Aroclor 1260 SF and Aroclor 1242 SF based on chlorine cmitept (according to Chase et aL 1989). * Based on relative potency of dophen A30 (similar in composition to Aroclor 1242) campared to dophen A60 (similar in com]ration to Aroclor 1260) in study by Schaeffer et aL (1984) - 1/10 based <>n original histopathology; 1/20 based on P*\V*G FE^SM^fllllfttlfr

-27- EN VIRON CSF for PCBs of 7.7 (mg/kg-day)"1 - in which dose is expressed in terms of the amount administered per unit of body surface area (approximated as body weight raised to the % power). Estimation of the CSF using a scaling factor based on body weight results in a CSF approximately six-fold lower than the value derived using a surface area scaling factor. From the bioassays performed by Schaeffer et al. (1984), it was shown that Clophen A30 is at least 10 times less potent a carcinogen than Clophen A60 in studies of identical design. Because Aroclor 1260 is similar in composition to Clophen A60 and Aroclor 1242 is similar to Clophen A30, Aroclor 1242 should exhibit a potency no more than one-tenth that of Aroclor 1260. Chase et al. (1989) thus assigned a potency to Aroclor 1242 of 0.13 (mg/kg-day)"1. The authors caution, however, that there are no studies that show a statistically significant increase in tumors for any mixture of PCBs other than Aroclor 1260 and Clophen A60. The estimate of carcinogenic potency for Clophen A30 was based on the combined incidence of hepatocellular carcinomas and neoplastic nodules. There is good to . conclude that the potency of the less chlorinated mixtures of PCBs is appreciably less than the estimate derived by Chase et al. I An interpolation procedure was used to assign potencies to the other Aroclors (Le., 1254 and 1248). The procedure was based on evidence that potency declines proportionally with chlorine content More specifically, estimated CSFs were derived based on the average number of chlorine atoms in each Aroclor. ^ Since the Chase et al. expert panel completed its analysis of relative carcinogenic potential of the various Aroclors, two reports have been published that have some bearing on some of the assumptions upon which the CSFs derived by Chase et al. were based. The Chase et al. analysis has been updated to reflect these recent publications.

2. Revisions to the Chase et al. Approach Based on Recently Proposed Scaling Factor As noted above, Chase et al. concluded that the most appropriate basis for the extrapolation of doses from animals to humans is in terms of body weight (or mass). Recently, however, a draft consensus document was published in the Federal

.28- ENVIRON Register by USEPA, the Food and Drug Administration (FDA), and the Consumer Product Safety Commission (CPSC), entitled Draft Report: A Cross-Species Scaling Factor for Carcinogen Risk Assessment Based on Equivalence of mg/kg3/4/day (USEPA 1992b). This draft document proposes that, "as the basis for a common and unified science policy among these three agencies on a default methodology for determining equivalence of doses ... when extrapolating results of rodent carcinogen bioassays to humans," that doses be expressed in terms of body mass raised to the % power. USEPA points out that other methodologies, including the body weight scaling factor used by Chase et al., are not necessarily less valid scientifically than the scaling factor of body weight to the % power. While this latter scaling factor is supported by the empirical data, it was in part selected to provide a single, consistent methodology across Federal agencies. Accordingly, the Chase et al. approach has been modified here by using the scaling factor of body mass to the % power, consistent with the proposal put forth by USEPA, FDA and CPSC.

3. Revisions to the Chase et al. Approach Based on Reevalnation of the Liver Histopathology The Institute for Evaluating Health Risk (IEHR 1991) commissioned a revaluation of six studies previously used for PCB carcinogenic risk assessment Reevaluation of the original liver slides for liver effects observed in these studies was performed by six noted pathologists, employing the current pathologic criteria developed by the National Toxicology Program (NTP). These criteria were updated in 1985 and thus provided the basis for a more uniform comparison among the studies and resulted in a recommended change in the carcinogenic potency estimates for PCBs. Of the six studies reviewed, four used Aroclor 1260 or its equivalent, Clophen A60. Three of these studies were long-term, and one was a reproductive study following nine months of exposure. These four studies were conducted with dietary intakes of 100 ppm of the particular PCB mixture. The two other studies reviewed were long-term studies on Clophen A30 and Aroclor 1254. All six studies

-29- ENVIRON were performed in rats, but of different strains and sexes. The results of the reanalysis are summarized as follows:

• confirmation via three different studies that chronic dietary exposure of rats to 60% chlorinated PCB formulations (i.e., Aroclor 1260 and Clophen A60) resulted in the development of benign and malignant liver tumors;

• chronic exposure of rats to a 54% chlorinated PCB formulation did not yield a statistically significant increase in either benign or malignant liver tumors. There was a small, non-significant increase in hepatocellular neoplasms, but the total number of affected rats was small and within the expected range for rats of the particular age and strain; and

' • chronic exposure of rats to a 42% chlorinated PCB formulation did not result in any increase in malignant liver tumors or a statistically significant I increase in benign liver tumors.

The CSFs for Aroclors 1260, 1254, 1248 and 1242, based on the revaluation of the liver pathology from the Norback and Weltman bioassay of Aroclor 1260 (as well as the scaling factor of body weight to the % power), are presented in Table 3. Consistent with the conclusions reached by Chase et al., the authors of the 7~- IEHR report concluded that considering all PCBs as equally carcinogenic is not supported by the data. They state that "[w]hile the results from studies of mixtures with 60% chlorination consistently report a high incidence of liver tumors, studies in rats which were fed mixtures with 54% or 42% chlorination did not detect statistically significant elevations of liver tumors" (IEHR 1991).

4. Revisions to the Chase et al. Approach Based on Consideration of Data from All Appropriate Bioassays As previously stated, USEPA developed the existing CSF for PCBs of 1.1 (mg/kg-day)"' using the results from only one bioassay (i.e., Norback and Weltman 1985) and data from only one sex (i.e., female Sprague-Dawley rats). The

-30- ENVIRON authors of the IEHR study recommend that data from all three studies employing chronic exposure to 60% chlorinated PCB formulations (i.e., Kimbrough et al. 1975, Norback and Weltman 1985, and Schaeffer et al. 1984), with the updated histopathology analysis, be used to develop a new CSF. More specifically, they recommended that the geometric mean of CSFs from all three studies (four data sets) should be used to develop the CSF for Aroclor 1260. Use of data from the three studies also has been used to estimate possible alternatives to the current CSF for Aroclor 1260. Relative carcinogenic potencies for Aroclor 1254, 1248 and 1242 based on data from the three studies, the revised CSF for Aroclor 1260, and the revised relative potencies of Clophen A60 and Clophen A30 are shown in Table 3. This approach was used to evaluate potential carcinogenic risk in this report It applies the most current scientific assessment of existing carcinogenicity studies. The "si analysis for Aroclors 1242 and 1248 are often more variable than for the other Aroclors. In fact, it is frequently difficult to distinguish between Aroclor 1242 and 1 Aroclor 1248. Accordingly, an intermediate CSF was used for these two Aroclors. Therefore, the CSFs used in this report were 13 (mg/kg-day)'1 for Aroclor 1260, 0.7 (mg/kg-day)'1 for Aroclor 1254 and 0.19 (mg/kg-day)'1 for Aroclors 1248 and 1242. A similar review of the carcinogenicity of PCBs has been presented by the Great Lakes Sport Fish Advisory Task Force (GLSFATF 1993), including a summary of the IEHR findings, inconsistences in human epidemiology studies, a discussion of cross- species scaling on the basis of body weight raised to the 3/4 power and differences in the carcinogenic potencies of different PCB congeners. The GLSFATF (1993) approach, therefore, supports the use of the modified cancer slope factors, as was done in this risk assessment.

-31- ENVIRON V. ESTIMATE OF HUMAN EXPOSURE

A, Receptors and Exposure Routes One of the first steps in the estimation of human exposure is the identification of populations which may be exposed to chemicals from the Sheboygan River and Harbor site. The primary possible receptors of concern for chemicals present at the site are individuals who eat contaminated fish caught in the Sheboygan River and Harbor as well as children and adults involved in recreational activities in and around the river and harbor.

1. Recreational Fishing 3 The approximate level of fish consumption from specified areas along the Sheboygan River was calculated using information provided in the site-specific -j Hmong survey (Appendix A) and the creel surveys (Appendices B and C).

Creel surveys. Creel surveys of anglers along the Sheboygan River were conducted in 1993 (Appendix B) and 1994 (Appendix C) by Mead and Hunt, Inc. For the purposes of the creel survey, the Sheboygan River was divided into three discrete sections: Area 1, Sheboygan Falls to the River Bend Dam; Area 2, River Bend Dam to the Waelderhaus Dam; Area 3, Waelderhaus Dam to Sheboygan Harbor; and Area 4 (Sheboygan Harbor)6 (see Figure ffl-1). During the Fall of 1993, 77 anglers were surveyed during a five week period from October llth to November 14th. Twenty-five, 10 hour sampling days were

No PCB congener data was available for fish in Area 4 and fish caught in the Harbor would be expected to be residents of Lake Michigan more so than fish which migrate from the Sheboygan River. Therefore, Area 4 was not included in the fish ingestion exposure scenario for this risk assessment.

-32- ENVIRON allocated over this period (10 weekend days and 15 randomly allocated weekdays). During the Spring of 1994, 147 anglers were surveyed within a ten week sampling period from April 9th to June 10th. Twenty-five, 12-hour sampling days were allocated over this period (10 weekend days and 15 weekdays). The creel surveys collected information about (1) the fish caught on the fishing trip completed or under way at the time of the interview (i.e., fishing location, type of fish caught, size of fish, species), (2) historical information about fishing, fishing location and fish consumption over the past year, (3) demographics of the anglers, and (4) fish preparation and cooking methods. l

Hmong survey. A survey of the Sheboygan Hmong community (a recently arrived ethnic refugee population from Southeast Asia) was conducted in 1994 i by Dr. Ray Hutchinson of the University of Wisconsin-Green Bay (Hutchinson 1 1994). A sample of 140 names and addresses was constructed from the 240 names and addresses listed for Hmong households in the 1994 Sheboygan area I telephone directory. From this group of 140 addresses, 122 interviews were completed with Hmong households. With a median household size of between _. | six and seven persons, these interviews represent data from between 730 and 980 individuals. A questionnaire was designed to measure fishing locations, fishing frequency, fish species caught and the frequency with which Hmong households consume i . specific species of fish from various locations. A series of questions was also asked to determine how game fish were prepared for cooking. When completed, the English-language version of the questionnaire was translated into Hmong by an experienced, native-Hmong language translator. Interviews were conducted in Hmong by three native Hmong-language speakers.

a) Fishing Locations Along the Sheboygan River Using the information obtained from the fall and spring creel surveys and the Hmong survey, an area-specific profile of fishing patterns was obtained.

-33- ENVIRON • Area 1 (Sheboygan Falls to River Bend Dam): Very limited fishing and fish consumption was reported for Area 1. Nonetheless, this area was included in the risk analysis. During the time of the creel survey, only one angler caught a smallmouth bass from Area 1; this bass was not going to be consumed. The historical information from the creel survey indicated that six anglers reported eating fish from Area 1 over the past year. The fish species consumed were smallmouth bass, walleye, panfish and muskellunge (musky). The Hmong survey revealed that only 3 anglers had fished in Area 1; these anglers reported catching steelhead n trout (the trout may have been incorrectly identified, as it is very rare to find steelhead trout in this portion of the river) and carp. It is interesting to note that, of the Hmong anglers that caught carp, approximately two-thirds reported that they never consume the carp that I they catch, as this group generally prefers species other than carp.

I • Area 2 (River Bend Dam to Waelderhaus Dam): Because there is very limited fishing between the River Bend and Waelderhaus Dams, and j virtually no documented fish consumption, Area 2 was not included in " the fish ingestion exposure scenario for this risk assessment According ' to Mead and Hunt (1994), there is only one access point for anglers in Area 2 and most of this river stretch is not hospitable to anglers (i.e., ^- heavy brush near the shoreline and slow turbid water.)

• Area 3 (Waelderhaus Dam to Sheboygan Harbor): Compared to Areas 1 and 2, fairly extensive fishing pressure was observed and reported for - , Area 3. This area was included in the risk analysis. During the time of the creel survey, 25 anglers caught 59 fish that were going to be consumed. Historical information from the creel survey indicated that 103 anglers reported fishing in Area 3 during the past year and 47 anglers reported that they consumed the fish caught from Area 3. The following fish species were consumed: salmon, steelhead trout, brown

-34- ENVIRON trout, brook trout, smallmouth bass, walleye, panfish, carp and suckers. ._ In addition, the Hmong survey indicated that 11 anglers fished in Area 3.

b) Fish Consumption Among Hmong Households •- The Hmong survey provides substantial evidence that Hmong anglers are more selective in their fishing behavior, and are engaged in behavior more accurately characterized as recreational fishing rather than subsistence fishing. The majority of the Hmong households, 72.5% of all respondents, reported that their families consumed fish once a month or less. This category includes 11.7% of the respondents who said that they and other members of their family never ate fish, 18.3% who said that they ate fish one or two times a year, and 42.5% who said that they ate fish once a month. ^ The preferred fish species for the Hmong angler is white bass, and the preferred fishing location is Lake Winnebago, including the Fond du Lac River. 1 Only three Hmong anglers reported fishing in the Sheboygan River from Sheboygan Falls to the Waelderhaus Dam. Most Hmong households in } Sheboygan appear to be familiar with the health advisories concerning the * 1 consumption of fish from the Sheboygan River and Harbor. --,, 1 The results of the Hmong survey indicate that the Hmong anglers and their families can be appropriately represented, in terms of fish consumption, by the respondents of creel surveys; thus, the quantitative distributions obtained from the creel surveys for meal frequency and meal size were assumed to apply to the _ Hmong community.

c) Summary In summary, the receptors evaluated in this risk assessment for fish ingestion from the Sheboygan River were selected based on information from the creel and Hmong surveys. A very limited number of anglers in Area 1 (Sheboygan Falls to River Bend Dam) may be exposed to PCBs by ingestion of resident fish species (e.g., bass) caught from the area of the river above River Bend Dam.

-35- ENVIRON Anglers in Area 3 may be exposed to PCBs by ingestion of migratory and resident fish species (e.g., salmon, steelhead and bass) sampled downstream of the Waelderhaus Dam.

2. Floodplain Soils Residents of Sheboygan and other areas near the Sheboygan River may also be exposed to PCBs by incidental ingestion of and dermal contact with floodplain soils during recreational activities. These individuals may be exposed while playing in areas of parks near the river (e.g., Esslinger, Kiwanis, and Rochester Parks) where some soils are not covered by vegetation. Since most areas along the river's floodplain are well vegetated, evaluation of the soil exposure pathways is very conservative. Potential soil exposures were evaluated for both adults and children (ages 2-6 years) in this assessment

B. Intake Calculations Chemical intakes (also referred to as daily doses) are expressed in terms of the mass of substance in contact with the body per unit body weight per time (or mg/kg-day). Doses are calculated as a function of chemical concentration in the medium, contact rate, exposure frequency and duration, body weight and averaging time. The generic equation for calculating the intake is as follows:

C x CR x EF x ED

where: C = Chemical concentration in medium, e.g., mg/kg; CR = Contact rate, kg/day, EF = Exposure frequency, days/year; ED = Exposure duration, years; BW = Body weight, kg; and AT = Averaging time period over which exposure is averaged, days.

.35. ENVIRON Accurate prediction of exposures is complicated by uncertainties in future behavior patterns of receptors and limitations in knowledge of other exposure variable values. A means of addressing the uncertainty in the prediction of exposures is to evaluate exposures using Monte Carlo simulation techniques in which distributions are used for input variables, rather than single "point estimate" values. The resultant distributions of estimated risks provide risk managers with a balanced portrait of the different levels of exposure and risk which may be experienced, and thus more complete information on which to base management decisions. In an exposure assessment, it is generally necessary to provide two different estimates of dose, one for carcinogenic effects and the other for systemic, or noncarcinogenic, effects. For carcinogens, the dose is estimated by averaging the total cumulative intake over a lifetime (i.e., set the averaging time equal to the estimated length of the lifetime) (USEPA 1989) and is referred to as the lifetime average daily • dose (LADD). The USEPA-sponsored risk assessment of the Sheboygan River area of concern only considered the carcinogenic human health risks (USEPA 1993). This is also supported by recent USEPA guidance for hazardous waste combustion facilities (USEPA 1994b). I Therefore, noncarcinogenic risk was not estimated in this report In this assessment, LADDs have been developed for children (2-6 years old) exposed "•I to floodplain soils (Table V-l) and for adults exposed to floodplain soils (Table V-2) and fish from the Sheboygan River (Tables V-3 and V-4). The intake assumptions used to evaluate exposure to PCBs in fish from the Sheboygan River are shown in Table V-5.

-37- ENVIRON TABLE V-l Cumulative DUtrfturttoni of lADDs DM to ExpoMrt to Soili tor Hypothetical ChiM Receptors (mc/kf-day) Incidental Insertion Dermal Contact PcrtcntUc Area 3 An«2 Anal A««3 Ana 2 Ana 1 Aroclor 1248 Aroclor 1254 Aroelorl248 Aroclor 1254 Aredorl24S Aroclor 1254 Aroclor 1248 Aroclor 1254 Aroclor 1248 Aroclor 1254 Aroclor 1248 Aroclor 1254 5 2.5C-10* 2.8e-10 2.6e-10 S.8e-10 14e-10 4.4e-10 4.2e-10 4.7e-10 4.4e-10 93e-10 3.9e-10 7.3e-10 10 2.6c-10 43e-10 2.7e-10 9.4c-10 14e-10 6.6e-10 4.4e-10 73e-10 45e-10 1.6e-09 3.9e-10 l.le-09 15 2.8e-10 S.le-10 2.8e-10 1.2e-09 2Je-10 18e-10 4.7e-10 13e-09 4.7e-10 2.0e-09 4.7e-10 1.5C-09 20 S.Oe-10 1.3e-09 3.9e-10 1.6e~09 4.0e-10 l.le-09 5.0e-10 2.2C-09 6.4e-10 2.7e-09 6.6e-10 1.9e-09 25 3.3e-10 1.9C-09 6.1e-10 2.1C-09 S.to-10 1.4e-09 53e-10 3.1e-09 l.Oe-09 3.4c-09 9.7e-10 2.3e-09 30 3.5e-10 2.5e-09 8.Se-10 2.6C-09 8^e-10 Zle-09 SJe-lO 4.1e-09 1.4e-09 4.4e-09 1.4e-09 3.4e-09 35 9.4e-10 3.6e-09 l.Oe-09 4.4e-09 l.le-09 16e-09 1.6e-09 5.9e-09 1.7e-09 7.3e-09 1.9e-09 4.4e-09 40 3.6e-09 6.6e-09 lJe-09 7Je^» l.leXW 3.6e-09 5.9C-09 l.le-08 2.2C-09 1.2e-08 1.9e-09 S.9e-09 45 5.1e-09 IJe-OB l.Se-09 9.9e4» lJe-09 4.5e-09 8.4C-09 14e-08 15C-09 1.6C-08 2.0e-09 73e-09 ; 50 8.9e-09 2.2*08 1.7*J» 1.6C-08 . ^P^tli -::?***»-^i :ft|;WW» ••• 3J5C-08 i8e-09 2.7C-08 2.7e-09 1.2e-08 55 1.3e-08 2.4e-08 7.5e-09 2Je-OB ZOe-09 l.le-08 ile-08 3.9e-08 1.2e-08 3.7e-08 3.3e-09 l.Se-08 60 1.7e-08 2.7e-OB 1.3e-OB S.Oe-08 37e-09 1.4e-08 2.8e-08 4Je-08 2.2e-08 8.3c-08 5.3e-09 2.2e-08 65 3.6e-08 3.3e-08 1.9e-08 6.0C-08 4.4e-09 ZOe-08 5.9e-08 5Je-08 3.2c-08 9.9e-08 7.3e-09 3.3c-08 70 45e-08 4.3e-08 2.5C-08 6.7e-08 l.Oe-08 2.6C-06 7.4e-08 7.1e-08 4.1C-08 l.le-07 1.7e-08 4.3e-08 75 6.3e-08 5.5e-08 3.1e-08 7.0e-08 l^e-08 3Je-08 l.Oe-07 9.1e-08 S.le-08 1.2e-07 3.1e-08 S^e-08 80 9.7e-08 7.3e.08 3.8e-08 7.3e-08 Zle-OB 4.U-08 1.6e-07 1.2e-07 6.4e-08 1.2e-07 3^e-08 6.8e-08 85 1.8e-07 1.4e-07 4.4e-06 73e-OB 4.4e-08 6.2e-08 3.1e-07 2.4e-07 7.3e-08 1.2e-07 7.3e-08 l.Oe-07

90 3^ffJ Z4«-07 4.8e-0ft WtJA •*3eX«:j|-: 9.7«M« 93t41 , 4.U-07 S.Oc-08 1.3C-07 LOe-07 l.oe-07 95 5.8e-07 4.6e-07 5.2e-08 l.Oe-07 1.6e-07 lJe-07 9.6e-07 7.5e-07 8.6e-08 1.7e-07 2.7e-07 3.0e-07 Note:

* Scientific notation presented «i 2-5e-10, for example, i* equal to 0.00000000025.

