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Stephen Johnson, BWSC, NERO 4 MON\WEALTH OF MASSACHUSET L EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMFNT OF ENVIRONMENTAL PROTECTION ONE WINTER ! rREET. BOSToN. MA 02103 617-29. q00 Aki 'V 1 C TRI 'M )X DA vin STRCJH Commnissamn MEMORANDUM TO: Cynthia Weidner, BWSC, NERO Stephen Johnson, BWSC, NERO THROUCH: Carol Rowan West, ORS FR OM: Nancy Bertinger, ORS 46 Maureen Vallatini, ORS DATE: December 18, 1997 SUBJECT: Review and Comments on Draft Environmental R sk Characterizatzon W orkpan fOr the Pair Shop Pond Sie, Welesly, T A November 14, 1997 Background The Departmenm of Environmental Protection (the "Department") and Wellcsley College have been paruicipatig in facilitated discussions, regarding the Paint Shop Pond Site, for the last year. Recent discussions have focused on the environmental risk assessment whiich will be conducted at the site pursuant to 310 CMR 40,C995. Several drafts of the environmental risk assessment scope of work have been generated; the most recent version entitled the Draft Environmental Risk CharacteNzarion Workplan for the Paint Shop Pond Sire, Wellesl y, MA Nvember 14, 1997 (the "Workplan"). The Workplan was discussed at two facilitation meetings held on December 1, 1997 and DeLember 5, 1997. The comments and discussion provided below reflect the discussions held at those sessions. General Comments 1. The natural historv survey proposed to measure wildlife species composition and habitat use is essentially a qualitative survey. This survey is an important component of the risk assessment Ithat it will support the identification of potential receptors. The survey report should include the identification of any migratory bird species that are likely to use the available habitat. Owing to the natural temporal and spatial variability in the occurrence and distribution of wildlife, the results of the survey will not necessarily provide an accurate, independent DEP On de Wond WIde Web rritp '/w magnet scam,rn usdep n Prnbe-d: vri Recycled Papef m 9 2 measure of effects. Therefore, ORS would not recommend placing a high weight on the survey results in the risk characterization. 2. Table 1 lists concentrations of metals in fish, vascular plants, sediment, surface water as independent measurement endpoints. These data will provide measures or estimates of exposure only; none by itself is a measure of effects. Environmental media and biota concentrations must be evaluated with respect to published benchmarks or toxicity data in order to assess risk. 3. The Workplan identifies several situations which will consider the use of benchmark and/or literature values in the assessment. ORS does not recommend an unconditional approval of this approach, since the proposed values have not yet been identified. It was mutually agreed, at the December 5, 1997 meeting, that summary documents of toxicity data would be submitted as interim documents for Departmental review and approval. Lake Waban and Paint Shop Pond 4. The proposal specifies collecting one water and one sediment sample from each of 5 Lake Waban locations for the laboratory fish embryo toxicity tests, and placing a fish embryo exposure chamber at each of those locations for the field-based toxicity tests. This study is designed to include locations with a range of contaminant concentrations; it does not specify replication of tests at individual locations or at multiple locations with similar contaminant concentrations. The intent is to evaluate differences toxicity along a concentration gradient using regression analysis. ORS is concerned that the study will not be sufficiently sensitive to detect toxic effects that may occur at a specific concentration. In order to discern adverse effects, it may be necessary to conduct multiple tests at the same concentration (or at similar concentrations). ORS recommends revising the plan for sample collection and exposure chamber placement so that replicate tests will be conducted at individual location. Wellesley may opt to do replicate tests (and collect replicate samples) from different locations of similar contaminant concentrations, instead of from single locations. It is important to recognize, however, that this approach runs a greater risk of producing ambiguous results due to variability among sampling locations in chemical and physical factors other than the target contaminants that could affect the outcome. The necessary sample size should be determined using available information on variability in the effects to be measured. 5. The Workplan specifies that benthic community measurements will be conducted along a gradient of contamination. ORS recommends that the plan be revised to ensure a sufficient sample size is collected from a location (or group of locations) with high sediment contaminant concentrations so that an adverse effect on the benthic community, if present, would be detected. 3 The sample size should be determined by the biologically relevant mean difference in abundance and biomass and the natural variability in those parameters. The relevance to food supply adequacy of the proposed relative mean difference of 50% abundance should be documented. 6. The Workplan presents an example of how various combinations of results might be evaluated in a weight-of-evidence approach. ORS believes this is a very useful illustration of the process. The example presented, however, has not been evaluated for substantive comment. 7. The potential benefits of adding benthic invertebrate tissue analysis to the Workplan should be considered further. Tissue residue analysis could provide valuable data on exposures of fish, wildlife and benthic organisms. Wetlands 8. The assessment of the wetlands is proposed as a 2 step process. The discussion of the wetlands assessment includes a number of measurement endpoints. The Workplan should clearly state that for purposes of determining whether Step 2 is necessary, the focus in Step 1 of the process is on tissue concentration endpoints. 9. It would be helpful if the wetlands discussion identified which measurement endpoints will be evaluated qualitatively. 10. It was agreed at the December 5, 1997 meeting that a flowchart would be included to better illustrate the 2-step process for the wetlands assessment. 11. The wetlands assessment identifies in footnote 5 that additional work may be needed as part of the Phase III evaluation for the site. ORS feels that this discussion should be more detailed and identify for future reference that this additional Phase III work may include additional field work including, but not limited to, sample collection and analysis and toxicity testing. 12. Assessment Endpoint Wetland 3 is identified as Maintenance ofwelands and wetland function. The inclusion of this assessment endpoint should be clarified and more fully discussed. Terrestrial 13. The food chain model assessing wildlife exposures should include exposures associated with drinking water, in addition to incidental ingestion of soil and prey consumption. V 4V Risk Characterization and Development of Target Levels 14. Figure 4 describing the development of target levels was inadvertently left out of the report; pursuant to our discussions on December 1, 1997 it will be included in a revised Workplan. 15. ORS has not formally reviewed the approach described the paper attached in Appendix C entitled Two Wildlife Exposure Models to Assess Impacts at the Individual and Population Levels and the Efficiency of Remedial Actions. It was not apparent whether this approach was actually being proposed for use at the site, or was only being considered for possible future use. Given that the food chain model will be submitted