-38- ENVI RON 1'

TABLE V-2 Cumulattre Diftrlbatfoiti of LADDi DM to EspoMr* to SolU tor Hypothetical Adull Receptors (ntf/kg-day) Incidental Ingesfion Dennal Contact Pertentile Area 3 Anal Anal Area 3 Area 2 Area 1 Aroclor 1248 Aroclor 1254 Aroclor 1248 Arot lor 1254 Arotlorl24« Aroch>rl254 AnKfcrUtt Aroclorl254 Arock»rU48 Aroclor 1254 Aroclor 1248 Aroclor 1254 5 5.2e-l !• 5.8e-ll 5.4C-11 1.2e-10 4.9e-ll 9.1C-11 Z3e-10 2.6e-10 2.4e-10 5.2e-10 2.1e-10 4.0e-10 10 5.46-11 9.3e-ll 5.6e-ll 1.9e-10 4.9e-ll 1.4C.10 2.4C-10 4.U-10 2^c-10 83e-10 2-le-lO 6.0e-10 15 5.8e-ll 1.7e-10 S.8e-U 23e-10 5^e-ll IJe-lO 2.6C-10 7.3e-10 2.6e-10 l.le-09 2.66-10 7.9e-10 20 6.2e-ll 2.7e-10 8.0e-ll 3.3c-10 &2e-ll 2Je-10 Z7e-10 1.2e-09 3^e-10 1.4e-09 3.6e-10 l.Oe-09 25 6.8e-H 3.9e-10 1.3e-10 4.3e-10 l^e-10 X9e-10 3.0e-10 1.7e-09 5J«-10 1.9e-09 5.3e-10 1.3e-09 30 7.2e-ll S.le-10 1.7e-10 5.4c-10 IJe-lO 4Je-10 3-lc-lO 2.2e-09 7.7e-10 2.4e-09 7.7e-10 1.96-09 35 1.9e-10 7.4e-10 2.1e-10 9.1e-10 13e-10 5.4e-10 8Je-10 3.2e-09 9.4e-10 4.0e-09 l.Oe-09 2.4e-09 40 7.4e-10 1.4e-09 2.7e-10 lJe-09 13e-10 7.4C-10 3Je-09 6.0C-09 1.2e-09 6Jc-09 l.Oe-09 3.2e-09 45 l.Oe-09 3.0c-09 3.1e-10 2.0c-09 Z5e-10 9Jc-10 4.6e-09 1.3e-08 1.4C-09 8.9e-09 l.le-09 4.1e-09 50 l.Se-09 4.4c-09 35e-10 3,3e-09 ;::«|pali:f • ••:i5esw;;;;:i. ^SOft-W-:--' 1.9c^» Ue-09 I3e-08 1.4e-09 6.66-09 55 2.6e-09 4.9e-09 1.6e-09 4.7C-Q9 4.1e-10 13*4» \2t-t* 2.1e-08 6,8e-09 2.06-08 1.8e-09 l.Oe-08 60 3.56-09 S.6e-09 2.8C-09 l.Oe-08 6.6C-10 18e-09 l^c-08 2.4«-OB 1.2C-08 4-Sc-OS 2.9e-09 1.26-08 65 7.46-09 6.9e-09 3.9C-09 1.2C-08 9.1e-10 4.1e-09 SJe-08 3.0e-08 1.7e-08 5.4e-08 4.0e-09 1.86-08 70 9.2e-09 8.9e-09 5.1e-09 1.4e-06 Zle-09 5.4c-09 4.0e-08 3.9c-08 2.2e-08 6.16-08 9.2e-09 2.46-08 75 1.36-08 l.lc-08 6.4C-09 1.4C-08 3Je-09 6.9C-09 5.7C-OB 5.06-08 2.8e-08 6.3e-08 1.7e-08 3.0e-08 80 2.0e-08 Ue-08 7.9e4» IJe-OB 4.4e-09 8.4e-09 8At-« 6.8C-OB 33e-08 6.5e-08 1.9e-08 3.7e-08 85 3.8e-08 3.0e-08 9.1e-09 15e-08 9.1e-09 IJe-OB 1.7e-07 1.3e-07 4.0e-08 6.7e-OB 4.0e-08 5.66-08 : 90 6.66-08 5.0eJ» 9.9e-09 1.6e-08 .••:••&*»•&. ' ,WW»-::;i::-- ,:-;::i:i:.*!MI7 2.^-07 4^6-08 6.96-08 5.6e-08 8.86-08 95 1.2c-07 9.4e-OB l.le-08 2.1e-08 3Je-08 3.7e-08 5.2e-07 4.1e-07 4.7e-08 9.4e-08 1.4e-08 1.66-07 Note:

* Scientific notation presented as S.2e-ll, for example, is equal to 0.000000000052.

-39- ENVIRON 11

TABLE VJ Cmrnlatir* Distributions IDT LADDi DM to InfctHM of Fish from Area 3 (rag/k^-day)

Migratory Fish Resident Fish

Salmon SlMllwad Bass Carp Perccnttl* Aroclor 1242 Aroclor 1254 Aroclor 12*0 Aroclor 1242 Aroclor 1254 Aroclor 12*0 Aroclor 1248 Aroclor 1254 Aroclor 1242 Aroclor 1254

5 3.7e-07- Ue-06 4«*-07 10.-06 14*46 17*47 6Je-0« lJe-07 lJe-07 3.01-07

10 S.6e-07 2.7C-06 l.le-06 2Je46 3.9*46 3J*47 6.7C-OS J.le-07 ).0e-07 5.6C-07

1) 6.41-07 Ue-06 14*46 1»»«6 4J>46 9Je47 6#eJX 54e-07 3.7e-07 «.le-07

10 7.0r-07 19t-06 lJe-06 ljft>4» 3J*-06 1.7*46 9Je4l 5.6t-07 43e-07 lJe-06

25 7Je-07 3.1e-06 1.7t-06 3J»W 33*46 lJe-06 lJe-07 5Je-07 5Je47 14e-06

30 7.6e47 3Jt-06 I«e46 34t46 JJ*46 \9tJ» 17*47 7*47 6.7e47 1.5* -06

11 7.9«-07 1J«-06 l*e-06 3Je-06 «jO»46 2.1*46 3Jt-07 »4e-07 7Je-07 IJe-06

40 t3e47 fcta-Ot tO«-06 Ij»>W «J»46 1>46 3Je-07 9.7*47 7JC-07 1.6C-06

41 SJe-07 Ij6e-06 WW-06 X7*0» «,7«-06 U*46 3.7e47 14*46 S.9C47 l^e-06 ; : : : : : n 9*47 3^e-06 U»-06 ".i»4» -E " • '%*^H :!:?i' s.;-;; "»j*«s 3J*47 1.1*46 1JO*46 l^e-06 51 l.le-06 4Je-06 lle-06 4JB»46 7J*46 16*46 43c47 l.le-06 l.le-06 1.6. -06

65 l.Se-06 4.7e-06 2J*-06 4.7«-W 911*46 2Je46 34C-07 l-ir-06 IJe-06 1.7e-06

70 1.6C-06 3.0e-06 14e-06 4Je-06 94*46 3.1*46 3.7e-07 IJe-06 14e-06 lJe^6

75 1.7t-06 3^46 Ue-06 44*46 1.1*43 34*46 12c47 IJe-06 IJe-06 I.«e-06

80 1.9C-06 3Je-06 l«e-06 3A»4« 1J«-03 3J6*46 9j6e-07 IJe-06 1.6e46 2.0C-06

15 lSe-06 5.7C-06 3Je-06 «J*4t 13*45 4.1*46 l.lc-06 1J*46 1.7e46 Z.le-06

90 2.0t-06 tte-06 3J*« «*^::S;::?B:S' ;: • .v-S'jA^a.-:::- •$*. •••:; 47*46 14*46 IJe-06 1.7*46 Ue-06

95 lle-06 7Jt-06 J.7e-06 lJt-03 1J*43 5.2HXS lJe-06 l.Tc-06 1.7e46 Ue-06

Note:

' Scientific DOUlion pmcnied u 3.7e-O7, for example, li equal to 0.00000077.

-40- ENVI RON t I.

TABLE V-4 CmiraUlh* dlitributloiu for iADDi DM M InfMthM of Fbh from Area 1 (mf/kf -day) But Carp Prrrcnlllc Aroclor 1248 ArodorUM Areelorl242 Aroclor 1254 Aroclor 1260 5 2.5e-07 S.2e-07 2.4C-OB 5.3e-OB 3.4e-09 10 4.9e-07 l.Oe-06 5Je-08 1.2e-07 8.3e-09 15 7.4e-07 1.6e-06 9.2e-08 2.1e-07 l^e-08 20 l.Oe-06 2.1*46 lJe-07 \2c-ffJ 25e-08 25 1.3e-06 2.7e-06 1.9e-07 45e^)7 3.7e-08 30 1.6e-06 3Je-06 2.6e-07 S.9e-07 5.0e-08 35 2.0C-06 4.0e-06 3Je-07 7.8e-07 6.7e-08 40 2.4e-06 4Ae-06 4JC-07 l.Oe-06 8.8e-08 45 3.0C-06 6.0e-06 5.8e-07 1.3e-06 l.le-07

50 3.6e-06 Wpxs^-;;- ,;.:.• ;.- ;:;:;v^,We4ir 1.6e-06 1.4e-07 55 4.2C-06 8.6C-06 9.6e-07 2.0e-06 1.7e-07 60 S.Oe-06 l.Oe-05 l^e-06 2.6e-06 2.1e-07 65 6.1e-06 \3*& 1.6e-06 3.2e-06 2.7e-07 70 7.5e-06 13e-05 2.U-06 4.1e-06 3.4e-07 75 9.4e-06 lJe-Q$ Z7e-06 5.3C-06 4.4e-07 80 1.2e-05 2Je-05 3.6e-06 6.9c-06 5.9e-07 85 lJe-05 2.9e-05 5.0e-06 9.2e-06 7.9e-07 90 2,leX» aa^l^p .'::f:; •^—tm •.««-«••: • 1.3e.OS j 1.2C-06 95 3.2e-OS 6.1eXJ5 IJe-OS 2.2e-OS 1.9e-06 Note: * Scientific notation presented «s 1.2e-06, for example, is equal to 0.0000012.

-41- ENVIRON V TABLE V-5 Intake Assumptions for Fish Consumption Equation: C x MS x MF x CF x FI x ED x ABS Dose (mg/kg-day) = f BW x AT

Distribution Range of Parameter Type Values Reference

Q = Chemical Concentration in Fish (pg/kg) cumulative See Table 7 Measured CF = Conversion Factor (mg/pg) point estimate 0.001 Standard conversion FT = Fraction Ingested of given species (unitless) Area 1 - Bass 0.9 Mead and Hunt 1994, Hutchinson 1994 X*- Area 1 - Carp 0.1 Mead and Hunt 1994, Hutchinson 1994 Area 3 - Steelhead point estimates 0.766 Mead and Hunt 1994 Area 3 - Salmon 0.181 Mead and Hunt 1994 1 J Area 3 -Bass 0.031 Mead and Hunt 1994 Area 3 - Carp 0.023 Mead and Hunt 1994 -J MS = Meal Size (kg/meal) discrete 0.06 - 0.91 Mead and Hunt 1994 _ MF = Meal Frequency (meals/year) Areal discrete 1-6 Mead and Hunt 1994 1 Area 3 discrete 1-114 Mead and Hunt 1994 ED - Exposure Duration (years) cumulative 1-75 USEPA 1992d, AfflC 1994

**( ABS = Absorption (unitless) point estimate 1.0 Default BW = Body Weight (kg) lognonnal 42-155 Brainard and Burmaster 1992 >1(AT = Averaging Time (days) point estimate 25550 USEPA 1991

-42- ENVIRON Intake assumptions used to evaluate exposure to PCBs by incidental ingestion of floodplain soils are shown in Table V-6. The intake assumptions used to evaluate dermal exposure to PCBs in floodplain soils are shown in Table V-7. Distributions of exposure assumptions were developed from site-specific information, USEPA guidance (1989, 1990, 1991, 1992a, 1992c), and scientific literature, and were used in Monte Carlo simulations, using the @RISK (version 1.55) attachment to Symphony. These assumptions are discussed below and cumulative distributions of the input variables, based on 5,000 iterations, are summarized in tables later in this section.

C. Exposure Assumptions

1. Generic Assumptions

a) Exposure Duration Individuals were assumed to be exposed to fish and floodplain soils throughout the period of occupying one residence (USEPA 1991). Cumulative distributions of residential occupancy periods (ROPs) were used to estimate exposure duration for all pathways and receptors (USEPA 1994a). These distributions were developed using mobility, mortality, and population data and are summarized in AIHCs Exposure Factors Sourcebook (AIHC 1994). The ROP distribution for the total U.S. population was applied to adults in this assessment Exposure durations for adults ranged from 1 to 75 years, with a mean of 11 years and a median (50th percentile) of 8 years. USEPA's default value of 30 years was at the 93.5th percentile of this distribution. The 2-6 year old child could be exposed to soils for up to 4 years while in this age group. The ROP distribution for children less than six years old was therefore truncated with a maximum of 4 years. The median of this distribution was 3.5 years.

-43- ENVIRON TABLE V-6 Intake Assumptions for Incidental Soil Ingestion Equation: C, x JR x CF x Ft x EF x ED x ABS Dose (mglkg-day) = BW x AT

Distribution Range of Parameter Type Values Reference C, = Chemical Concentration in Soil (mg/kg) cumulative See Table 9 Measured CF = Conversion Factor (kg/mg) point estimate 0.000001 Standard conversion FI = Fraction Ingested from Contaminated point estimate 1.0 Default Source (unitless) IR = Soil Ingestion Rate (mg/day) Adult cumulative 0-216 Calabrese et aL 1990, AIHC 1994 Child cumulative 0-391 Calabrese et aL 1989, AIHC 1994 EF « Exposure Frequency (days/year) Adult triangular 1-46 Site-specific Child triangular 1-115 Site-specific ED = Exposure Duration (years) Adult cumulative 1-75 USEPA 1992d, AIHC 1994 Child cumulative 0.1-4 USEPA 1992d, AIHC 1994 ABS = Absorption (unitless) point estimate 03 USEPA 1986 BW = Body Weight (kg) Adult lognonnal 42-155 Brainard and Burmaster 1992 1 Child cumulative 10-25 USEPA 1990 AT = Averaging Time (days) point estimate 25550 USEPA 1991

-44- ENVIRO TABLE V-7 Intake Assumptions for Dermal Contact with Soil Equation:

uose (mg/Kg-aay) • •

Range of Parameter Distribution Type Values Reference C, = Chemical Concentration in Soil (mg/kg) cumulative See Table 9 Measured CF = Conversion Factor (kg/mg) point estimate 0.000001 Standard conversion SA = Skin Surface Area Available for Contact (on'/event) Adult uniform 1400-4600 USEPA 1990 Child uniform 870-2200 USEPA 1990 AF = Soil to Skin Adherence Factor (mg/cm2) uniform 0.2-LO USEPA 1992b EF = Exposure Frequency (events/year) Adult triangular 1-46 Site-specific Quid triangular 1-115 Site-specific ED = Exposure Duration (years) Adult cumulative 1-75 USEPA 1992d, AIHC 1994 Child cumulative 0.1-4 USEPA 1992d, AIHC 1994 ABS = Absorption (unitless) uniform 0.006-0.06 USEPA 1992b BW - Body Weight (kg) Adult lognormal 42-155 Brainard and Burmaster 1992 Child cumulative 10-25 USEPA 1990 AT = Averaging Time (days) point estimate 25550 USEPA 1991

-45- ENVIRON b) Body Weight Adult male body weight data were obtained from the National Health Survey conducted from February 1976 through February 1980. These data are best described by a lognormal distribution with a geometric mean of 76.6 kg (169 Ibs). The underlying normal distribution has an arithmetic mean of 5.13 and standard deviation of 0.17 (Brainard and Burmaster 1992). Body weights for male and female children 2 to 6 years old were simulated with a cumulative distribution, based on percentile data presented in the USEPA Exposure Factors Handbook (USEPA 1990). The arithmetic mean of body weights for this age group is approximately 16 kg (36 pounds).

2. Recreational Fishing

a) PCB Concentrations in Fish An extensive database of PCB concentrations in fish from the Sheboygan 1 River and Harbor has been developed based on samples collected since the 1970s. Analytical data from the most recent year of sampling for each species (1992 for salmon and steelhead and 1993 for bass) best represent current exposure concentrations for fish ingestion. Although PCB concentrations in fish decreased markedly following land-based removal activities in 1979, PCB concentrations in fish increased substantially following dredging in 1989 and 1990. Since that time the PCB concentrations have tended to decrease and absent intervening activities are likely to continue to decrease, although existing fish may live for some time and contain PCB concentrations near current levels. Current PCB concentrations in fish were used to estimate future concentrations for this risk assessment. Again, it should be noted that the PCB concentrations used were from uncooked fillets. Cumulative distributions of Aroclor concentrations in fillet samples of each fish species in each area, shown in Table V-8, were applied to represent

-46- ENVIRON JJ

TABLE V-8 Cumulative Distributions of PCB Concentrations in Fish (mg/kg)1 Area 3 Area 1 Salmon Steelhead Bass Carp Bass Carp Aroclor-1242 Aroclor-1254 Aroclor-1260 Aroclor-1242 Aroclor-1234 Aroclor-1260 Aroclor-1248 Aroclor-1254 Aroclor-1242 Aroclor-1254 Aroclor-1248 Aroclor-1254 Aroclor-1242 Aroclor-1254 Aroclor-1260 M mmuii-.li jiimmi 0.001 0.004 0.001 0.001 0.002 0.001 0.002 0.001 0.002 0.003 0.002 0.003 0001 0.00! 0001 5 Oil 073 0.15 0.14 0.16 0.02 0.11 0.22 0.42 0.68 0.25 0.84 0.20 0.41 0.02 10 0.17 0.80 0.34 0.20 0.27 0.04 0.12 0.54 0.70 1.30 0.53 1.54 0.25 0.93 004 15 0 19 0.84 0.41 0.20 0.33 0.07 0.12 0.92 0.86 2.10 0.96 1 96 0.34 1.22 009 20 021 0.85 0.43 0.21 0.37 0.12 0.16 0.96 1.00 2.80 1.16 2.18 0.88 1.70 0 15 25 021 0.90 0.49 0.23 0.39 0.13 0.32 1.00 1.27 3.15 1.25 230 1 06 2.00 0.21 30 0.22 0.93 0.55 0.24 0.40 0.14 0.47 1.30 1.5J 3.35 1.30 2.36 1 38 2.70 024 35 023 0.95 0.57 0.24 0.42 0.14 0.55 1.54 1.68 3.48 1.35 2.42 1 65 3.85 0 33 40 0.24 099 0.58 0.25 0.44 0.15 0.61 1.66 1.80 3.60 1.40 2.48 1 80 4 30 040 45 0.25 1 05 0.59 0.25 0.46 0.16 0.63 1.78 2.05 3.66 1.45 2.58 2 15 5.30 0.46 50 029 1.15 0.61 0.26 0.48 0.17 0.65 1.90 2.35 3.72 1.30 2.70 2.50 7.35 063 55 0.33 1.23 0.63 0.28 0.51 0.18 0.75 1.94 2.54 3.76 1.52 2.76 300 9.33 081 60 0.43 1.28 0.66 0.32 0.58 0.19 0.83 1.98 2.60 3.80 1.34 2.82 3.40 10.35 092 65 045 1.39 0.69 0.33 0.63 0.20 0.92 2.02 2.9) 3.86 1.36 288 5.57 11.12 1.02 70 0.48 1.47 0.71 0.34 0.67 0.22 0.97 2.06 3.20 4.10 1.58 3.14 5.90 11.75 1 09 75 0.50 1.54 0.7J 0.34 0.74 0.24 1.40 2.10 3.48 4.38 1.60 350 622 13.49 1.17 SO 054 1.61 0.78 0.3J 0.88 0.2S 1.64 2.16 3.80 4.60 1.72 362 640 16.99 1.25 83 0.57 1.68 0.93 0.42 0.93 0.29 1.82 2.22 3.91 4.85 1.84 380 924 18.12 1 35 90 058 1.87 1.04 0.62 0.95 0.33 1.88 2.28 3.95 5.05 1.96 4 10 16.30 1875 1 46 95 0.63 2.22 1.08 1.06 1.05 0.36 2.06 2.86 3.99 5.21 2.71 511 17.75 22.00 1 69 Maximum 069 2.60 1.30 1.90 1.30 0.31 2.30 3.70 4.30 5.40 3.80 630 19.00 28.98 200 Note:

' These distributions include samples which were non-detects, with values at one-half the detection limit.

•47- ENVIRON concentrations to which on adult might be exposed during fish consumption. The distributions were derived from the analytical data for specific Aroclors, assuming that non-detects had concentrations equal to one-half the detection limit.

b) Meal Frequency Area 3 (Waelderhaus Dam to Sheboygan Harbor). Using information obtained from the 47 creel survey anglers who reported consuming fish from Area 3, the fish meal frequency ranged from 1 meal per year to 114 meals per "• year, with a median of 5 meals per year. These data were entered into the i model as a discrete distribution. x_. Based on the availability of recent analytical data, two migratory species (salmon and steelhead trout) and two resident fish species (smallmouth bass and \ carp) were evaluated for Area 3. The meal frequency was apportioned to the evaluated species in the following manner:

~~ • 76% of the meal frequency was attributed to trout consumption (steelhead, brown and brook). Analytical data for steelhead trout was used to represent this group of fish.

• 18% of the meal frequency was attributed to salmon consumption. • Analytical data for chinook and coho salmon was used to represent this group of fish.

• 3% of the meal frequency was attributed to smallmouth bass, walleye and panfish. Analytical data for smallmouth bass was used to represent this group of fish.

• 2% of the meal frequency was attributed to carp and suckers. Analytical data for carp was used to represent this group of fish. The cumulative distribution of meal frequency is shown in Table V-9.

.48- ENVIRON Area 1 (Sheboygan Falls to River Bend Dam). Using information from the 6 creel survey anglers who reported consuming fish from Area 1, the fish meal frequency ranged from 1 to 6 meals per year, with a median value of 4.5 meals per year. As with Area 3, these data were entered into the model as a discrete distribution. Based on the availability of recent analytical data, two resident fish species (smallmouth bass and carp) were evaluated for Area 1. PCB concentration data for smallmouth bass was assumed to be representative of the other Area 1 fish species that are being consumed (walleye, panfish, and muskellunge). The data for carp indicate that very few anglers actually fished for and consumed this species from Area 1. While 10% of the fish meals from the aforementioned meal frequency distribution was attributed to carp and 90% was attributed to the fish species group represented by smallmouth bass, it should be noted that this j distribution is conservative in that very few fish are consumed from Area 1. In fact, a fish census performed recently by Blasland, Bouck & Lee, Inc., 1 demonstrated that only an estimated 21 legal-size bass (Le., > 14 inches long) are in Area 1 (see Appendix E). Therefore, there is an insufficient supply of bass in Area 1 to match the conservative exposure assumption used here.

c) Meal Size Information regarding meal size was obtained from the creel survey. Data from 133 respondents was entered into the model as a discrete distribution with a median meal size of 8 ounces (0.227 kg) and a range of 2 ounces (0.057 kg) to 32 ounces (0.908 kg). Meal size was then combined with meal frequency to obtain the total yearly fish consumption rate. This yearly consumption rate was divided by 365 to obtain a daily fish ingestion rate which was then used in the evaluation of the risk associated with fish ingestion. The cumulative distribution for meal size is shown in Table V-9.

-49- ENVIRON TABLE V-9 Cumulative Distributions of Exposure Parameters for Fish Ingestion

Meal Frequency Meal Frequency Exposure Body Weight Meal Size in Area 3 in Area 1 Percentlle Duration (yr) (kg) (kg/meal) (meal/yr) (meal/yr)

Minimum 1.0 41.8 0.06 1 1 5 1.6 57.9 0.11 1 1 10 22 61.7 0.11 1 1 15 2.8 643 0.11 2 1 20 3.4 66.4 0.11 3 2 25 4.0 68.4 0.11 3 2 30 4.8 70.1 0.11 3 2 35 5.6 7L8 0.23 4 4 40 6.4 73.4 0.23 4 4 45 12 75.0 0.23 5 4 ] 50 8,0 76.7 0.23 5 4 55 9.4 783 0.23 6 5 60 10.8 80.0 0.23 6 5 65 U2 81.9 023 9 5 70 13.6 83.8 Q23 10 6 75 15.0 86.0 034 12 6 80 18.7 88.5 0.34 15 6 85 223 91.4 034 20 6 90 26.0 953 0.45 27 6 95 33.0 101.4 0.57 62 6 Maximum 74.5 1543 0.91 114 6

-50- ENVI RON 3. Floodplain Soil

a) PCB Concentrations in Soil Cumulative distributions of Aroclor concentrations in soil, shown in Table V-10, were used to estimate exposure concentrations for adults and children visiting areas within the Sheboygan River's floodplain. As with concentrations in fish, the distributions were derived from the analytical data for specific Aroclors, assuming that non-detects had concentrations equal to one-half the detection limit. Additionally, duplicate samples from a single location were averaged together prior to developing the cumulative distributions.

b) Parameters for Incidental Ingestion of Soil Distributions of soil ingestion rates, shown in Tables V-ll and V-12, were based on AEHCs (1994) interpretation of Calabrese et al's soil tracer studies (Calabrese et al. 1989 and 1990, for children and adults, respectively). Although several tracers were used in these studies, the cumulative distributions developed by AIHC are based on zirconium data, reportedly the most reliable soil tracer. The mean soil ingestion rate was 45.6 mg/day for adults, and 61.8 mg/day for children. Limited information is available regarding the variability of exposure frequency to soil, so triangular distributions were developed based on climatic conditions and reasonable assumed behavioral patterns of adults and children. It was assumed that soil exposures would be limited to the period of the year when the ground is not covered by snow or frozen. The mean freeze-free period in Wisconsin is 161 days/year, or 23 weeks (ESSA 1968). Adults were assumed to have a maximum exposure of 2 days/week during the freeze-free period, or 46 days/year. Children were assumed to have a maximum exposure of 5 days/week during the freeze-free period, or 115 days per year. It was assumed that the

-51- ENVIRON TABLE V-10 Cumulative Distributions of PCB Concentrations in Soil (rag/kg)1 Area 3 Area 2 Areal Percentile Aroclor-1248 Aroclor-1254 Aroclor-1248 Aroclor-1254 Aroclor-1248 Aroclor-L254 Minim inn 0.025 0.025 0.028 0.028 0.025 0.027 5 0.025 0.047 0.028 0.061 0.027 0.030 10 0.025 0.070 0.029 0.10 0.028 0.048 15 0.030 0.093 0.030 0.13 0.030 0.086 20 0.042 0.12 0.041 0.17 0.032 0.14 25 0.062 0.15 0.065 022 0.035 020 30 0.091 0.22 0.090 0.28 0.037 0.26 35 0.12 028 0.11 0.47 0.10 038 40 0.12 038 0.14 0.76 038 0.70 45 0.13 0.48 0.16 1.05 034 134 50 0.17 0.77 0.18 1.72 0.94 2.29 55 0.21 1.17 0.80 2.40 136 230 60 034 L44 1.42 531 L80 2*7 65 0.47 2.10 2.03 636 3.80 335 70 LOS 177 2^3 7.11 4.73 438 75 1.96 3.54 330 7.40 6.72 5.86 80 224 434 4.08 7.69 1031 7.95 85 4.70 6.56 4.70 7.93 19.58 1531 90 6.63 1033 5.11 8.15 33.% 25.97 95 17.01 19.00 5.50 10.99 61.47 4829 Maximum 95.87 129.93 8.59 14.00 119.92 71.99 Note:

' These distributions include samples which were non-detects, with values at one-half the detection limit

-52- ENVI RON TABLE V-ll Cumulative Distributions of Exposure Parameters for Soil Ingestion and Dermal Contact for Hypothetical Adult Receptors Soil to Skin Body Exposure Exposure Ingestion Surface Adherence Weight Duration Frequency Rate Area Dermal Factor Percentile (kg) (yr) (days/yr) (rag/day) (cm1) Absorption (rag/cm1) Minimum 36.2 1.0 1.4 0.0 1400 0.006 020 5 58.0 1.6 8.5 0.0 1559 0.009 0.24 10 61.7 2.2 11.6 0.0 1719 0.011 028 15 643 2.8 14.0 0.0 1880 0.014 032 20 66.4 3.4 16.0 0.0 2040 0.017 036 25 68.4 4.0 17.8 0.0 2200 0.019 0.40 30 70.1 4.8 19.4 0.0 2359 0.022 0.44 35 71.8 5.6 20.8 0.0 2519 0.025 0.48 40 73.4 6.4 222, 0.0 2680 0.028 0.52 45 75.0 72 23.5 0.0 2840 0.030 056 50 76.7 8.0 24.7 0.0 3000 0.033 0.60 55 783 9.4 253 5.0 3159 0.036 0.64 60 80.0 10.8 27.0 10.0 3320 0.038 0.68 65 8L9 1Z2 283 15X) 3480 0.041 0.72 70 83.8 13.6 29.6 41.5 3640 0.044 0.76 75 86.0 15.0 3LO 82J 3799 0.046 0.80 80 88.4 18.7 32.6 1233 3960 0.049 0.84 85 91.4 223 34.4 155.9 4120 0.052 0.88 90 953 26.0 36.5 175.9 4280 0.055 0.92 95 101.4 33.0 393 196.0 4440 0.057 0.% Maximum 150.0 74.9 45.7 216.0 4599 0.060 1.00

-53- ENVIRON TABLE V-12 Cumulative Distributions of Exposure Parameters for Soil Ingestion and Dermal Contact for Hypothetical Child Receptors Soil to Skin Body Exposure Exposure Ingestion Surface Adherence Weight Duration Frequency Rate Area Dermal Factor Percentile (kg) (yr) (days/yr) (rag/day) (cm1) Absorption (rag/cm1) Minimum 10.0 0.1 22 0.0 870 0.006 0.20 5 13.0 1.8 22.6 0.0 936 0.009 0.24 10 13.5 2.1 31.6 0.0 1003 0.011 0.28 15 14.1 23 38.4 2.0 1069 0.014 032 20 14.4 2J 442 4.0 1136 0.017 036 25 14.6 2.7 493 6.0 1202 0.019 0.40 30 14.9 2.9 54.0 8.0 1269 0.022 0.44 35 152 32 582 10.0 1335 0.025 0.48 40 15.5 3.4 62,1 12,0 1402 0.028 0.52 45 15.7 3.5 65.8 14.0 1468 0.030 0.56 SO 16.0 3.5 69.4 16.0 1535 0.033 0.60 55 163 3.6 72,7 22.4 1601 0.036 0.64 60 16.7 3.6 755 28.7 1668 0.038 0.68 65 17.0 3.7 785 35.1 1734 0.041 0.72 70 17.4 3.7 81.9 41.5 1801 0.044 0.76 75 17.7 3.8 84.8 47.9 1867 0.046 0.80 80 18.1 3.8 88.0 542 1934 0.049 0.84 85 18.4 3.8 91.6 60.6 2000 0.052 0.88 90 193 3.9 95.9 67.0 2067 0.055 0.92 95 203 3.9 101.5 109.8 2133 0.057 0.% Maximum 25.0 4.0 114.4 1387.0 2200 0.060 1.00

-54- ENVIRON most likely exposure frequency for adults would be 26 days/year, corresponding to 2 days/week during June, July, and August. The most likely exposure frequency for children was assumed to be 83 days per year: 5 days/week during June, July, and August, and 2 days/week during May and September.

c) Parameters for Dermal Contact with Soil Detailed body surface area data have been published (USEPA 1990). Uniform distributions were used to estimate the amount of skin surface area available for dermal contact with soil (Tables V-ll and V-12). At least the 3 hands and face would be exposed; at most, the hands, forearms, lower legs, and face would contact the soil. These body parts correspond to a surface area of 1,400-4,600 cm2 for adults and 870-2,200 cm2 for children between the ages of 2 and 6 years (USEPA 1990). ' Studies of dermal absorption of 3,3',4,4'-tetrachlorobiphenyl, suggest that the percent of PCBs in soil which are absorbed through the skin ranges from 0.63% ] to 2.1% (USEPA 1992c). However, USEPA (1992c) has recommended that the upper end of the assumed range be set at 6% to account for uncertainty in the I data base. A uniform distribution, shown in Tables V-ll and V-12, was used to represent the percent of PCBs in soil which would be dermally absorbed, with a minimum of 0.6% and a maximum of 6% (USEPA 1992c). Based on information in USEPA (1992c), a uniform distribution, shown in j Tables V-ll and V-12, of 0.2 to 1.0 mg/cm2 was used to estimate the soil to skin adherence factor. Dermal contact with soil was assumed to occur with the same exposure frequency as incidental ingestion of soil (see discussion above).

-55- ENVIRON VI. RISK CHARACTERIZATION

A. Risk Calculations In this section, the estimated doses, calculated as described in Section V, are combined with the toxicity criteria presented in Section IV to estimate potential human health risks. LADDs are used to estimate potential cancer risk. The cancer slope factors (CSFs) represent the "plausible upper-bound estimate of the probability of a response per unit intake of a chemical over a lifetime" (USEPA 1989). Potential cancer risk is estimated in the following manner

Risk « LADD x CSF

where: Risk = Carcinogenic risk, number of excess cancers (e.g., 1 x 10"6 is 1 excess cancer in one million persons exposed), unitless; LADD = Lifetime average daily dose, mg/kg-day; and CSF = Cancer slope factor, (mg/kg-day)"1.

B. Potential Cancer Risks As shown in Table VI-1, estimated 90th percentile excess lifetime cancer risks in both Areas 3 and 1 were within the National Contingency Plan's acceptable range of 10'6 to 10^ (USEPA 1990). The predominant contributor to the potential cancer risk in Area 3 is ingestion of steelhead trout (4 x 10"3), while the predominant contributor in Area 1 is ingestion of bass (3 x 105).

-56- ENVIRON TABLE VI-1 Cumulative Distributions of Total Cancer Risk Ingestion of Fish from the Sheboygan River Area 3 Area 1 Migratory Resident Resident Ingestion Ingestion Flsbk Ingestion Ingestion Fish* Ingestion Ingestion Fish' Percentile of Salmon of Steelhead Total of Bus of Carp Total of Bass of Carp Total 5 le-07* 2c-07 3e-07 lc-08 2e-08 4c-08 5e-07 le-07 8e-07 10 2e-07 3e-07 5e-07 20-08 4e-08 7e-08 9e-07 2c-07 le-06 15 3e-07 5e-07 8c-07 3e-08 6c-08 le-07 le-06 3e-07 2e-06 20 4e-07 6e-07 le-06 4c-08 8c-08 le-07 2e-06 5e-07 2e-06 25 5e-07 8e-07 le-06 6c-08 le-07 2c-07 2e-06 6e-07 3e-06 30 6e-07 le-06 2e-06 8e-08 le-07 2e-07 3e-06 8e-07 4e-06 35 8e-07 le-06 2e-06 le-07 2e-07 3c-07 3e-06 9e-07 5c-06 40 le-06 2e-06 3e-06 le-07 2e-07 3c-07 4e-06 le-06 5e-06 45 le-06 2e-06 3e-06 lc-07 2e-07 4e-07 5e-06 le-06 7e-06 50 le-06 2c-06 4c-06 mim •-•:-. •-rtevjm- Se-07 6c-06 2c-06 8c-06 55 2e-06 3e-06 5e-06 2e-07 4c-07 6e-07 7e-06 2e-06 9c-06 60 2e-06 4e-06 6c-06 Sc-07 5e-07 8C-07 8e-06 3e-06 le-05 65 3e-06 5c-06 8c-06 4e-07 6c-07 le-06 lc-05 3e-06 le-05 70 4e-06 6e-06 le-05 5e-07 8c-07 le-06 lc-05 4«-06 2e-05 75 5e-06 8e-06 le-05 6e-07 le-06 2e-06 le-05 5e-06 2e-05 80 6e-06 le-05 2e-05 Se-07 le-06 2c-06 2e-05 6e-06 2c-05 85 9e-06 le-05 2e-05 le-06 2e-06 3c-06 2e-05 8e-06 3e-05 90 lc-05 2e-05 4c-05 %ni2itt» + <:c;>3e4»&"-: 5*06 3c-05 le-QS 4e-05 95 3e-05 5e-05 7e-05 3e-06 6c-06 9c-06 5e-05 2c-05 7c-05 Notes: * Scientific notation presented as le-07, for example, is equal to 0.0000001 or one in ten million. " Migratory fish are the salmon and steclhead groups. e Resident fish are the bass and carp groups.

-57- ENVIRON The estimated 50th percentile excess lifetime cancer risks in both Areas 3 and 1 were also within the National Contingency Plan's acceptable range of 106 to 10"4 (USEPA 1990). The predominant contributor to the potential cancer risk in Area 3 is ingestion of steelhead trout (2 x 10"6), while the predominant contributor in Area 1 is ingestion of bass (6 x 10*6). Table VI-2 shows the potential cancer risks to adult and child receptors associated with ingestion of and dermal contact with floodplain soils. Again, each of these estimated 90th percentile excess lifetime cancer risks is within or below the USEPA's acceptable benchmark range. Exposure to floodplain soils in Area 1 yielded the ^ relatively largest potential cancer risk for both the adult and the child receptor (3 x 10"7 and 7 x 10"7, respectively). N_. Each of the estimated 50th percentile excess lifetime cancer risks is below the USEPA's acceptable benchmark range. Exposure to floodplain soils in Area 1 yielded I the greatest potential cancer risk for both the adult and the child receptor (1 x 10** and 4 x 10"*, respectively).

.58- ENVIRON TABLE VI-2 Cumulative Distributions of Total Cancer Risk Soil Ingestion and Dermal Contact Adult Child Percentile Area 3 Area 2 Area 1 Area 3 Area 2 Area 1 5 le-10* 2e-10 2e-10 6e-10 9e-10 7e-10 10 3e-10 5e-10 4e-10 lc-09 2e-09 2e-09 15 5e-10 8e-10 9e-10 2e-09 3e-09 3e-09 20 7e-10 le-09 le-09 3e-09 4c-09 5e-09 25 lc-09 2e-09 2e-09 4e-09 6e-09 9e-09 30 2e-09 3e-09 3e-09 5e-09 9e-09 le-08 35 2e-09 4e-09 5e-09 7e-09 le-08 2e-08 40 3e-09 5e-09 7e-09 9e-09 2e-08 2e-08 45 4e-09 6e-09 lc-08 le-08 2e-08 3e-08 50 5e-09 8e-09 lc-08 2e-08 3c-08 4e-08 55 7e-09 lc-08 2e-08 2e-08 3c-08 5c-08 60 9c-09 lc-08 2e-08 3e-08 4e-08 7c-08 65 lc-08 2c-08 3e-08 4c-08 5c-08 9e-08 70 2e-08 2e-08 4e-08 5c-08 7c-08 le-07 75 2c-08 3e-08 6c-08 6c-08 9c-08 2c-07 80 3e-08 4e-08 Se-08 9e-08 le-07 2e-07 85 5e-08 6c-08 le-07 le-07 le-07 3e-07 : r :; : : : : '• • ' 90'' > -; ^•9e-08lt r 9^)8 .•ic4rw-i< : - ••/ae-O? ••:•;•;•, '''^&#im^ p;*c47--*- 95 2e-07 le-07 3e-07 4e-07 3e-07 7e-07 Note:

* Scientific notation presented as le-10, for example, is equal to 0.0000000001 or 1 b ten billion.

-59- ENVIRON VO. UNCERTAINTY

The ability to accurately estimate risks depends on the accuracy of the variables used in the calculations. The sources of uncertainty not addressed by the Monte Carlo analysis that are believed to have the greatest impact on this risk assessment are discussed below.

A. Estimation of Human Exposure

1. Ingestion of Fish This analysis considers the most recent sampling data available for each species of fish. Data from 1992 were used for salmon and steelhead trout, while 1993 data were used for bass and carp. The current exposure concentrations in fish were used to estimate future concentrations for this risk assessment This assumption will tend to overestimate the carcinogenic risk posed to hypothetical receptors in the fish ingestion scenario, as PCB levels in the Sheboygan River are expected to decrease, not remain constant, in the future. Additionally, these data were obtained using uncooked fish fillets. Had the fish been cooked prior to analysis, the PCB concentrations would be expected to be lower than those found in the uncooked fillets. A number of uncertainties are associated with the carcinogenic risks estimated for exposure to PCBs by ingestion of fish from Area 1. Firstly, PCB concentrations for smallmouth bass were used to represent PCB concentrations in a group of fish containing smallmouth bass, walleye, panfish and muskellunge. However, under protocols approved by USEPA, walleye, panfish and muskellunge have not been analyzed. In addition, smallmouth bass is expected to provide a reasonable representative PCB concentration for the other species in this group. Secondly, only

-60- ENVIRON six anglers in the creel survey reported eating fish from Area 1. The infrequent fishing trips assumed for the winter months are justified by the fact that sections of the river become ice-covered. The creel surveys were taken during the spring and fall runs of salmon and trout. At other times when fishing patterns have not been monitored, there may be somewhat more fishing in Area 1. The more frequently an angler fishes in Area 1, the higher the probability of including that angler in the creel survey. The creel surveys were conducted during peak fishing seasons on the Sheboygan River; rates of fishing at other times of the year could be lower. It should also be noted that most of the risk estimated in Area 3 is associated with the ingestion of migratory fish species (salmon and steelhead trout). The PCB concentrations in these fish are influenced by PCB concentrations in Lake Michigan rather than the Sheboygan River. In fact, a recent letter from USEPA Region V to BBL (1994b) states that J) "At this time, based on current conditions and the data collected thus far, U.S. Environmental Protection Agency (U.S. EPA) agrees with the 1 Wisconsin Department of Natural Resources (WDNR) and [BBL's] conclusion that PCB levels in adult coho and steelhead caught from the I Sheboygan River/Harbor are no greater than those levels observed in J coho and steelhead caught from the Root and Pigeon Rivers. In addition, U.S. EPA agrees that both WDNR and Superfund data •' demonstrate that current levels of PCBs in the Sheboygan River at this time do not appear to contribute significantly to total PCB body burdens in adult migratory salmonines."

As with Area 1, surrogate fish species were used to represent fish species for which recent analytical data was unavailable.

2. Exposure to Floodplain Soils A study by the Centers for Disease Control on PCB-contaminated soils in Paoli, Pennsylvania, has failed to demonstrate increased serum PCB levels in exposed individuals relative to levels found in a cross-section of the American public. Soil contamination in the residential neighborhoods studied ranged from less than 1 ppm to more than 6,400 ppm (Needham et al. 1992). Accordingly, any calculation of

-61- ENVIRON exposures to PCB-contaminated soils may grossly overestimate the actual carcinogenic risk posed by these exposures.

B. Monte Carlo Analysis The Monte Carlo analysis has been conducted using distributions derived from information in USEPA-published sources, where possible, for calculating carcinogenic endpoints. Monte Carlo analysis does not eliminate uncertainty due to data limitations regarding exposure parameters. This approach estimates ranges of risks for the potentially-exposed population, and permits the easy identification of risk values that correspond to reasonable worst-case estimates, thus avoiding the development of improbable risk estimates that approach the 100th percentile (as is the case with traditional "point estimate" risk assessments that rely on multiple individual exposure point estimates, many of which are at the 90-95th percentile). In the absence of USEPA-published distributions for exposure parameters, data from the scientific literature or from site-specific data sampling were used to derive distributions, or point estimate assumptions were used. This methodology leads to a more realistic prediction of risk from the pathways evaluated in this risk assessment than would otherwise be the case if conservative, default point estimate assumptions were used.

C Fish Sample Preparation The fish samples analyzed to generate the Aroclor concentration data in this risk assessment were not trimmed. The Protocol for a Uniform Great Lakes Sport Fish Consumption Advisory (GLSFATF 1993) indicates that "skinning and trimming the fish and cooking it in the proper fashion can remove much of the fat from the fish and therefore significantly reduce the levels of organic contaminants."7 This is supported by studies such as those presented by Skea et al. (1979) and Zabik et al. (1979). Skea et al. (1979) reported that removal of the skin and dorsal, ventral and lateral line fat from

7 We note that the GTSFATF has determined a Health Protective Value for human exposure of 5 x 10"s mg/kg-day for PCBs. This value was selected to be protective of both cancer and non- cancer health effects. This lifetime average daily dose (LADD) estimated in this risk assessment for the Sheboygan River is less than that value, indicating that there would not be any expectation of adverse health effects based on their analysis of the scientific data relating to PCBs.

-62- ENVIRON smallmouth bass can reduce the concentration of Aroclor 1254 by 64%. Similarly, Zabik et al. (1979) reported that cooking trout significantly reduced Aroclor 1254 by 26 to 70%, depending upon the level of preparation (e.g., skin off, trimmed). The GLSFATF protocol summarized many of the PCB reduction studies (GLSFATF 1993) and stated that

"as a whole, the literature indicates a contaminant reduction factor of 50% due to trimming and cooking is a realistic expectation for all lipophilic contaminants of concern in the Great Lakes. From the literature it is clear that a reduction in delivered dose of contaminant is greatest when careful trimming includes skin and fat removal. This appears to apply for the full gamut of lipophilic chemicals • commonly identified in Great Lakes sport fish. While skin removal prior to cooking appears preferable, simply discarding the skin after cooking also increases the reduction from the standard fillet. While the most data exists for brown trout and lake trout, other freshwater species such as smallmouth bass and salt water species such as bluefish also exhibit similar body lipid distributions and contaminants can be , reduced via trimming procedures. Carp has been less well studied and | trimming/conking reductions may be less, although study methodology may have accounted for the lower reductions reported 1 > The GLSFATF concluded that the combination of trimming and cooking offers the - I greatest reductions, reported to be at 60-80% (GLSFATF 1993). ~ I As noted previously, the fish samples used to estimate Aroclor concentrations in fish -_i caught in the Sheboygan River were neither trimmed nor cooked Based on the discussion presented above, it is fair to assume that trimming and cooking the bass, carp, salmon and steelhead samples prior to analysis would significantly reduce the concentrations of Aroclors detected. Trimming and cooking new fish samples has not been done. However, one could apply an approximate reduction factor to the concentrations of Aroclors presented in Table III-l to better estimate the concentration of Aroclors to which the hypothetical receptors evaluated in this risk assessment are exposed. Using the conservative 60% reduction in PCB concentration upon trimming and cooking would decrease the overall risks by approximately 60%.

D. Evidence of Human Toxicity from PCB Exposure Two recent articles have reviewed the scientific information on the effect of PCBs on human health (Kimbrough, 1995; James, et al., 1993). The conclusion reached by both

-63- ENVIRON of these scientists is that the only demonstrable human health effect attributable to high level occupational exposures to PCBs were dermal (i.e., chloracne). Further, that there is no clear and convincing evidence that PCB exposures were causally associated with adverse human health effects. It should be noted that an estimated LADD for occupational workers, based on acceptable occupational exposures (e.g. ACGIH - TLVs or OSHA PELs) would be at least three orders of magnitude greater than the LADDs calculated in this risk assessment for the Sheboygan River. In other words, the exposures estimated in this report are at least a 1,000 times less than an acceptable level of occupational exposure, that has not results in any adverse health effects, other than dermal.

71

1 '-I

.54. ENVIRON VIII. CONCLUSIONS

In this risk assessment, ENVIRON examined the potential human health risks presented by exposure to PCBs in and around the Sheboygan River. ENVIRON evaluated exposures to PCBs by the ingestion of fish as well as the incidental ingestion and dermal contact with floodplain soils. The U.S. Food and Drug Administration has established a tolerance level of 2.0 ppm total PCBs in fish fillets for interstate commerce (USFDA 1988). As demonstrated in this risk assessment, PCB concentrations exceeding 2.0 ppm in fish fillets do not necessarily imply unacceptable cancer risks. In summary, the 90th percentile total cancer risks to individuals eating fish caught in the Sheboygan River were 4 x 10~3 for migratory species from Area 3 (Waelderhaus Dam to Sheboygan Harbor) and 5 x 10"6 and 4 x 10*3 for resident species from Areas 3 and 1 (Sheboygan Falls to River Bend Dam), respectively. It should be noted that ingestion of migratory fish from Area 3 poses no greater risk than does ingestion of resident fish from Area 1. The 90th percentile total cancer risks associated with incidental ingestion of and dermal contact with floodplain soils were 9 x 10"8, 9 x 10"* and 2 x 107 for adult receptors in Areas 3, 2 (River Bend Dam to Waelderhaus Dam) and 1 respectively. Also, the 90th percentile total cancer risks associated with incidental ingestion and dermal contact with floodplain soils were 2 x 107, 2 x 10"7 and 4 x 10"7 for child receptors in Areas 3, 2 and 1, respectively. These risk levels were within or below the 10"* to 10^ benchmark range deemed acceptable in the National Contingency Plan.

3J12A:PCC00692.W51

-65- ENVIRON IX. REFERENCES

Agency for Toxic Substances and Disease Registry (ATSDR). 199la. Toxicological profile for selected pofychlorinated biphenyls (PCBs) (Aroclor-1260, -1254, -1248, -1242, -1232, -1221, and 1016). Draft.

Agency for Toxic Substances and Disease Registry (ATSDR). 1991b. Toxicological " profile for pofychlorinated biphenyls (PCBs). Final.

American Industrial Health Council (AIHC). 1994. Exposure Factors Sourcebook. May.

Blasland, Bouck & Lee (BBL). 1992. Alternative specific remedial investigation report: • - Sheboygan River and Harbor. Syracuse, NY.

Brainard, J., and D.E. Burmaster. 1992. Bivariate distribution for height and weight of --., men and women in the United States. Risk Analysis 12(2):265-275.

- Calabrese, E J., R. Barnes, E J. Stanek m, H. Pastides, CE. Gilbert, P. Veneman, X. Wang, A. Lasztity, and P.T. Kostecki. 1989. How much soil do young children _ j ingest: An epidemiologic study. Reg. TaxicoL Pharmacol. 10:123-137.

j Calabrese, EJ., EJ. Stanek, m, CJE. Gilbert and R.M. Barnes. 1990. Preliminary adult soil ingestion estimates: Results of a pilot study. Reg. Tox. Pharmacol 12:88-95.

.__ Chase, R.H., J. DoiUl, S. Friess, J.V. Rodricks, and S.H. Safe. 1989. Evaluation of the j toxicology of PCBs. Prepared for Texas Eastern Gas Pipeline Co. March.

Environmental Science Services Administration (ESSA) of the US Department of - Commerce. 1968. Climatic Atlas of the United States. Reprinted by the National Oceanic and Atmospheric Administration. 1983.

Erickson, M.D. 1986. Analytical chemistry of PCBs. Boston, Mass.: Butterworth Publishers.

Great Lakes Sport Fish Advisory Task Force (GLSFATF). 1993. Protocol for a uniform Great Lakes sport fish consumption advisory. Madison, WI. September.

Humphrey, H.E.B. 1988. Chemical contaminants in the Great Lakes: The human health aspect. In Toxic contaminants and ecosystem health: A Great Lakes focus, ed. M.S. Evans, 153-165. New York, NY: John Wiley and Sons.

-66- ENVIRON Hutchinson, R. 1994. Fish consumption of Hmong households in Sheboygan, Wisconsin. Green Bay, WI.

Institute for Evaluating Health Risks (IEHR). 1991. Reassessment of liver findings in PCS studies in rats. Pathology Working Group review. June 27.

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Mead & Hunt, Inc. 1993. Fish consumption survey: Sheboygan, Wisconsin, Fall 1993. Madison, WI.

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Needham, L.L., J.L. Pirkle, V.W. Burse, D.G. Patterson, and J.S. Holler. 1992. Case studies of relationship between external dose and internal dose. / Expo. Anal Env. Epidem. Suppl. 1:209-221.

Norback, D.H., and R.H. Weltman. 1985. Polychlorinated biphenyl induction of hepatocellular carcinoma in the Sprague-Dawley rat. Environ. Health Perspect 60:97- 105. Poland, A., E. Glover, and A.S. Kinde. 1976. Sterospecific high affinity binding of 2,3,7,6-tetrachlorodibenzo-p-dioxin by hepatic cytosol: Evidence that the binding species is receptor for induction of aryl hydrocarbon hydroxylase. /. Biol Chem. 16:4936-4946.

Safe, S. 1990. Polychlorinated biphenyls (PCBs), dibenzo-p-dioxins (PCDDs), dibenzofurans (PCDFs) and related compounds: Environmental and mechanistic considerations which support the development of toxic equivalency factors (TEFs). Crit. Rev. ToxicoL 21:51-88.

-67- ENVIRON Schaeffer, E., H. Greim, and W. Goessner. 1984. Pathology of chronic polycnlorinated biphenyl (PCB) feeding in rats. ToxicoL AppL Pharmacol 75:278-288.

Skea, J.C., H.A. Simonin, EJ. Harris, S. Jackling, JJ. Spagnoli, J. Symula and J.R. Colquhoun. 1979. Reducing levels of mirex, Aroclor 1254, and DDE by trimming and cooking Lake Ontario brown trout (Salmo trutta Linnaeus) and smallmouth bass (Micropterus dolomieui Lacepede). /. Great Lakes Res. 5:153-159.

U.S. Environmental Protection Agency (USEPA). Office of Pesticides and Toxic Substances. 1983. Environmental transport and transformation of pofychlorinated biphenyk. Leifer, A., R.H. Brink, G.C. Thorn, and K.G. Partymiller. Washington, D.C. EPA-560/5-83-025.

U.S. Environmental Protection Agency (USEPA). Office of Health and Environmental Assessment. 1986. Development of advisory levels for pofychlorinated biphenyls (PCBs) cleanup. Final. Washington, D.C. EPA/600/6-86/002. OHEA-E-187. May.

U.S. Environmental Protection Agency (USEPA). Office of Remedial Response. 1988. Superfund exposure assessment manual. Washington, D.C. EPA/540/1-88/001.

U.S. Environmental Protection Agency (USEPA). Office of Emergency and Remedial Response. 1989. Risk assessment guidance for Superfund. Volume L Human health evaluation manual (Part A). Interim final EPA/540/1-89/002. Washington, D.C. December.

U.S. Environmental Protection Agency (USEPA). 1990. Exposure factors handbook. EPA/600/8-89/043.

U.S. Environmental Protection Agency (USEPA). Office of Emergency and Remedial Response. 1991. Human health evaluation manual, supplemental guidance: Standard default exposure factors. Memorandum from T. Fields, Jr., Acting Director. OSWER Directive 9285.6-03. Washington, D.C. May.

U.S. Environmental Protection Agency (USEPA). 1992a, Guidelines for exposure assessment, Notice. Fed. Reg. 57:22888. May 29.

U.S. Environmental Protection Agency (USEPA). 1992b. Draft Report: A cross species scaling factor for carcinogen risk assessment based on equivalence of mg/kg*/day; Notice. Fed Reg. 57: 24152-24172. June 5.

U.S. Environmental Protection Agency (USEPA). Office of Research and Development. 1992c. Dermal exposure assessment: Principles and applications. EPA/600/8- 91/01 IB. Washington, D.C January.

.68- ENVIRON U.S. Environmental Protection Agency (USEPA). Office of Air Quality. 1992d. A Monte Carlo approach to simulating residential occupancy periods and its application to the general population. Office of Air Quality, EPA-450/3-92-011.

U.S. Environmental Protection Agency (USEPA). 1993. Assessment and remediation of contaminated sediments (ARCS) program: Baseline human health risk resulting from PCS contamination at the Sheboygan River, Wisconsin, area of concern. EPA/905/R- 93/001. February.

U.S. Environmental Protection Agency (USEPA). Office of Solid Waste and Emergency Response. 1994a. Revised Draft of Risk Assessment Implementation Guidance for Hazardous Waste Combustion Facilities. Memorandum from M. Shapiro, Director. May5.

U.S. Environmental Protection Agency (USEPA). Region V. 1994b. Letter from B. Eleder, Remedial Project Manager, to Blasland Bouck & Lee, Inc., regarding long- term fish monitoring in the Sheboygan River and Harbor. July 22.

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Wisconsin Department of Health (WDOH). Wisconsin Department of Natural Resources. 1993. Health guide for people who eat sport caught fish from Wisconsin waters. PUBL-IE-019. ApriL

Wisconsin Department of Health (WDOH). 1994. Public health assessment: Sheboygan River and Harbor, Sheboygan County, Wisconsin. Madison, Wl. April 29. Zabik, M.E., P. Hoojjat and CM. Weaver. 1979. Polychlorinated biphenyls, dieldrin and DDT in lake trout cooked by broiling, roasting or microwave. Butt. Environm. Contam. TolicoL 21:136-143.

3512A:PCC00692.WJ|

-69- ENVIRON APPENDIX A 3 I Hmong Survey 1 HMONG SURVEY

Introduction The State of Wisconsin Department of Public Health has identified three population subgroups in the Sheboygan area who may be consuming fish which have been placed in Category 3 of the Wisconsin state health advisory which recommends that these fish not be eaten. These three groups include subsistence fishermen (and their families), the local WIC population (low-income households with young children that receive assistance under the Well Infant and Child program), and the local Hmong community (a newly arrived, ethnic refugee population from Southeast Asia). The purpose of this study was to determine the extent of fish consumption among the Sheboygan Hmong community, with particular attention given to the amount and type fish consumed, method of preparation, and method of cooking for each species.

Sampling Procedurcsv While the U.S. Census data for 1990 reported a total of only 1,340 persons in the Hmong community, information provided by the State of Wisconsin suggested that there were between 400 and 450 Hmong households living in Sheboygan. With an average family size of six or seven persons, this would indicate a total Hmong population of 2,500 to 3,500 persons. Working from this population estimate, our initial proposal called for personal interviews with a sample of 150 households, which would represent coverage of between 30 and 40 percent of all Hmong households. We contacted the Lao Family Association in Sheboygan and requested a listing of the Hmong households living in Sheboygan and surrounding communities. The Board of Directors of the Lao Family Association met in February of 1994 to consider our written request for this information. Members of the board felt that the survey was unnecessary because Hmong households living in Sheboygan were aware of the health advisory; some

A-l ENVIRON members of the board suggested that the study be conducted in Green Bay, instead of in Sheboygan, because the board members understood that households in Green Bay were not aware of the health advisories to the same extent as households in Sheboygan. We constructed a sampling frame of 140 names and addresses from the 240 names and addresses listed for Hmong households in the 1994 Sheboygan area telephone directory. This represents a 58 percent sample of the 240 Hmong households listed in the telephone directory for the city of Sheboygan. From this group of 140 addresses, 125 interviews were completed with Hmong households. In three cases, the respondents were not fully cooperative during the interviews in that they did not want to give - information about their households. These cases were deleted from the final data file, and the responses reported here refer to completed interviews with 122 Hmong households. With a median household size of between six and seven persons, these interviews represent data for between 730 and 980 individuals. "3 Questionnaire and Interview Procedures i Fishing activity and fish consumption in the Great Lakes region has been studied by ~~ researchers from state resource agencies and research universities for several decades. I The questionnaire was designed to measure the frequency with which Hmong households •- i consume specific species of fish which are included in the health advisories. The potential risk from actual consumption of fish containing PCBs above the FDA limit is related to the type of fish, its age, the way in which the fish is cleaned and the way in f which it is cooked; it is also related to the amount consumed. PCBs are concentrated in the fatty tissues of the fish and accumulate there over time. Some species of fish are migratory and to the extent that they accumulate PCBs, they generally accumulate them from Lake Michigan. Some species of fish are leaner and grow more quickly, and thus are less likely to contain PCBs. Other species have a large volume of fatty tissue, grow slowly, live longer and over time may accumulate higher concentrations of PCBs. As provided by the Department of Natural Resources advisory, some health risks may be minimized by removing the skin from the fish and by removing the brown fatty tissue from the top and sides of the fish before cooking. For this reason, a series of questions asked respondents to indicate how game fish were prepared for cooking and the

A-2 ENVIRON preferred method of cooking both resident and migratory species. Where possible, our questionnaire made use of question wording and response formats used in previously-published studies. The final English-language version of the questionnaire was translated into Hmong by an experienced, native Hmong language translator. This individual speaks Hmong, Lao, Thai, French and English, and has worked for several years as a bilingual aid and translator for Hmong social service agencies in Wisconsin and Pennsylvania. In preparing the questionnaire used in this study (provided in Attachment A), we reviewed survey formats from earlier studies of sports fishermen and of fish consumption, including the 1985 Sports Fishing Survey (Wisconsin Department of Health and Human Services and University of Wisconsin-Extension), the 1991-92 and 1993 Sports Fishing Survey (Wisconsin Division of Health and University of Wisconsin- Madison, Water Chemistry Program), and Catching and Eating Freshwater Fish in New York (Cornell University, Department of Natural Resources, Human Dimensions Research Unit, 1992). The final survey made use of color illustrations of smallmouth bass and coho salmon from a recent Department of Natural Resources (DNR) guide to sport fishing in Wisconsin. Because the DNR guide did not include illustrations of steelhead trout and carp, we used comparable color illustrations of these species from Lawrence M. Page and Brooks M. Burr Freshwater Fishes (a publication in the Peterson Field Guide series). In estimating fish consumption, we made use of illustrations from the most recent survey of fish consumption conducted by the Department of Public Health. These photographs show variously sized portions of fish arranged on a plate, complete with silverware and other table settings. The fish portions shown in these photographs show cleaned fish fillets, while the usual method of preparation by the Hmong is fish which has been steamed or boiled (prepared as a stew or a fish boil). The questionnaire included more detailed information about four different species of fish: bass and carp (resident species which live their entire lives in the Sheboygan River) and salmon and trout (migratory species which generally live most of their lives in Lake Michigan but, in the past, have been stocked in the Sheboygan River). Respondents were shown a picture of each of these species and asked whether they caught this type of

A-3 ENVIRON fish. Respondents who indicated that they did catch this type of fish were then asked where the fish were caught. Fish caught above Sheboygan Falls are not included in the health advisory, while fish caught in both the harbor and the river below Sheboygan Falls are included in the advisory. Fish from other locations (e.g., High Cliffs on Lake Winnebago) are not included in the state health advisory. Interviews were conducted in Hmong by three native Hmong-language speakers. Our previous research with the Hmong community indicated that many Hmong adults speak little or no English, and almost all would prefer to speak in Hmong. The use of native Hmong-language interview staff is essential for the success of any research project in this ethnic community. Households received a payment of $20.00 to compensate for the time required for their participation in the study. Although nominal payments to respondents for their participation in research studies is a recognized and accepted method for increasing sample quality in social science research, several households refused to accept payment after completing the interview.

Results Community Characteristics. The potential impacts related to the Wisconsin Department of Health fish consumption advisory are associated with the demographic characteristics of population subgroups in the community. Therefore, this report summarizes pertinent data relating specifically to the Hmong community. As shown in Table A-l, nearly half (44.3 percent) of the Hmong households we interviewed have lived in Sheboygan for five years or longer. Many of these households have become familiar with American lifestyles and are aware of health advisories warning against the consumption of fish from the Sheboygan River. About one quarter of the Hmong households had moved to Sheboygan within the last two years. While as many as half of these households had lived in other cities in Wisconsin, Minnesota and California before moving to Sheboygan, others moved to Wisconsin directly from refugee camps in Thailand.

A-4 ENVIRON TABLE A-l Survey Question HH-1 "How long have you lived in Sheboygan?" Five years or longer 443 percent Two to five years 27.0 percent Less than two years 28.7 percent n = 122

The demographic structure of the Hmong community in Sheboygan is similar to that of Hmong communities in other cities in Wisconsin. The average number of persons in J the Hmong households interviewed was 6.3 persons, and more than a third of the Hmong households (353 percent) had eight or more persons in the household. The Hmong in Wisconsin and in other states are likely to marry at an early age and have a large number of children, continuing a demographic pattern noted in ethnographic studies of the Hmong in Laos and Thailand. As shown in Table A-2, more than a third (36.0) of the households that we interviewed included children under the age of five, but only nine percent had children less than two years of age.

TABLE A-2 Survey Question HH-5 Family Composition Children less than two years of age 9.0 percent Children aged two-five years 27.0 percent No children under five years of age 63.9 percent n = 122

There is a strong association between years of residence in the community and household composition. More than eighty percent of the households that had lived in Sheboygan for less than five years included children under the age of two, and three-quarters (75.8 percent) include children aged two-five. Only 16.2 percent of the households that had lived in the community for more than five years, on the other hand, included children under the age of two; and nearly sixty percent (58.8 percent) of these

A-5 ENVIRON established households did not include children under the age of five. As will be seen below, the association between length of residence and household structure is significant in several respects.

Fishing Activity. The survey addressed levels of fishing activity by Hmong households. The results, summarized in Table A-3, indicate that 40 percent never fish while approximately 60 percent reported that one or more members of their family fish. Nearly two-thirds of the households interviewed reported no fishing activity at all or only infrequent fishing; many of the responses included in the "once a month" category were answers such as "one-two times a year" or "every other month." Only 2.5 percent fish "every day" and only 82 percent fish "almost every day." Information from earlier studies are similar to the results reported here. Subsequent data on fishing activity will be presented using data provided by families who responded positively to having fished.

TABLE A-3 Survey Question FA-4 "How frequently do yon go fishing?" Never 40.2 percent Once a month or less 23.8 percent Once a week 13.1 percent 2-3 times a week 12.3 percent Almost every day 8.2 percent Every day 2.5 percent n = 122

Fishing Location. The fishing locations reported in Table A-4 are based on cumulative responses to the question, "Where do you go fishing?" Up to five responses were recorded in the data base and are included in this table; 45 of the 77 respondents provided information on two or more fishing locations. Limited fishing activity is focused on local waterways. Hmong anglers travel substantial distances to their preferred fishing locations. The most frequently mentioned fishing location for Hmong

A-6 ENVIRON anglers is Lake Winnebago, including the area around High Cliffs (a state park on the east shore of the lake) and the Fond du Lac River (at a park on the south end of the lake). More than two-thirds (72.7 percent) of the Hmong anglers said that they fished in Lake Winnebago, and more than one-third (35.1 percent) fished in the Fond du Lac River. This area is located some forty to fifty miles west of Sheboygan. The two sites most frequently mentioned are twenty-eight miles apart The closest fishing location mentioned outside of Sheboygan is the Pigeon River, located just north of the city. Fishing locations outside of Sheboygan are shown in the map in Figure A-l. Nearly a quarter of the respondents said that they fished in the Sheboygan Harbor (24.7 percent). Another 14.3 percent fished in the Sheboygan River below Waelderhaus Dam. Only three respondents (3.9% of the total) said that they fished in the Sheboygan River above Waelderhaus Dam.

TABLE A-4 Survey Question FA-5 "Where do yon go fishing?" Lake Winnebago 72.7 percent Fond du Lac River 35.1 percent Sheboygan Harbor 24.7 percent Pigeon River 18.2 percent Sheboygan River (below Waelderhaus Dam) 143 percent Lake Michigan 13.0 percent Sheboygan River (from Sheboygan Falls to Waelderhaus Dam) 3.9 percent Other locations 13 percent n = 77 Note: Percentage total exceeds 100% due to cumulative responses.

A-7 ENVIRON FIGURE A-l

Fishing Locations Outside of Sheboygan

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1

U Pigeon River

njj--' ^^Shefaoygan Sheboygan Harbor -. v

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•ron .Washington

A-8 ENVI RON The pattern of fishing activity reported here is similar to that found in an earlier study of fishing activity for the Hmong population in Green Bay. Information from ihe Green Bay study indicated that relatively few Hmong anglers fished in the Fox River, and that many Hmong anglers travelled substantial distances to their preferred fishing location, Lake Winnebago, including the High Cliffs and Butte des Morts area, nearly 50 miles from the local community.

Fish Species. Information on the particular species of fish caught at the various locations by Hmong anglers suggests that the Hmong have developed very specific preferences related to fish availability in the northeast Wisconsin region. Respondents who indicated that they or other persons in their households did participate in fishing (n=78) were asked an open-ended question, "What type of fish do you/your husband catch when you/he go fishing?" Table A-5 summarizes the responses to the question. The most frequently mentioned species is white bass, which is available year-round in Lake Winnebago (the preferred fishing location for Hmong anglers, as noted above). More than three-quarters of the Hmong anglers (76.9 percent) reported that they catch white bass. Smallmouth bass, steelhead trout and carp, three species common to a number of rivers throughout the northeast Wisconsin area, were mentioned by more than a quarter of the households sampled. Coho salmon is caught less frequently, by only 16.7 percent of the Hmong anglers. Other fish species, including brown trout, lake trout, perch and catfish were mentioned by another 23.1 percent of the respondents. Nearly one-quarter (23.1 percent) of the respondents indicated that they also netted smelt in the spring, and in all but one instance this activity was reported in Sheboygan Harbor.

A-9 ENVIRON TABLE A-5 Survey Question FA-6 "What type of fish do you catch?" White Bass 76.9 percent Smallmouth Bass 28.2 percent Steelhead Trout 28.2 percent Carp 26.9 percent Smelt 23.1 percent Coho Salmon 16.7 percent Other Trout 9.0 percent Other (including perch and catfish) 14.1 percent n = 78 1 Note: Percentage total exceeds 100% due to cumulative responses. Fish Consumption. Fish consumption by Hmong households living in Sheboygan was measured by use of a general question (FA-1) which asked, "How frequently does your family eat fish at home?" as well as by separate questions (FA-7 through FA-10) which -1 asked "How frequently does your family eat fish during the summer, fall, winter and spring months?" Responses to the first of these questions, shown in Table A-6 below, indicate that a significant majority of Hmong households eat fish very infrequently. More than 70 percent of the respondents indicated that they eat fish "once a month or less." None eat fish every day. Fewer than 13 percent of the respondents (12.5 percent) indicated that they and others in their household eat fish "2-3 times a week" from the various locations noted above.

A-10 ENVIRON TABLE A-6 Survey Question FA-1 "How often does your family eat fish at home?" Never 11.7 percent Once a month or less 60.8 percent Once a week 10.8 percent 2-3 time a week 12.5 percent Almost every day 4.1 percent Every day 0.0 percent n = 120

Respondents were also asked to indicate how frequently they eat fish during the winter, spring, fall and summer months. The results to these questions (shown in Table A-7) indicate substantial variation in fish consumption from one time of the year to another. Over 90 percent (90.8 percent) responded that they eat fish "once a month or less" during the winter, compared with slightly more than half (54.6 percent) of the Hmong households which reported that they eat fish "once a month or less" during the summer months. As would be expected, the summer months see the highest levels of fish consumption, when 27.7 percent of the Hmong households report that they eat fish "once a week," "nearly every day" or "every day." Overall, responses to the four seasonal questions provide a more conservative estimate of the frequency of fish consumption by Hmong households than the initial (FA-1) question asking about fish consumption for the family as a whole. For nine months of the year, 80 percent or more of Hmong households report that they eat fish "once a month or less" (84.9 percent in the fall; 90.8 percent in the winter; and 84.5 percent in the spring).

A-ll ENVIRON TABLE A-7 Survey Questions FA-7 through FA- 10 "How frequently do you eat fish during the [season]?" Winter Spring Fall Summer Never 63.9 55.2 45.4 16.8 Once a month or less 26.9 29.3 39.5 37.8 Once a week 6.7 5.2 6.7 17.6 2-3 times a week 2.5 8.6 6.7 15.1 Almost every day 0.0 1.7 1.7 10.1 Every day 0.0 0.0 0.0 2.5 n=116 n=110 n=116 n=119 Figures within cells represent percentages unless otherwise indicated.

Resident Fish Species Smallmouth Bass. Separate questions asked about fishing activity and fish consumption for two resident fish species, smallmouth bass and carp. Responses to these questions are shown below. Note that the percentage responses shown within each table refer only to those respondents who indicated that they or other household members caught the specific fish species indicated. The sample subset of Hmong anglers represented in these tables is small: 24 respondents for the information about smallmouth bass and 31 respondents for the information about carp. While nearly a quarter (24.6 percent) of Hmong anglers indicated that they caught smallmouth bass, none of the anglers reported taking smallmouth bass from the upper Sheboygan River. The most common locations mentioned in Table A-8 for this species were Lake Winnebago (37.5 percent) and the Fond du Lac River (83 percent), which together were mentioned by 45.8 percent of the anglers. Just over 20 percent reported that they caught smallmouth bass in the Sheboygan Harbor (8.3 percent) and the Sheboygan River below Waelderhaus Dam (12.5 percent). Another 12.5 percent reported that they caught smallmouth bass in the Pigeon River and in Lake Michigan.

A-12 ENVIRON TABLE A-8 Survey Question SB-2 "Where do you usually catch smallmouth bass?" Lake Winnebago 37.5 percent Pigeon River 12.5 percent Lake Michigan 12.5 percent Sheboygan River (below Waelderhaus Dam) 12.5 percent Fond du Lac River 8.3 percent Sheboygan Harbor 8.3 percent Sheboygan River (from Sheboygan Falls to Waelderhaus Dam) 0.0 percent Other locations 83 percent n = 24

As shown in Table A-9, nearly half of the respondents (47.6 percent) indicated that they fished for smallmouth bass "once a month or less." This response category includes seven persons who indicated that they caught smallmouth bass "once or twice a year," "every other month" or some similar response. Only three persons responded "once a month," so the actual frequency of activity is substantially less than is suggested by the category shown. Only three (14.3 percent) of the respondents reported that they fished for smallmouth bass on a regular basis ('7-3 times a week" or more frequently).

A-13 ENVIRON TABLE A-9 Survey Question SB-3 "How frequently do you go fishing for smallmouth bass?" Once a month or less 47.6 percent Once a week 38.1 percent 2-3 times a week 9.5 percent Almost every day 4.8 percent Every day 0.0 percent n = 21

Consumption of smallmouth bass caught by Hmong anglers in our sample is even less frequent than their reported fishing activity for this species. More than three-quarters (783 percent) of the Hmong anglers reported that they "never" eat smallmouth bass or eat this fish "once a month or less" (Table A-10). Only one person (43 percent) reported that he ate smaUmouth bass "2-3 times a week," and none reported that he/she ate it "almost every day" or "every day."

TABLE A-10 Survey question SB-4 + SB-5 •How often do you eat smallmouth bass after you have caught it?* Never 34.8 percent Once a month 43.5 percent Once a week 17.4 percent 2-3 times a week 43 percent Almost every day 0.0 percent Every day 0.0 percent n = 23

A-14 ENVIRON Carp. With regard to carp, the two most common locations for carp mentioned by Hmong respondents are Lake Winnebago and the Pigeon River (Table A-11). Nearly a third (32J percent) took carp from Lake Winnebago and more than a quarter (25.8 percent) of Hmong anglers caught carp in the Pigeon River.

TABLE A- 11 Survey Question CP-2 "Where do you usually catch carp?" Lake Winnebago 32.3 percent Pigeon River 25.8 percent Sheboygan Harbor 12.9 percent Sheboygan River (from Sheboygan Falls to Waelderhaus Dam) 9.7 percent Sheboygan River (below Waelderhaus Dam) 9.7 percent Lake Michigan 32 percent Fond du Lac River 32 percent Other locations 32 percent n = 31

More than half of the anglers (56.6 percent), as shown in Table A-12, indicated that they fished for carp infrequently, e.g. "once or twice a year" or "once a month." This response category includes thirteen persons who indicated that they caught carp "once or twice a year," "every other month" or some similar response, and four persons who responded "once a month." The actual frequency of activity is, therefore, substantially less than once a month. Only about one-in-seven (13.3 percent) of the anglers reported that they caught carp on a regular basis ("2-3 times a week" or more).

A-15 ENVIRON TABLE A-12 Survey Question CP-3 "How frequently do you go fishing for carp?" Once a month or less 56.6 percent Once a week 30.0 percent 2-3 times a week 10.0 percent Almost every day 3.3 percent Every day 0.0 percent n = 30

Consumption of carp caught by Hmong anglers in our sample is less frequent than their reported fishing activity for this species, as shown in Table A-13. More than two- thirds (67.7 percent) of the Hmong anglers reported that they "never" eat the carp that they catch. Another 12.9 percent reported that they eat this fish "once a month or less." Only 32 percent reported that they ate carp "once a week." Only five households (16.1 percent of the Hmong anglers who reported that they caught carp) indicated that they ate this fish "2-3 times a week." None of the Hmong anglers reported that they ate it "almost every day" or "every day."

TABLE A-13 Survey Question CP-4 + CP-S "How often do you eat carp after you have caught it?" Never 67.7 percent Once a month or less 12.9 percent Once a week 3.2 percent 2-3 times a week 16.1 percent Almost every day 0.0 percent Every day 0.0 percent n = 31

A-16 ENVIRON Migratory Fish Species Steelhead Trout. A second group of questions asked about fishing activity and fish consumption for two migratory fish species found in the Sheboygan River, steelhead trout and coho salmon. Responses to these questions are shown below. The percentage responses shown within each table refer only to those respondents who indicated that they or other household members caught the specific fish species indicated. The majority of Hmong anglers reported that they did not catch these fish on a regular basis. There were 17 respondents for the information about steelhead trout and 12 respondents for the information about coho salmon. Only about one-in-six (15.1 percent) of the Hmong anglers indicated that they caught steelhead trout The most common locations where steelhead trout are caught (shown in Table A-14) include four locations near Sheboygan, including Lake Michigan (23.5 percent), the Sheboygan Harbor (mentioned by 23.5 percent of the anglers), the Pigeon River (17.6 percent) and the Sheboygan River below Waelderhaus Dam (mentioned by 17.6 percent). Another 5.9 percent reported that they caught steelhead trout in the Sheboygan River above Waelderhaus Dam (which is highly improbable as the migratory species are physically unable to get by the dam).

TABLE A-14 Survey Question ST-2 "Where do you usually catch steelhead trout?' Lake Michigan 23.5 percent Sheboygan Harbors 23.5 percent Sheboygan River (below the Waelderhaus Dam) 17.6 percent Pigeon River 17.6 percent Sheboygan River (from Sheboygan Falls to Waelderhaus Dam) 5.9 percent Lake Winnebago 5.9 percent Fond du Lac River 0.0 percent Other locations 5.9 percent n = 17

A-17 ENVIRON Nearly two-thirds (61.6 percent) of the anglers who reported that they caught steelhead trout indicated that they fished for this species "once a month or less," as shown in Table A-15. This response category includes five persons who indicated that they caught steelhead trout "once or twice a year," "every other month" or some similar response and three persons who responded "once a month." Less than one-in-six (15.4 percent) of the respondents reported that they caught steelhead trout on a regular basis ("2-3 times a week" or "almost every day"). None of the respondents indicated that they fished for steelhead trout "every day."

TABLE A-1S Survey Question ST-3 "How frequently do you go fishing for steelhead trout?" Once a month or less 61.6 percent Once a week 23.1 percent Almost every day 15.4 percent 2-3 times a week 0.0 percent Every day 0.0 percent n = 13

Table A-16 shows that nearly two-thirds (62.5 percent) of the Hmong anglers reported that they did not eat steelhead trout, and another 18.8 percent indicated that they eat this fish "once a month or less." Only 6.3 percent (n= 1) reported that they eat steelhead trout "2-3 times a week," and another 6.3 percent (n=l) said that they eat this fish "every day." TABLE A-16 Survey Question ST-4 + ST-5 "How often do you eat steelhead trout after you have caught it?" Never 62.5 percent Once a month or less 18.8 percent Once a week 63 percent 2-3 times a week 63 percent Almost every day 0.0 percent Every day 63 percent n = 16

A-18 ENVIRON Coho Salmon. Only twelve of the Hmong anglers (9.8 percent) indicated that they caught coho salmon, making this the least frequently caught fish of the four fish species that were studied. As expected, due to the behavior of this species, the two most common locations for coho salmon were Sheboygan Harbor and the Sheboygan River below Waelderhaus Dam each mentioned by 33.3 percent of the respondents (Table A-17). One-quarter (25.0 percent) of the Hmong anglers reported that they caught coho salmon in Lake Winnebago.

TABLE A-17 Survey Question CS-2 "Where do you usually catch coho salmon?" Sheboygan River 333 percent Sheboygan Harbor (below Waelderhaus Dam) 333 percent Lake Winnebago 25.0 percent Pigeon River 83 percent Lake Michigan 0.0 percent Sheboygan River (from Sheboygan Falls to Waelderhaus Dam) 0.0 percent Fond du Lac River 0.0 percent Other locations 0.0 percent n = 12

As summarized in Table A-18, more than half of the twelve respondents (54.6 percent) indicated that they fished for coho salmon "once a month or less." This response category includes five persons who indicated that they caught coho salmon "once or twice a year," "every other month" or some similar response and three persons who responded "once a month." Fewer than one-in five (18.2 percent) of the respondents reported that they caught coho salmon on a regular basis ("2-3 times a week" or "nearly every day").

A-19 ENVIRON TABLE A- 18 Survey Question CS-3 "How frequently do you go fishing for coho salmon?" Once a month or less 54.6 percent Once a week 27.3 percent 2-3 times a week 9.1 percent Almost every day 9.1 percent Every day 0.0 percent n = 12

Consumption of coho salmon caught by anglers in our sample was infrequent. Two-thirds (66.7 percent) of the Hmong anglers reported that they "never" eat the coho salmon that they catch (Table A-19). Another 25.0 percent reported that they eat this fish "once a month or less." Only 83 percent (n=l) reported that they eat coho salmon "once a week." These responses correspond with comments made by several respondents during the interview who indicated that coho salmon is not a preferred game fish and often is caught unintentionally in local rivers.

TABLE A-19 Survey Question CS-4 + CS-5 "How often do you eat coho salmon after you have caught it?" Never 66.7 percent Once a month 25.0 percent Once a week 83 percent 2-3 times a week 0.0 percent Almost every day 0.0 percent Every day 0.0 percent n = 12

A-20 ENVIRON Preparation and Consumption of Migratory and Resident Fish Species The survey included questions derived from earlier studies of fish consumption to determine the method of cleaning and preparing the migratory and resident fish species studied. The questions regarding cleaning the fish (SB-7, ST-7, CS-7, CP-7) were worded "How do you prepare this fish for cooking?" and included response categories of "skin is removed" and "fat from top and sides is removed." The questions about preparing the fish (SB-7, ST-7, CS-7, CP-7) were worded "How do you usually cook this type of fish?" and included the usual response categories of "boiled," "broiled," "baked" and "fried." In order to make these responses more meaningful to the Hmong respondents who may not ~* be used to American/European methods of broiling fish, these response categories were worded "boiled in stew," "broiled in oven," "baked in oven" and "fried in pan." Hmong responses to questions about preparation and cooking of migratory and resident fish species may not be directly comparable to data obtained from studies of the ^ general population or of subgroups such as commercial fishermen. First, it is important to note that the majority of respondents (between 70 and 80 percent) reported that they did not catch the fish species studied (smallmouth bass, steelhead trout, coho salmon and trout). A majority (again, between 70 and 80 percent) of those who reported that they did catch these species indicated that they did not eat the fish they caught Responses to these preparation and consumption questions are based on a very small number and, of those, many were not caught in the Sheboygan River. For smallmouth bass, steelhead trout and carp, the usual means of fish preparation is , to gut the fish and cut off the head and fins. Removal of skin and fatty tissue was mentioned by the majority of Hmong respondents for smallmouth bass, but by only one respondent for steelhead trout and by only two respondents for carp. The method of preparing coho salmon was different from the other species. All respondents (n=4) indicated that they removed the skin and fat Hmong responses to the questions about cooking methods are substantively different from that of other population groups. Broiling and baking fish in the oven are common cooking techniques in most American households. We have collected recipes for cooking fish from several Hmong households, and steaming fish and cooking fish in a stew (with vegetables and spices) would appear to be the most common methods of preparation. In

A-21 ENVIRON these recipes, the fish is often cut into steaks. There is a close correspondence between the method of fish preparation and cooking by Hmong households; fish which is steamed (whole) or boiled in a stew (steaks) will be cleaned and prepared in a different manner from fish which is broiled or baked. We asked Hmong anglers to estimate the amount of fish that they consumed at each meal. To insure consistency with other studies, we gave respondents copies of photographs of place settings with 1/3 and 1/2 pound fish portions used in a recent Department of Public Health study of Wisconsin anglers (Sports Fishing Survey, 1993). Responses for each of the migratory and resident fish species are shown in Table A-20.

TABLE A-20 Survey Question ST-P "How much [fish species] do you eat in a typical meal when you eat this species?" Bass Carp Trout Salmon 1/3 pound 20.0 722 20.0 25.0 1/2 pound 133 44.4 20.0 25.0 One pound 13.3 0.0 20.0 0.0 Other response 533 333 40.0 50.0 n=15 n=9 n=5 n=4 Figures within cells represent percentages unless otherwise indicated.

While most respondents indicated that they ate between 1/3 and 1/2 pound of fish at each meal, many respondents did not give one of the expected responses (a measure of weight of fish consumed at a typical meal). Instead, Hmong respondents were more likely to reply "a whole fish" or "two fish" than to estimate a specific weight (a whole smallmouth bass would be equivalent to 1/2 pound of edible fish, but even a direct calculation such as this is not warranted from the data obtained by survey results). One difficulty may be that the fish portions illustrated in photographs used in the Department of Public Health studies are not readily compared to the fish portions eaten by Hmong households. The photographs show skinned fish fillets, while the typical fish portion served in a Hmong household is likely to be a half or whole fish (steamed) or

A-22 ENVIRON fish steak (boiled or stew). Estimating the amount of fish consumed by comparison with photographs of cleaned fish fillets is difficult. A final note about the preference for particular migratory and resident fish species may be in order. For most Anglo fishermen, steelhead trout and coho salmon would be considered prized game fish. But many of our Hmong respondents indicated that they caught these fish unintentionally. Clearly, they were not fishing for them, and the majority indicated that they did not eat the fish when they caught it. The preferred fish among the Hmong community is white bass, a fish which is not preferred by Anglos.

Conclusions

1. Many Hmong do not fish and most Hmong do not fish frequently.

2. Of those who do fish, the preferred fish species for the Hmong angler is white bass. A relatively small number of Hmong anglers reported that they caught the migratory and resident fish species studied. Only 24.6 percent (n=24) of the Hmong anglers caught smaUmouth bass; 28.7 percent (n=31) caught carp; 15.1 percent (n=16) caught steelhead trout; and 9.8 percent (n=12) caught coho salmon.

3. The preferred fishing location for resident fish species assessed in this survey (smaUmouth bass and carp) is Lake Winnebago, including the Fond du Lac River at the southern end of the lake. Just 7.8 percent (n=6) of the Hmong anglers reported that they have caught resident fish species (smaUmouth bass and carp) in the Sheboygan Harbor or the Sheboygan River below Waelderhaus Dam; approximately 3.9 percent of the Hmong anglers surveyed (n=3) reported that they have caught fish in the stretch of the Sheboygan River extending from Sheboygan Falls to the Waelderhaus Dam.

4. Only a small number of individuals catch migratory fish species (steelhead trout and coho salmon) in Sheboygan Harbor and the Sheboygan River below Waelderhaus Dam. For example, while 33.3 percent of the Hmong anglers who reported that they

A-23 ENVIRON caught coho salmon said that they caught this fish species in the Sheboygan Harbor, this represents only four individuals.

5. The majority of Hmong households, an overwhelming 72.5 percent of all persons we interviewed, reported that their families consumed fish "once a month or less." This includes 11.7 percent of the respondents who said that they and other members of their family "never" eat fish, 18.3 percent who said that they eat fish "one or two times a year," and 42.5 percent who said that they ate fish "once a month." For nine months of the year (including the fall, winter, and spring months) at least 84 percent of the respondents indicated that their families consumed fish "once a month or less."

6. Consumption of both resident and migratory fish species from any location is substantially lower than the reported level of fishing activity for these species. More than two-thirds of the Hmong anglers reported that they "never" eat the carp, steelhead trout and coho salmon they catch. Only 21.7 percent (n=5) of the Hmong anglers who caught smallmouth bass reported that they consumed this fish "once a week" or more frequently; 193 percent (n=6) of the Hmong anglers who caught carp reported that they consumed this fish "once a week" or more frequently; 18.9 percent (n=3) of the Hmong anglers who caught steelhead trout reported that they consumed this fish "once a week" or more frequently; and only 83 percent (n=l) of the Hmong anglers who caught coho salmon reported that they consumed this fish "once a week" or more frequently.

7. Comments made by respondents suggest that Hmong households in Sheboygan were familiar with health advisories concerning the consumption of fish from the Sheboygan River and the Sheboygan Harbor. Information about the health advisories has been a regular part of the English as a Second Language (ESL) classes at the local technical school for many years.

8. While some persons seem to assume that the Hmong population represents a special category of subsistence anglers, there is substantial evidence that Hmong anglers are

A-24 ENVIRON more selective in their fishing behavior, and may be engaged in behavior more accurately characterized as sport fishing than as subsistence fishing. The majority of respondents who do fish do so infrequently, and the majority of Hmong anglers reported that they do not eat the resident and migratory species that were studied. During the course of the interviews, many respondents noted that this was a leisure activity.

9. Many Hmong anglers from the Sheboygan area report that they fish in Lake Winnebago, the Fond du Lac River or the Pigeon River, rather than the Sheboygan River or Sheboygan Harbor. Future informational efforts on the part of the DNR might better focus on the health risks associated with particular species of fish, rather than only the location of fishing activity.

10. Questions about the cleaning and preparation of fish used in earlier studies, and for other population groups, may not be relevant for the Hmong population. The preferred fish species, method of preparation and method of cooking fish appear to be different from that of other population groups. As a consequence, the usual type of serving and serving size will be different from that of other groups. The use of standard questions from other studies of fish consumption with Hmong respondents may produce some questionable data. There would be little value in conducting another survey that focuses on this. It should be emphasized that most Hmong households do not consume fish on a regular basis. Those that do would appear to represent 15 percent of the total Hmong population in the Sheboygan Area.

3512A:PCC00692.W51

A-25 ENVIRON References

Hutchinson, R. 1992. Acculturation in the Hmong Community (Second Edition). Green Bay: University of Wisconsin, Center for Public Affairs.

Hutchinson, R. and C. Kraft. 1994. "Fishing Activity and Fish Consumption." Journal of Great Lakes Research (forthcoming).

Page, L. M., and Burr, B. M. 1991. Freshwater Fishes. New York: Houghton Mifflin Company.

Questionnaires from Previous Research Studies

—. 1985. Sports Fishing Survey. Wisconsin Department of Health and Human Services and University of Wisconsin-Extension.

. 1991-92. Sports Fishing Survey, Wisconsin Division of Health and University of Wisconsin-Madison, Water Chemistry Program.

. 1992. Catching and Eating Freshwater Fish in New York. Cornell University, Department of Natural Resources, Human Dimensions Research Unit

. 1993. Sports Fishing Survey. Wisconsin Division of Health and University of Wisconsin-Madison, Water Chemistry Program.

3512A:PCCOM92.WS1

A-26 ENVIRON ATTACHMENT A

Sheboygan Fish Consumption Survey IDNUMBER: SHEBOYGAN FISH CONSUMPTION

My name is . I'm conducting a study of fish consumption in Sheboygan. All families that participate in the study will receive $20.00 for their time. I have just a few questions that will take 10-15 minutes to answer. Can you participate in the study? I will pay you the $20.00 as soon as we finish the interview.

HMONG TRANSLATION:

If you are directly asked about the study, you may provide the following information:)

(My name is . I am a student at UWGB. I'm conducting the interviews during our spring vacation) HMONG TRANSLATION:

Sampling Information from the telephone directory:

Respondent Name:

Respondent Address:

Phone Number:

Att-A-1 SHEBOYGAN FISH CONSUMPTION

HH-1. How long have you lived in Sheboygan?

HH-2. What year did you come to the United States?

HH-3. What other cities have you lived in?

HH-4. How many persons are their in your family?

HH-5. Please tell me their age and name (if you don't want to give the name, can you just tell me if they are male or female?

1. age name gender 2. '

3.

4.

5.

6.

7. 8.

HH-6. Does anyone else live in the house with you?

no yes

IF YES: Please tell me their age and name (if you don't want to give the name, can you just tell me if they are male or female? 1. age name gender 2.

3.

4.

Att-A-2 Sheboviian Fish Consumption -- March 1994

FA-1. How often does your family eat fish at home?

never two-three times a week once a month almost every day once a week every day

FA-2. Do you buy this fish in a store?

yes—purchase fish from store no—do not purchase fish from store

What store do you usually buy the fish from?

Hmong store Grocery Store Seafood store or stand

FA-3. Does anyone in your household like to catch fish/go fishing?

No: Go to FA-7 on following page. Yes: Continue with questions FA-4 thru FA-6

Who in your family usually goes fishing?

PROBE: Does anyone else go with them?

FA-4. How often do they go fishing?

once a month two-three times a week once a week almost every day every day

FA-5. Where do you/your husband go fishing?

Sheboygan Harbor Sheboygan River: below Sheboygan Falls Sheboygan River: above Sheboygan Falls Other: Probe: Are there any other areas?

Att-A-3 Sheboygan Fish Consumption -- March 1994

FA-6. What type of fish do you/your husband catch when you/he go fishing?

Smallmouth bass Steelhead trout Coho Salmon Carp Other:

Bass: Do you know what kind? _ Trout: Do you know what kind?

We also would like to know how often/frequently your family eats fish during different times of the year.

FA-7. Could you tell me how often/frequently you your family eats fish during the summer months (June through August)?

never two-three times a week once a month almost every day once a week every day

FA-8. How often/frequently does your family eat fish during the Fall months (September through November)?

never two-three times a week once a month almost every day once a week every day

FA-9. How often/frequently does your family eat fish during the Winter months (December through February)?

never two-three times a week once a month almost every day once a week every day

FA-10. How often/frequently does your family eat fish during the Spring months (March through May)?

never two-three times a week once a month almost every day once a week every day

Att-A-4 Sheboygan Fish Consumption — March 1994

Smallmouth Bass segment: Show respondent card with photograph of smaJlmouth bass.

SB-1. Have you ever caught this type of fish? (Has your husband ever caught this type of fish?)

no not sure DF NO: Go to ST-1 on following page. yes IF YES: Ask the following questions:

SB-2. Where do you usually go to catch this type of fish?

Sheboygan River: below Sheboygan Falls Sheboygan Harbor Sheboygan River: above Sheboygan Falls Other:

SB-3. How frequently do you go fishing for this type of fish?

SB-4. Have you ever eaten this type of fish after you have caught it?

no IF NO: Go to ST-1 on following page. yes IF YES: Ask the following questions:

SB-5. How often do you eat this type of fish after you have caught it?

once a month two-three times a week once a week almost every day every day

SB-6. How do you usually cook this type of fish? (PROBE for additional response)

boiled in stew baked in oven broiled in oven fried in pan Other:

SB-7. How do you prepare this fish for cooking?

skin is removed fat from top and sides is removed other: (PROBE):

SB-8. Here are photographs of several serving sizes of this fish. Which of these photographs best reflects the serving size you usually eat at a meal?

1/3 Pound 1/2 Pound 1 Pound

Att-A-5 Sheboygan Fish Consumption -- March 1994

Steelhead Trout segment: Show respondent card with photograph of steelhead trout.

ST-1. Have you ever caught this type of fish?

no not sure IF NO: Go to CS-1 on following page. yes EF YES: Ask the following questions:

ST-2. Where do you usually go to catch this type of fish?

Sheboygan River: below Sheboygan Falls Sheboygan Harbor Sheboygan River: above Sheboygan Falls Other:

ST-3. How frequently do you go fishing for this type of fish?

ST-4. Have you ever eaten this type of fish after you have caught it?

no EF NO: Go to CS-1 on following page. yes IF YES: Ask the following questions:

ST-5. How often do you eat this type of fish after you have caught it?

once a month two-three times a week once a week almost every day every day

ST-6. How do you usually cook this type of fish?

boiled in stew baked in oven broiled in oven fried in pan Other:

ST-7. How do you prepare this fish for cooking?

skin is removed fat from top and sides is removed other: (PROBE):

ST-8. Here are photographs of several serving sizes of this fish. Which of these photographs best reflects the serving size you usually eat at a meal?

1/3 Pound 1/2 Pound 1 Pound

Att-A-6 Sheboygan Fish Consumption -- March 1994

Coho Salmon segment: Show respondent card with photograph of Coho Salmon.

CS-l. Have you ever caught this type of fish?

no not sure EF NO: Go to CP-1 on following page. yes DF YES: Ask the following questions:

CS-2. Where do you usually go to catch this type of fish?

Sheboygan River: below Sheboygan Falls Sheboygan Harbor Sheboygan River: above Sheboygan Falls Other:

CS-3. How frequently do you go fishing for this type of fish?

CS-4. Have you ever eaten this type of fish after you have caught it?

no IF NO: Go to CP-1 on following page. yes IF YES: Ask the following questions:

CS-5. How often do you eat this type of fish after you have caught it?

once a month two-three times a week once a week almost every day every day

CS-6. How do you usually cook this type of fish?

boiled in stew baked in oven broiled in oven fried in pan Other:

CS-7. How do you prepare this fish for cooking?

skin is removed fat from top and sides is removed other: (PROBE):

CS-8. Here are photographs of several serving sizes of this fish. Which of these photographs best reflects the serving size you usually eat at a meal?

1/3 Pound 1/2 Pound 1 Pound

Att-A-7 Sheboygan Fish Consumption -- March 1994

Carp segment: Show respondent card with photograph of Carp.

CP-1. Have you ever caught this type of" fish?

no not sure IF NO: FINISH INTERVIEW yes IF YES: Ask the following questions:

CP-2. Where do you usually go to catch this type of fish?

Sheboygan River: below Sheboygan Falls Sheboygan Harbor Sheboygan River: above Sheboygan Falls Other:

CP-3. How frequently do you go fishing for this type of fish?

CP-4. Have you ever eaten this type of fish after you have caught it?

no IF NO: FINISH INTERVIEW. yes IF YES: Ask the following questions:

CP-5. How often do you eat this type of fish after you have caught it?

once a month two-three times a week once a week almost every day every day

CP-6. How do you usually cook this type of fish?

boiled in stew baked in oven broiled in oven fried in pan Other:

CP-7. How do you prepare this fish for cooking?

skin is removed fat from top and sides is removed other: (PROBE):

ST-8. Here are photographs of several serving sizes of this fish. Which of these photographs best reflects the serving size you usually eat at a meal?

1/3 Pound 1/2 Pound 1 Pound

Att-A-8 SUPPLEMENT TO SPORT FISHING SURVEY REFER TO FOR QUESTION #3

1/3 POUND SERVING

1/2 POUND SERVING Att-A-9 Smallmouth Bass

1/3 POUND SERVING

1/2 POUND SERVING

Alt-A-10 1/3 POUND SERVING

r

1/2 POUND SERVING

Alt-A-11 APPENDIX B

Fish Consumption Survey for the Sheboygan River, Sheboygan County, Wisconsin Fall 1993 INTRODUCTION

At the request of Tecumseh Products Company, Mead & Hunt, Inc., in conjunction with Fishery Information Management Systems, Inc. (FIMS, Auburn, Alabama), conducted a fish consumption survey on the Sheboygan River, Wisconsin. This survey is complemented by a similar study conducted during the spring of 1994. It is believed that collecting data during both the fall and spring spawning periods will produce a more complete understanding of the anglers' fishing and fish consumption habits.

Study Area

The Sheboygan River originates approximately nine miles southeast of Fond du Lac, Wisconsin, and flows approximately 61 miles east, where it empties into Lake Michigan at the City of Sheboygan. This study concentrated on the lower 13.6 miles of the river between Sheboygan Falls and Lake Michigan, including the lake breakwater area (Figure B-l). This reach of the river is characterized by a sinuous channel configuration. Macrophytes were scarce during the majority of the study. There are three "roller" dams within the study reach. Although these dams allow fish to pass downstream, they restrict any upstream fish movement during much of the year.

B-l ENVIRON a^1000. 2000 Scale in Meters

AREA 1 1o - JAYCEE RIVER WALKWAY 2o - ROCHESTER PARK AREA 2 Jo - RIVER BEND DAM - WAELDERHAUS DAW AREA 3 40 - WAELDERHAUS OAK - GOLF CART BRIDGE So - WAYSIDE - CTH TA 60 - KIWANIS PARK AREA 4 7o - SOUTH BREAKWATER MINOR 3TES AREA 1 1b - ACROSS FROM UTILITY BUILDING AREA 3 2b - GOLF CART BRIDGE - WEEDENS CREEK 3b - 1-43 - CTH PP INTERSECTION 4b - NEW JERSEY AVENUE BRIDGE Sto - Bth STREET BRIDGE 6b - PARK AREA 4 7b - NORTH BREAKWATER

Figure SHEBOYGAN RIVER AND HARBOR SURVEY SITES B-1 METHODS

Survey Design

Spatially, the study area was divided into an upper stratum (I) and a lower stratum (II). Each stratum was further divided into two areas. Stratum I included Area 1 (Sheboygan Falls to River Bend Dam) and Area 2 (River Bend Dam to Waelderhaus Dam). Stratum n included Area 3 (Waelderhaus Dam to Sheboygan Harbor) and Area 4 (the north and south breakwaters at the mouth of the Sheboygan River). The study was conducted for the 5-week period from October 11 to November 14, 1993 (Table B-l in Attachment B). During the survey weeks (Saturday - Friday), surveys ^_ were conducted on all 10 weekend days and 60%, or 15 of the 25 weekdays. Surveys were taken over a 10-hour period on the randomly chosen days. However, in some cases ..) it was necessary for the creel clerk to remain at the site for more than 10 hours to

*4» maximize the number of complete trip interviews. ; Historically, Stratum n (the section of the Sheboygan River downstream of -j Waelderhaus Dam) has received the greatest fishing pressure. Therefore, 70% and 30% - I of the sampling effort were expended in Strata n and I, respectively. As described above, each spatial stratum contained two sample areas. Each 10-hour »-» day was divided into two 5-hour sampling periods, an a.m. and p.m. period. On the randomly chosen days in either spatial stratum, both areas were sampled by randomly - . allocating one area to the a.m. time period and the other to the p.m. time period. Survey sites were chosen based on two criteria-access and fishing pressure. Access '_ was defined in two ways: direct, such as a park or boat ramp, and indirect, such as a bridge crossing or path from a road. Fishing pressure was qualitatively determined '_, through pre-study observations and discussions with anglers. The survey sites were then divided into major and minor sites. In general, major sites, which would receive the greatest amount of sampling effort, were usually sites where there was direct access and high fishing pressure. Minor sites were usually the opposite. There were seven major sites: two in Area 1, one in Area 2, three in Area 3, and one in Area 4. In addition, there were seven minor sites: one in Area 1, five in Area 3, and one in Area 4. Since ••

B-3 ENVIRON Area 3 was the longest and had the most access points, it contained the greatest number of major and minor survey sites. Area 2, with only one access point, contained the least number of survey sites.

Field Procedures

Anglers were intercepted and interviewed upon completion of their fishing trip at major or minor survey sites. In a small number of cases it was necessary for the clerk to conduct incomplete trip interviews to maximize the number of interviews obtained. An incomplete interview is defined as an interview conducted prior to completion of the angler's fishing trip. In this study, incomplete trip interviews accounted for 18% of the total number of interviews taken. Data from complete interviews as well as incomplete interviews were included in the results. No limit was established as to the length of time the creel clerk could stay at a particular survey site. However, the creel clerk was encouraged to investigate regularly other sites (every 30 - 45 minutes) to assess any future site-to-site moves. Major site locations were generally occupied by the clerk longer than one hour (minor sites were normally checked more briefly). The creel clerk was instructed to question the anglers in the same manner each time to maintain consistency throughout the study. In addition, the clerk was instructed not to inadvertently answer the question for the angler. If the question was not understood the first time, it was asked again. If the angler continued not to understand the question, it was explained in more detail For some questions, it was appropriate to give the angler a range of potential answers. Upon the completion of an interview, the angler was given an index card with the word "creel" and a three-digit number printed on it. This reduced the chances of repeat interviews on a given day and allowed the creel clerk to individualize each angler.

B-4 ENVIRON RESULTS

The study was conducted for 25 days over 5 consecutive weeks between October 11 and November 14, 1993 (Table B-l in Attachment B). During the study 70% of the sampling effort was expended in Stratum n. There were 63 complete trip interviews and 14 incomplete trip interviews recorded during the course of the study. Of the 77 interviews taken, 58 (75%) occurred during the first two weeks of the study (October 11 - October 24). The following results are presented as percents, means and/or ranges of angler responses to the questions on the survey form (Attachment B). The raw data as well as the survey question codes are presented in Tables B-2 - B-8 in Attachment B.

B-5 ENVIRON Fishing Location and Conditions Data

The creel clerk was instructed to note the sampling site for each interview (Table B-l) and the weather condition at the time of the interview (Table B-2).

TABLE B-l Number of Interviews Per Sampling Site #of %of Site Area* Interviews Interviews Jaycee River Walkway 1 0 0 Across from Utility Building 1 0 0 Rochester Park 1 3 4 River Bend Dam - Waelderhaus Dam 2 0 0 Waelderhaus Dam - Golf Can Bridge 3 42 55 Wayside - CTH TA 3 15 19 Kiwanis Park 3 0 0 North Breakwater 4 2 3 South Breakwater 4 15 19 Totals 77 100 Note: •Area 1 extends from Sheboygan Falls Dam to River Bend Dam; Area 2 extends from River Bend Dam to Waelderhaus Dam; Area 3 extends from Waelderhaus Dam to Sheboygan Harbor; Area 4 is Sheboygan Harbor.

• 96% of the interviews were taken in Stratum n.

B-6 ENVIRON TABLE B-2 Weather Conditions at the Time of the Interviews Weather Condition # of Interviews % of Interviews Clear and Windy 28 36 Clear and Calm 8 10 Cloudy, Windy, and Rain 0 0 Cloudy and Windy 41 53 Cloudy, Calm, and Rain 0 0 Cloudy and Calm 0 0 Totals 77 99

It appears fishing pressure is negatively correlated with precipitation.

B-7 ENVIRON Fish Consumption-Related Data

Question 1: Have you kept any fish that you have caught today? Of those anglers who gave a positive response, the following species were documented (Table B-3):

TABLE B-3 Species Possessed by Anglers at the Time of the Interview #of % of All Average Length (cm) Average Weight (g) Species Fish Fish (range) (range) Chinook Salmon 8 40 87 7,900 (75-101) (4,000-13,000) Brown Trout 5 25 59 2,200 (52-63) (2,000-2,500) Brook Trout 3 15 31 300 (29-33) (265-360) Stedhead Trout 3 15 71 4,000 (66-75) (3,500-4,500) Smallmouth Bass 1 5 39 280

• 14 (18%) of the anglers interviewed had fish in their possession at the time of the interview. • 20 fish were examined for an average of 1.5 fish/angler (range: 1-5). • 17 (85%) of the fish were to be consumed • The creel survey was not designed to document catch-and-release practices of anglers.

Question 2A: Do you typically eat the fish that you catch from this location?

• 39 (51%) of the anglers interviewed typically eat the fish they catch from the Sheboygan River. Of the 39 anglers offering positive responses to this question, 3 were interviewed in Area 1, 0 were in Area 2, 22 were in Area 3 and 15 were interviewed in Area 4.

Question 2B: If you do not eat the fish, why don't you eat the fish that you catch from this location?

B-8 ENVIRON The 38 anglers that do not eat fish from the river cite the following reasons which are summarized in Table B-4, below:

TABLE B-4 Reasons for Not Eating Fish % of the #of Subset of Respondents Respondents Who Do Not Who Do Not Reasons for not Eating Fish Eat Fish Eat Fish Think fish are contaminated 19 50 Practice catch and release angling 15 40 Do not like the taste of fish 2 5 1 Do not like to eat fish 2 5 • The majority of the catch and release anglers were interviewed at Waelderhaus Dam.

Question 2C: What do you do with the fish that you catch but do not intend to eat? The anglers response to this question can be summarized as follows:

• Of the 38 anglers that do not eat the fish, 28 (74%) release the unwanted fish, 8 (21%) give the unwanted fish to friends or relatives and 2 (5%) use the fish as bait

Question 3A: Have you caught enough fish today for a family meal?

• Of the 14 anglers that said they would consume the fish they possessed, 100% said they had enough fish for what they considered to be a family meal.

Questions 4A-4C: How many other people typically eat meals with you in your household? How many of you are adults? How many are children? What are the ages of the children? The anglers response to these questions can be summarized as follows:

B-9 ENVIRON • An average of 3 persons would participate in a meal of fish caught from the Sheboygan River. Of those participants, 85% are adults and 15% are children.

• The average age of the children participating in meals of fish was 12 years old (range: 5-16).

Question 5A: How do you typically cook fish that you harvest here?

• The primary method of preparation (the first answer given) of the 39 anglers that consume fish caught in the Sheboygan River is summarized in Table B-5, below:

TABLE B-5 Fish Preparation Methods Cooking Method TOTAL *<* «of Cleaning Method Grill Smoke Bake Fry Broil Can Boil Responses Responses Gut only ------Gut, scale and cut head 2 9 1 - - - - 12 31 off -.- I Gut, remove skin, fins 1 ------1 3 and head Gut, steak or chunk 2 2 - - - - - 4 10 Gut, fillet w/ rib bones 1 2 1 1 1 - - 7 15 Gut, fillet w/o rib bones - 6 4 3 - 3 - 16 41 Totals # of Responses 6 19 6 4 1 3 - 39 % of Responses 15 49 15 10 3 8 - 100

• Smoking accounted for 49% of the angler's primary method of cooking their fish (either salmon or trout). • 56% of the anglers said they primarily fillet their fish and all respondents gut the fish.

B-10 ENVIRON Questions 5B - 5E: Do you usually trim the fat from the fish before cooking it? Do you usually trim and discard any dark flesh from the fish? Do you usually eat the livers of the fish you harvest here? Do you usually eat the roe (eggs) of the fish you harvest here? The anglers responses to these questions can be summarized as follows:

• 34 (87%) of the anglers trim the fat from the fish before cooking and 28 (72%) trim the dark flesh.

• 100% of the anglers do not eat the livers of fish and almost all (97%) do not eat the •• roe of fish.

Question 6: A serving of fish consists of approximately 4 ounces. This would be about the size of the palm of your hand How many servings of fish do you usually eat per ] meal?

• The average amount of fish consumed/meal was 7.5 ounces (range: < 0.5-20). i • 85% of the anglers consume less than 8 ounces/meal i

Demographic Data \

Question 7: What state, county and town do you live in? The percentage of anglers f~ from each state, county and town can be summarized as follows:

• 70% of the anglers were from Wisconsin, 40% were from Sheboygan County and 32% were from the City of Sheboygan.

Question 8: How long have you been fishing today?

• The average length of tune expended for a complete fishing trip was 33 hours (range: 0.5-10.5)

B-ll ENVIRON • Anglers at Waelderhaus Dam spent an average of 4.6 hours fishing, whereas the combined average of the other sites was 1.8 hours.

Question 9: Which category of race are you in? The categories were Afro-American, Asian-American, Euro-American, Hispanic-American and Native-American.

• 99% of the 77 anglers sampled were of European descent and 1% were of Hispanic descent.

Question 10; What age group are you in? The age groups were less than 20 years, 20 to 29 years, 30 to 39 years, 40 to 49 years, 50 to 59 years and more than 60 years old. The number of anglers and percentage of anglers in each age group are summarized in Table B-6: TABLE B-6 Age of Anglers Age Class #of %of (years-old) Respondents Respondents < 20 6 8 20-29 8 10 30-39 24 31 40-49 14 18 50-59 7 9 > 60 18 23 Totals 77 99

Historical Data

Question 11; How many days did you fish at the specific areas last year? The number of days the anglers spent fishing in each area and the number of angler responses when

B-12 ENVIRON asked the amount of time they spend fishing in each area temporally are summarized by area and season in Table B-7, below:

TABLE B-7 Fishing Activity Grouped by Area and Season Area 1 Area 2 Area 3 Area 4 Sheboygan Falls to River Bend Dam to Waelderhaus Dam to Sheboygan Harbor River Bend Dam Waelderhaus Dam Sheboygan Harbor Responses SP Su F W SP So F W Sp Su F W Sp Su F W Don't know ------1 - 1 1 1 1 Daily 3 2 2 - 2 2 2 - 3 2 4 - 10 10 12 - 2-4x/week - 1 ------10 5 13 3 4 3 3 1 Ix/week ------3 - 3 1 4 1 2-3x/month ------2 2 9 1 1 1 3 - Iz/month ------1 2 7 - 1 1 2 1 Less often - 1 1 - - - - - 1 - - 1 - - - - Ix/season ------1 ------2x/season ------1 - - - - - 3x/scason ------4x/season ------5x/season ------1 - - - - Totals 3 4 3 0 2 2 2 0 18 11 38 6 20 17 25 4

• Sp = spring, Su = summer, F = fall, W = winter, and x = times. • Historically, it appears Areas 3 and 4 receive the greatest amount of fishing pressure. This was borne out by the survey data here.

Question 12: During the past year have you or any family member eaten any fish that were caught in these areas? Table B-8 summarizes the anglers' responses to this question by number of fish meals in the past year and by species.

B-13 ENVIRON TABLE B-8 Fish Consumption by Area Areal AreaS Sheboygan Falls to Waelderhaus Dam to Area 4 River Bend Dun Sheboygan Harbor Sheboygan Harbor Average #of Average #of Average #of Total* Fish Species (range) Anglers (range) Anglers (range) Anglers of Anglers Steelhead Trout - - 3.0 8 3.0 10 18 (1-5) (1-7) Brook Trout ------0

Brown Trout - - 5.5 10 5.0 13 23 (1-5) (1-20) Salmon - - 3.1 13 5.9 11 24 (1-8) (1-10) Smallmouth Bass 1.0 1 - - - - 1 (1) Panfish - - - - 12.0 1 1 (12) Northern Pike - - - - 1 1 1 (1) Muskellunge ------0 Walleye 23 3 - - - - 3 (1-4) Carp ------0 Suckers ------0 Totals 4 31 36 71

Question 13: How many meals have you eaten over the past month with fish that you've caught here?

• The 3 anglers that responded averaged 1.3 meals in the past month (range 1-2).

B-14 ENVIRON ATTACHMENT B

Fish Consumption Questionnaire and Response Summary Tables, Fall 1993 Fish Consumption Survey

I am conducting a fresh water fish consumption survey. May I take a few minutes of your time to ask some questions about the fish that you catch here?

Date and Location

Month Day Year System Interview # Time:

Weather Conditions:

Fish Consumption Related Questions

1. Have you kept any fish that you have caught today? (Circle refpoace) Yes No

2A. Do you typically eat fish that you catch from this location? (OKtoMponK) Yes No : then

BFNOTO#1& 2B. Why? (Code: ). YESTO#2A 2C. What do you do with them? GOTO QUESTIONS #4A (Code: ) GO TO QUESTION #2C only if #2B is answered contaminated, otherwise go Question #8

3A. Have you caught enough fish today for a family meal? (Circle ropowe) Yes No : then

3B. How many more fish like the ones you've caught do you need to make a meal? (cater (he number of iddibo«lfUiBe«tod).

GO TO THE NEXT QUESTION

4A. How many other people typically eat meals with you in your household?

(eater umber of peopk mrbrting the interviewee)

4B. How many of you are adults? How many are children?

4C. What are the ages of the children?

5A. How do you typically cook fish that you harvest here? (Code: )

Att B-l ENVIRON (Code: ) (Code: ) (Code: )

5B. Do you usually trim the fat before cooking? YES NO

5C. Do you usually trim and discard any dark flesh? YES NO

5D. Do you usually eat the livers of the fish you harvest here? YES NO

5E. Do you usually eat the roe (eggs) of the fish you harvest YES NO here?

6. A serving of fish consists of approximately 4 ounces. This would be about the size of the palm of your hand. How many servings of fish do you usually eat per meal?

Demographics

7. What State , County , and Town do you live in?

8. How long have you been fishing today?

9. Race:

10. Age of Angler: <«*«* •n*of>ri*>

<20 20-29 30-39 40-49 50-59 >60

THIS IS THE END OF THE SHORT FORM (Measure any fish harvested)

Alt B-2 ENVIRON Historical Information

11. How many days did you fish at the specific areas last year? Spring Summer Fall Winter Area 1 Area 2 Codes Area3 Area 4

12. During the past year have you or any family member eaten any fish that were caught in these areas?

# of Fish Meals/Year #of Species People Eating River Steelbcad SnaUmouth Other Section a Fish •Yes No Trout Carp Bass Sackers Parish SalmoB Meal Area 1 Area 2 Area3 Area 4

13. How many meals have you eaten over the past month with fish that you've caught here? Area 1 Area 2 Area 3 Area 4

Att B-3 ENVIRON All fish are to be identified, measured, and weighed. Ask the angler to indicate which fish will be consumed the next time fish are eaten for a family meal and how the fish will be cleaned (show angler the fish cleaning method chart).

Weight To be Consumed Cleaning Species Number Length (cm) (grams) Yes No Method

Cleaning Method: Enter the method (A-F) in first space; whether the skin is left on (O) of off (F) in the second space; and whether the belly fat is removed (R) or not (N) in the third space.

AttB-4 ENVIRON TABLE B-l Study Random Sampling Schedule Time Date Day Stratum Period Area October 11 Mon II AM,PM 3,4 October 13 Wed n AM,PM 3,4 October 14 Thu I AM,PM 2,1 October 16 Sat n AM,PM 4,3 October 17 Sun I AM.PM 2,1 October 19 Tue n AM,PM 3,4 October 21 Thu n AM.PM 3,4 October 22 Fri i AM.PM L_ 1»2 October 23 Sat n AM,PM 4,3 October 24 Sun i AM.PM U October 27 Wed n AM,PM 3,4 October 28 Thu i AM.PM W October 29 Fri i AM,PM U October 30 Sat n AM.PM 43 October 31 Sun i AM.PM 1,2 November 02 Tue i AMJ»M 2,1 November 03 Wed n AM.PM 43 November 05 Fri i AM,PM 1,2 November 06 Sat n AM,PM 3,4 November 07 Sun n AM.PM 4,3 November 08 Mon i AM.PM 1,2 November 09 Tue n AM,PM 3,4 November 10 Wed n AM,PM 4,3 November 13 Sat n AM,PM 3,4 November 14 Sun i AM,PM 2,1

Att B-5 ENVIRON TABLE B-2 Survey Question Codes YES OR NO QUESTIONS QUESTION 5A (A, - A,) 1 Yes 1 Grill 2 No 2 Smoke 3 Bake SYSTEM CODES 4 Fry 1 Rochester Park, Sheboygan Falls 5 Broil 2 Riverbend Dam -Waelderhaus Dam 6 Can 3 Waelderhaus Dam -Weedens Creek 7 Steam 4 Wayside -Taylor Road 8 Boil 5 Kiwanis Park, Sheboygan 6 North Breakwater QUESTION 5A (Pi - PJ 7 South Breakwater 1 Whole, gut only 2 Gut, scale, head off WEATHER CONDITIONS 3 Gut, skin, fins off, head off 1 Clear, windy 4 Steak or chunk 2 Clear, calm 5 Fillet w/o rib bones 3 Cloudy, windy, precipitation 6 Fillet w/ rib bones 4 Cloudy, windy 5 Cloudy, calm, precipitation QUESTION 11 6 Cloudy, calm « Don'v^ _ tt. knoi ._ w 2-4 times per week QUESTION 2B Once per week 1 Think fish are contaminated 2-3 times per month 2 Don't like the taste Once per month 3 Don't like to eat fish Less often (specify) 4 Catch and release angler Daily

QUESTION 2C FISH SPECIES CODES (LENGTH AND 1 Release fish WEIGHT SHEET) 2 Give fish to friends or relatives 1 Steelhead (Rainbow trout) 3 Kill or discard fish 2 Carp 4 Feed it to pets or other animals 3 SmaUmouth bass 5 Use as bait 4 Suckers 5 Panfish 6 Chinook salmon 7 Coho salmon 8 Brown trout 9 Brook trout

Att B-6 ENVIRON APPENDIX C

Fish Consumption Survey for the Sheboygan River, Sheboygan County, Wisconsin Spring 1994 INTRODUCTION

At the request of Tecumseh Products Company, Mead & Hunt, Inc., in conjunction with Fishery Information Management Systems, Inc. (FIMS, Auburn, Alabama), conducted a fish consumption survey on the Sheboygan River, Wisconsin. This survey complements a similar study conducted during the fall of 1993. In addition, it was believed that collecting data during both the spring and fall spawning periods would produce a more complete understanding of anglers' fish consumption habits.

Study Area

The Sheboygan River originates approximately nine miles southeast of Fond du Lac, Wisconsin, and flows approximately 61 miles east, where it empties into Lake Michigan at the city of Sheboygan. This study concentrated on the lower 13.6 miles of the river between Sheboygan Falls and Lake Michigan, including the lake breakwater area (Figure C-l). This reach of the river is characterized by a sinuous channel configuration. Macrophytes were scarce during the majority of the study. However, during late May and early June anglers were hindered by an increase in the amount of filamentous algae. There are three "roller" dams within the study reach. Although these dams allow fish to pass downstream, they restrict any upstream fish movement during much of the year.

C-l ENVIRON 1000 2000

Scole in Meters

AREA 1 10 - JAYCEE RIVER WALKWAY 2o - ROCHESTER PARK AREA 2 So - RIVER BEND DAM - WAELDERHAUS DAM AREA 3 4o - WAELDERHAUS DAM - GOLF CART BRIDGE 5o - WAYSIDE - CTH TA Go - KIWANIS PARK AREA 4 7o - SOUTH BREAKWATER UIMOP gits AREA 1 10 - ACROSS FROM UTILITr BUILDING AREA 3 2b - COLF CART BRIDGE - WEEDENS CREEK Jb - 1-43 _ CTH PP INTERSECTION «b - NEW JERSEY AVENUE BRIDGE Sb - 8th STREET BRIDGE 6b - PARK AREA 4 76 - NORTH BREAKWATER

Figure SHEBOYGAN RIVER AND HARBOR SURVEY SITES C-1 METHODS

Survey Design

Spatially, the study area was divided into an upper stratum (I) and a lower stratum (II). Each stratum was further divided into two areas. Stratum I included Area 1 (Sheboygan Falls to River Bend Dam) and Area 2 (River Bend Dam to Waelderhaus Dam). Stratum n included Area 3 (Waelderhaus Dam to Sheboygan Harbor) and Area 4 (the north and south breakwaters at the mouth of the Sheboygan River). The study was conducted during five alternating weeks over a 10-week period from April 9 - June 10, 1994 (Table C-l in Attachment C). During the survey weeks (Saturday - Friday), surveys were conducted on all 10 weekend days and 60%, or 15 of the 25 weekdays. Surveys were taken over a 12-hour period on the randomly chosen days. However, in some cases it was necessary for the creel clerk to remain at the site for more than 12 hours to maximize the number of complete trip interviews. Historically, Stratum n has received the greatest fishing pressure. Therefore, 60% and 40% of the sampling effort were expended in Strata n and I, respectively. As described above, each spatial stratum contained two sample areas. Each 12-hour day was divided into two 6-hour sampling periods, an ajn. and p.m. period. On the randomly chosen days in either spatial stratum, both areas were sampled by randomly allocating one area to the a.m. time period and the other to the p.m. time period. Survey sites were chosen based on two criteria-access and fishing pressure. Access was defined in two ways: direct, such as a park or boat ramp, and indirect, such as a bridge crossing or path from a road. Fishing pressure was qualitatively determined through pre-study observations and discussions with anglers. The survey sites were then divided into major and minor sites. In general, major sites, which would receive the greatest amount of sampling effort, were usually sites where there was direct access and high fishing pressure. Minor sites were usually the opposite. There were seven major sites: two in Area 1, one in Area 2, three in Area 3, and one in Area 4. In addition, there were seven minor sites: one in Area 1, five in Area 3, and one in Area 4. Since Area 3 was the longest and had the most access points, it contained the greatest number

C-3 ENVIRON RESULTS

There were 147 complete trip interviews and three incomplete trip interviews recorded during the course of the study. Of the 150 interviews taken, 96 (64%) occurred during the first and second weeks of the study (April 9-April 15; April 23-April 29). The following results are presented as percents, means and/or ranges of angler responses to the questions on the survey form (Attachment C). The raw data as well as the survey question codes are presented in Tables C-2 - C-7 in Attachment C.

Fishing Location and Conditions Data

The creel clerk was instructed to note the sampling site for each interview (Table C-l) and the weather conditions at the time of the interview (Table C-2).

TABLE C-l Number of Interviews Per Sampling Site

Site Am* # of Interviews % of Uterrtews Jayccc River Walkway 1 1 1 Across from Utility Building 1 2 1 Rochester Park 1 3 2 River Bend Dam - Waelderhaus Dam 2 3 2 Waelderhaus Dam - Golf Cart Bridge 3 38 25 Wayside - CTH TA 3 25 17 KrwanisPark 3 7 5 North Breakwater 4 5 3 South Breakwater 4 66 44

Totals 150 101

Note: * Area 1 extends from Sheboygan Falls Dam to River Bend Dam; Area 2 extends from River Bend Dam to Waelderhaus Dam; Area 3 extends from Waelderhaus Dam to Sheboygan Harbor; Area 4 is Sheboygan Harbor.

• 94% of the interviews were taken in Stratum II.

C-5 ENVIRON TABLE C-2 Weather Conditions at the Time of the Interviews #of #of Weather Condition Interviews Interviews Clear and Windy 45 30 Clear and Calm 49 33 Cloudy, Windy, and Rain 3 2 Cloudy and Windy 40 27 Cloudy, Calm, and Rain 0 0 Cloudy and Calm 13 9 Totals 150 101

It appears fishing pressure is negatively correlated with precipitation.

C-6 ENVIRON Fish Consumption-Related Data

Question 1: Have you kept any fish that you caught today? Of those anglers who gave a positive response, the following species were documented (Table C-3):

TABLE C-3 Species Possessed by Anglers at the Time of the Interview

#of %of All Average Length (cm) Average Weight (g) Species Fish Fish (range) (range) Brook Trout 31 48.4 27 262 (22-31) (158-382) Steelhead Trout 14 21.9 69 2,400 (38-90) (1,000-6,000) Brown Trout 12 18.8 56 2,100 (48-66) (1,500-4,000) Smallmouth Bass 3 4.7 - - Burbot 1 1.6 66 1,800 Carp 1 1.6 75 5,800 Channel Catfish 1 1.6 54 1,600 Suckers 1 1.6 32 500 Note: •The smaUmouth bass were not measured because the angler refused the creel clerk's request

28 (19%) of the anglers interviewed had fish in their possession at the time of the interview. 64 fish were examined for an average of 23 fish/angler (range: 1-6). 62 (97%) of the fish were to be consumed. Given the size and abundance of the brook trout, and the fact that they are a fall spawning fish, it is probable that this species was stocked during the spring of 1994. The survey was not designed to document catch-and-release practices of the anglers.

C-7 ENVIRON Question 2A: Do you typically eat fish that you catch from this location?

• 106 (71%) of the anglers interviewed typically eat the fish they catch from the Sheboygan River.

Question 2B: If you do not eat the fish, why don't you eat the fish from this location?

• The 44 anglers that do not eat fish from the river cite the following reasons which are summarized in Table C-4 below:

TABLE C-4 Reason for Not Eating Fish # of Respondents % of the Subset of Who Do Not Eat Respondents Who Reason for Not Eating Fish Fish Do Not Eat Fish Practice catch and release angling 22 50 Think fish are contaminated 12 27 Do not like to eat fish 6 14 Do not like the taste of fish 4 9

• The majority of the catch and release anglers were interviewed at Waelderhaus Dam.

Question 2C: What do you do with the fish that you catch but do not intend to eat?

• Of the 44 anglers that do not eat the fish, 38 (86%) release the unwanted fish and 6 (14%) give the unwanted fish to friends or relatives.

Question 2D: If the fish were not contaminated, what would you do with them? The anglers' responses to this question can be summarized as follows:

C-8 ENVIRON • Of the 12 anglers that did not eat the fish because they were contaminated, 10 (83%) would eat the fish and 2 (17%) would release the fish even if they were not contaminated. Of the 10 anglers who would eat fish which were not contaminated, 2 were interviewed in Area 1, 0 were in Area 2, 7 were hi Area 3 and 1 was interviewed in Area 4.

Question 3A: Have you caught enough fish today for a family meal?

• Of the 26 anglers that said they would consume the fish they possessed, 16 (61%) said they had enough fish for what they considered to be a family meal.

Question 3B: How many more fish like the ones you've caught do you need to make a meal?

• Of the 10 anglers that said they did not possess enough fish for a family meal, the mean number of fish needed was 2.6 more fish (range: 2-10).

Questions 4A-4C: How many other people typically eat meals with you in your household? How many of you are adults? How many are children? What are the ages of the children? The anglers responses to these questions can be summarized as follows:

• An average of 3 persons would participate in a meal of fish caught from the Sheboygan River. Of those participants, 79% are adults and 21% are children.

• The average age of the children participating in meals of fish was 10 years old (range: 1-17).

C-9 ENVIRON Question 5A: How do you typically cook fish that you harvest here?

• The primary method of preparation (the first answer given) of the 106 anglers that consume fish caught in the Sheboygan River is summarized in Table C-5:

TABLE C-5 Fish Preparation Methods

Cooking Method Totals

#of %of Cleaning Method Grill Smoke Bake Fry Broil Can Boll Responses Responses

Gut only 2 16 1 0 0 0 0 19 18 Gut, scale and cut head off 3 2 1 3 3 0 1 13 12 Gut, remove skin, fins and 1 0 0 1 0 0 0 2 2 head Gut, steak or chunk 0 5 0 6 0 3 1 15 14 Gut, fillet w/ rib bones 2 2 1 2 0 0 0 7 7 Gut, fillet w/o rib bones 9 10 7 22 1 1 0 50 47

Totals

* of Responses 17 35 10 34 4 4 2 106 % of Responses 16 33 9 32 4 4 2 100

• Smoking and frying accounted for 65% of the angler's primary method of cooking the fish (either salmon or trout). • 54% of the anglers said they primarily fillet their fish and all respondents gut the fish.

Questions 5B - 5E: Do you usually trim the fat before cooking? Do you usually trim and discard any dark flesh? Do you usually eat the livers of the fish you harvest here? Do you usually eat the roe (eggs) of the fish you harvest here? The anglers responses to these questions can be summarized as follows:

C-10 ENVIRON • 93 (88%) of the anglers trim the fat from the fish before cooking and 65 (61%) trim the dark flesh.

• 105 (99%) of the anglers do not eat the livers of fish and nearly all (98%) do not eat the roe of fish.

Question 6: A serving of fish consists of approximately 4 ounces. This would be about the size of the palm of your hand. How many servings of fish do you usually eat per meal?

• The average amount of fish consumed/meal was 9.3 ounces (range: 2-32). Note that one response (120 ounces) was considered as an outlier and therefore was not included in the mean. • 69% of the anglers consumed between 4 and 8 ounces/meal

Demographic Data

I Question 7: What state, county and town do you live in ? The percentage of anglers from each state, county and town can be summarized as follows:

• 89% of the anglers were from Wisconsin, 69% were from Sheboygan County and 53% were from the City of Sheboygan.

Question 8: How long have you been fishing today?

• The average length of time expended for a complete fishing trip was 2.5 hours (range 0.3-14) • Anglers at Waelderhaus Dam generally spent a longer time fishing (complete trip) than anglers at other sites.

C-ll ENVIRON Question 9: Which category of race are you in? The categories were Afro-American, Asian-American, Euro-American, Hispanic-American and Native-American.

• 96% of the 150 anglers sampled were of European descent, 2% were of Asian descent and 2% were of Hispanic descent

Question 10: What age group are you in? The age groups were less then 20 years, 20 to 29 years, 30 to 39 years, 40 to 49 years, 50 to 59 years and more then 60 years old. The number of anglers and percentage of anglers in each age group are summarized in Table C-6:

TABLE C-6 Age of Anglers Age Class #of %of (years-old) Respondents Respondents < 20 21 14 20-29 26 17 30-39 27 18 40-49 32 21 50-59 10 7 > 60 34 23 Totals 150 100

C-12 ENVIRON Historical Data

Question 11: How many days did you fish at the specific areas last year? The number of days the angler spent fishing in each area and the number of angler responses when asked the amount of time they spend fishing in each area temporally are summarized in Table C-7, below:

TABLE C-7 Fishing Activity Grouped by Area and Season Anal Area 2 Area 3 Sheboygan Falls to River Bend Dam to Wadderhaus Dam to Area 4 River Bend Dam Waelderhans Dam Sheboygan Harbor Sheboygan Harbor Responses Sp Sn F w Sp Sn F W Sp Sn F W Sp Su F W Don't know ------Daily ------8 5 6 - 11 12 10 - 2-4i/wcck 6 7 3 - 2 3 2 - 11 11 15 - 21 20 12 - Is/week 4 4 5 - 2 2 3 - 14 8 15 - 17 14 18 2 2-3x/month 1 - 2 - 1 - 1 - 16 9 9 1 7 10 9 - Ix/month ------14 8 9 - 7 6 5 1 Less often ------Ix/season ------3 2 2 1 5 1 3 - 2x/season - - - - 1 - - - 3 2 2 - - - - 1 3x/season ------4x/season 1 ------5z/season - - - - - 1 - - 1 ------Totals 12 11 10 0 6 6 6 0 70 45 58 2 68 63 57 4

• Sp = spring, Su = summer, F = fall, W = winter, and x = times. • Areas 3 and 4 receive the greatest amount of fishing pressure.

Question 12: During the past year have you or any family member eaten fish that were caught in these areas? Table C-8 summarizes the anglers response to this question by number of fish meals in the past year and by species.

C-13 ENVIRON TABLE C-8 Fish Consumption by Area Area 1 Area 3 Sheboygan Falls to Wadderhaus Dam to Area 4 River Bend Dam Sheboygan Harbor Sheboygan Harbor Average #of Average #of Average #of Total* Fish Species (range) Anglers (range) Anglers (range) Anglers of Anglers Steelhead Trout - - 9.5 23 4.0 18 41 (1-60) (1-10) Brook Trout - - 8.1 9 8.0 1 10 (1-20) (8) Brown Trout - - 8.6 18 12.9 40 58 (1-50) (1-104) Salmon - - 5.8 13 7.6 25 38 (1-52) (1-25) Smallmouth 4.5 2 3.0 3 2.0 2 7 Bass (4-5) (1-4) (2) Panfish 4.0 2 L8 4 75.4 7 13 (2-6) (1-3) (3-400) Northern pike - - - - 14.5 2 2 (4-25) MuskeDunge 1.0 1 - - - - 1 Walleye - - 3.0 1 1.0 2 3 (1) Carp - - 3.8 4 - - 4 (1-6) Suckers - - 2.0 2 - - 2 (1-3) Totals 5 77 97 179 Note:

The total number of anglers exceeds 150 due to cumulative responses.

C-14 ENVIRON Question 13: How many meals have you eaten over the past month with fish that you've caught here? The number of meals eaten over the past month are summarized by area in Table C-9.

TABLE C-9 Meals Eaten Within the Past Month River Section Average # of Meals # of Anglers Area 1 1.7 3 (1-2) Area 3 2.0 13 (1-5) Area 4 2.3 17 (1-4)

C-15 ENVIRON ATTACHMENT C

Fish Consumption Questionnaire and Response Summary Tables, Spring 1994 Fish Consumption Survey

I am conducting a fresh water fish consumption survey. May I take a few minutes of your time to ask some questions about the fish that you catch here?

Date and Location

Month Day Year System Interview # Time:

Weather Conditions:

Fish Consumption Related Questions

1. Have you kept any fish that you have caught today? (Ckck recponfe) Yes No 2A. Do you typically eat fish that you catch from this location? (Cfccle fopooce) Yes No: then

IF NO TO #1 & 2B. Why? (Code: ), YES TO #2A 2C What do you do with them? GOTO QUESTIONS #4A (Code: ) GO TO QUESTION #2D only if #2B is answered contaminated, otherwise go Question #8 2D. If the fish were not contaminated, what would you do with them? (Code: ) 3A. Have you caught enough fish today for a family meal? (Circle ncpooK) Yes No : then

3B. How many more fish like the ones you've caught do you need to make a meal? (tttta fee number of adOrnd bh needed).

GO TO THE NEXT QUESTION

4A. How many other people typically eat meals with you in your household?

(eater manlier of people irtirtmg (he interviewee)

4B. How many of you are adults? How many are children?

4C. What are the ages of the children?

Alt C-l ENVIRON 5A. How do you typically cook fish that you harvest here? (Code: ) (Code: ) (Code: ) (Code: )

5B. Do you usually trim the fat before cooking? YES NO

5C. Do you usually trim and discard any dark flesh? YES NO

5D. Do you usually eat the livers of the fish you harvest here? YES NO

5E. Do you usually eat the roe (eggs) of the fish you harvest here? YES NO

6. A serving of fish consists of approximately 4 ounces. This would be about the size of the palm of your hand. How many servings of fish do you usually eat per meal?

Demographics

7. What State , County , and Town do you live in?

8. How long have you been fishing today?

9. Race: (Ck«*iWwpri-.e««fct7) (B) Afro-American (H) Hispanic-American (A) Asian-American (N) Native-American (C) Euro-American

10. Age of Angler: (check *I«OI*M> <**&)

<20 20-29 30-39 40-49 50-59 >60

THIS IS THE END OF THE SHORT FORM (Measure any fish harvested)

Att C-2 ENVIRON Historical Information

11. How many days did you fish at the specific areas last year? Spring Summer Fall Winter Area 1 Area 2 - Codes Area 3 Area 4

12. During the past year have you or any family member eaten any fish that were caught in these areas?

# of Fish Meals/Year Species # of People River Stodhead Snullimrath Other EatiBga Yes No Section Trout Carp Bui Sucker* Panfisa Salmon FbhMcal Area 1 Area 2 AreaS Area 4

13. How many meals have you eaten over the past month with fish that you've caught here?

Area 1 Area 2 Area 3 Area 4

Att C-3 ENVIRON All fish are to be identified, measured, and weighed. Ask the angler to indicate which fish will be consumed the next time fish are eaten for a family meal and how the fish will be cleaned (show angler the fish cleaning method chart).

To be Weight Consumed Cleaning Species Number Length (cm) (grams) Yes No Method

Cleaning Method: Enter the method (A-F) in first space; whether the skin is left on (O) of off (F) in the second space; and whether the belfyfat is removed (R) or not (N) in the third space.

AttC-4 ENVIRON TABLE C-l Study Random Sampling Schedule

Time Date Day Stratum Period Area

April 09 Sat I AM.PM 1,2 April 10 Sun II AM4>M 43 April 12 Tue I AM.PM 1,2 April 14 Thu n AM.PM 3,4 April 15 Fri n AMJ>M 3,4 April 23 Sat ii AM^PM 43 April 24 Sun n AMJ>M 4,3 April 25 Mon i AM4»M 2,1 April 28 Thu i A\tPM 2,1 April 29 Fri n AM,PM 43 MayOT Sat n AM^M 3,4 May 08 Sun i AM^M 1£ May 09 Mon n AM^M 3,4 May 11 Wed n AM.PM 43 May 13 Fri i AM.PM 1^ May 21 Sat n AMJ>M 43 May 22 Sun i AM^»M 1^ May 24 Tue i AM.PM 2,1 May 25 Wed n AM4»M 43 May 26 Thu n AM4»M 43 June 04 Sat i AM^M 1,2 June 05 Sun n AM.PM 3,4 June 06 Mon n AM^M 3,4 June 07 Tue n AM^M 43 June 10 Fri i AM.PM 1,2

Att C-5 ENVIRON TABLE C-2 Survey Question Codes YES OR NO QUESTIONS QUESTION SA (A, - A,) 1 Yes 1 Grill 2 No 2 Smoke 3 Bake SYSTEM CODES 4 Fry 1 Rochester Park, Shcboygan Falls 5 Broil 2 Utility Bldg., Sheboygan Falls 6 Can 3 Riverbend Dam -Waclderhaus Dam 7 Steam 4 Waelderhaus Dam -Weedens Creek 8 Boil 5 Wayside -Taylor Road 6 Kiwanis Park, Sheboygan QUESTION 5A (P, - P«) 7 North Breakwater 1 Whole, gut only 8 South Breakwater 2 Gut, scale, head off 9 Jaycee River Walkway, Sheboygan Falls 3 Gut, skin, fins off, head off 4 Steak or chunk WEATHER CONDITIONS 5 Fillet w/o rib bones 1 Clear, windy 6 Fillet w/ rib bones 2 Clear, calm 3 Cloudy, windy, precipitation QUESTION 11 4 Cloudy, windy 1 Don't know 5 Cloudy, calm, precipitation 2 2-4 times per week 6 Cloudy, calm 3 Once per week 4 2-3 times per month QUESTION 2B 5 Once per month 1 Think fish are contaminated 6 Less often (specify) 2 Don't like the taste 7 Daily 3 Don't tike to eat fish 4 Catch and release angler FISH SPECIES CODES (LENGTH AND WEIGHT SHEET) QUESTION 2C 1 Stcelhead (Rainbow trout) 1 Release fish 2 Carp 2 Give fish to friends or relatives 3 Smallmouth bass 3 Kul or discard fish 4 Suckers 4 Feed it to pets or other animals 5 Panfish 5 Use as bait 6 Chinook salmon 7 Coho salmon QUESTION 2D 8 Brown trout 1 Eat 9 Brook trout 2 Release 10 Burbot 3 Give away 11 Channel catfish < 4 Kill 5 Feed to pets 6 Use as bait

Att C-6 ENVIRON APPENDIX D Monte Carlo Simulation MONTE CARLO SIMULATION

A. Justification for Use in Risk Assessment According to USEPA guidance for public health risk assessment, "intake variable values for a given pathway should be selected so that the combination of all intake variables results in an estimate of the reasonable maximum exposure (RME) for that pathway" (USEPA 1989). Even "high-end" risk estimates must not exceed the value one would expect for the ^ person subject to reasonable marimiim exposures. This means that when constructing this estimate from a set of factors, not all factors should be set to values that maximize exposure J or dose, since this will lead to an estimate that is much too conservative (USEPA 1992a). i If one were to multiply numerous individual reasonable maximum values for exposure variables, the product of these variables would produce an estimate of risk that is extreme , and highly improbable. For example, if three exposure variables are required to estimate i risk and a value for each of these variables is selected at the 95th percentile of its respective -; distribution, the probability that the overall risk will be less than or equal to the calculated value is 99.9%, based on the following equation:

Y P. - I-(I-P)11 = 1-(1-0.95)3

P. = 0.999

where:

P0 = overall probability p = cumulative probability of individual value n = number of variables

D-l ENVIRON In other words, the probability that the actual risk is greater than this value is only 0.1%. Since more than three variables are typically required to estimate risk, the probability of occurrence of the calculated risk is much less than 0.1%. This is counter to sound science and USEPA exposure guidance (USEPA 1992a) on developing RME risks that are between the 90th percentile and 98th percentile of risk for a population. Furthermore, if a risk estimate were to use reasonable maximum levels for each variable, typical sensitivity analyses (recalculation using ±25 or ±50% of the individual exposure values) would be precluded, because many of the input variables are already at or close to the mayimiiTn, The use of only upper-bound values is problematic when the resulting risk is above a threshold defined as de minimis risk as there is no way to interpret an assessment when the risks are above this threshold. In a recent memorandum, USEPA has placed increased emphasis on presentation of "a full and complete picture of risk" (USEPA 1992b). Specifically, the Agency stated that:

"Regarding exposure and risk characterization, it is Agency policy to present information on the range of exposures derived from exposure scenarios and on the use of multiple risk descriptors (Le., central tendency, high end of individual risk, population risk, important subgroups, if known)."

In recent guidance for exposure assessment, assessing uncertainty was considered to be an integral and invaluable portion of the exposure assessment (USEPA 1992a), as it is believed to assist the risk manager in making decisions. Specifically, the guidance states, "Exposure assessors have a responsibility to present not just numbers but also a clear and explicit explanation of the implications and limitations of their analyses. Uncertainty characterization helps carry out this responsibility" (USEPA 1992a). The guidance also states that if "sufficient information about the variability in lifestyles and other factors are available to simulate the distribution through the use of modeling, e.g., Monte Carlo simulation, the estimate from the simulated distribution may be used" (USEPA 1992b). Monte Carlo analysis is a technique that has been applied to numerous areas affected by random behavior. Monte Carlo analysis has been used in human health risk assessments. Monte Carlo analysis incorporates probability density functions or cumulative frequencies for each input variable in the risk formulas, as distinguished from single values to represent

D-2 ENVIRON input variables. In this process, variables from within these distributions are generated based on their probability (frequency of occurrence) and are combined at random with values from other distributions (for other exposure variables), selected on the same basis, to calculate risk. After these calculations are repeated several thousand times, the risk results can be presented as distributions that reflect the overall uncertainty in the input values.

B. Distributions Used in the Risk Assessment This section describes the distributions for the exposure assumptions used to estimate risk to hypothetical individuals potentially exposed to PCBs in fish caught in the Sheboygan River and PCBs in soils in the Sheboygan River floodplain. These descriptions of the distributions were derived from the user's manuals of commonly-utilized risk estimation software packages (Palisade 1990, 1994; TIA 1992).

1. Cumulative Distributions. A cumulative distribution is used to describe the probability of a value less than or equal to any variable

value. Points on the cumulative curve 10* are specified with increasing value •K 0%

and increasing probability. 4« Cumulative distributions were used to 2% OX 1 2 $ 4 estimate PCB concentrations in fish Chid E*x»ur» OwnBon (yMra) and in soil, exposure duration in both the fish and floodplain soil scenarios, and ingestion rate and child body weight in the floodplain soil exposure scenarios.

D-3 ENVIRON 2. Discrete Distributions A discrete distribution is used when there is a finite number of possible outcomes. Each possible outcome is weighted based upon the expected frequency of occurrence of ao% 4O% that outcome. Discrete distributions M% were used to estimate both meal size 20% and meal frequency in the fish 10% 0% ingestion scenario, since the raw data 0.4 O.i 1.0 were clumped (i.e., a number of anglers gave the same response). The statistics obtained from a discrete distribution best represented the raw data because the actual response frequency was retained.

3. Lognormal Distributions A lognormal distribution is widely used in situations where the data are positively skewed (i.e., most of the values occur near the minimum value) and is defined by the mean and standard deviation of the data. A lognormal distribution was used to estimate the adult body weight for the 0 40 10 120 1W 200 fish ingestion and both floodplain soil exposure scenarios.

D-4 ENVIRON 4. Triangular Distributions A triangular distribution generates a probability distribution based on the minimum, most likely and maximum expected values for a given set of data. The magnitude of the most likely value determines whether the triangular distribution is symmetrical 4W *K or skewed toward the high or low end. 2% Values near the minimum and 1% 0% maximum are less likely to occur than 10 20 *0 40 60 A** Benur* Fn+Mnoi*> Mfc those near the most likely value. A triangular distribution was used to estimate exposure frequency in both floodplain soil exposure scenarios, because detailed data regarding exposure frequency were lacking.

5. Uniform Distributions A uniform distribution is used in cases where the variable in question varies uniformly between two values or when only a range is known. Every value across the range of the uniform distribution is assigned an equal

0% likelihood of occurrence. Uniform 1000 2000 9000 WOO AduN Surtfm Am (en* ) distributions were used to estimate skin surface area, the soil-to-skin adherence factor and dermal absorption of Aroclors from the soil in the dermal contact with floodplain soil scenario.

D-5 ENVIRON REFERENCES

Palisade Corporation (Palisade). 1990. Risk analysis and simulation add-in for Lotus 1-2-3. Version 1.55. Newfield, NY: Palisade.

Palisade Corporation (Palisade). 1994. Risk analysis and simulation add-in for Microsoft Excel or Lotus 1-2-3. Release 3.0. Newfield, NY: Palisade.

Technical Information Associates, Inc. (TIA). 1992. Crystal Ball for Windows user's manual. Version 2. Boulder, CO: Decisioneering.

U.S. Environmental Protection Agency (USEPA). Office of Emergency and Remedial Response. 1989. Risk assessment guidance for Superfund. Volume I. Human health evaluation manual (Part A). Interim final EPA/540/1-89/002, Washington, D.C December.

U.S. Environmental Protection Agency (USEPA). 1992a. Guidelines for exposure assessment, Notice. Fed. Reg. 57:22888. May 29.

U.S. Environmental Protection Agency (USEPA). 1992b. Guidance on risk characterization for risk managers and risk assessors. Memorandum from F. Henry Habicht

J512A:PCC00692.W51

D-6 ENVIRON SHEBOYGAN RIVER SMALLMOUTH BASS POPULATION ESTIMATES

In conjunction with the Interim Monitoring Program (IMP) resident fish sampling activities in autumn 1994, numbers of legal-size smallmouth bass (Micropterus dolomieui) were recorded to estimate their population density and standing crop in two river reaches. These two reaches were the area between the Kohler Dams (from Waelderhaus dam upstream to River Bend dam) and the Rochester Park area (from River Bend dam upstream to the riffle adjacent to the CTF and the Tecumseh plant site). Total river areas of these reaches were estimated to be 15.1 and 11.5 acres, respectively. Because it was impractical to collect fish from the entire reach, subsections of each reach were sampled. Sampling areas within each reach were selected to contain habitat types that were representative of the habitat types present in the entire reach (i.e. pools and riffles). One subsection was sampled in the Kohler reach from the Waelderhaus dam upstream, covering an area of 8.1 acres. Two subsections of the Rochester Park reach were sampled: a 1.7-acre section (designated lower Rochester Park) adjacent to sediment Areas 16-19, and a 3.5-acre reach (designated upper Rochester Park) consisting of the section from Rochester Park upstream to the riffle adjacent to the CTF. During the collection activities, fish were captured using standard electrofishing techniques with both boat-mounted and streamside electrofishing units (depending on river characteristics). To prevent fish movement from the collection areas, block nets were placed across the upstream and downstream boundaries of each subsection prior to collection. When sampling upper Rochester Park, a block net also was set at the mouth of the Onion River to prevent fish from leaving the sampling area. With the block nets in place, two consecutive passes with electrofishing equipment were made in each sampling area. Numbers of smallmouth bass captured during each pass were recorded. By using approximately equal effort on the first and second pass, standard fisheries

E-l ENVIRON APPENDIX E

Sheboygan River Smallmouth Bass Population Estimates Based on these calculations and the assumption that the sample areas are representative of each reach, it was estimated that there are five legal-size smallmouth bass in the reach between the Kohler Dams, and 21 legal-size bass in the Rochester Park reach. These results are typical of what would be expected for a stream of this type with these habitat types and characteristics.

3J12A.PCC00692.WJ1

E-3 ENVIRON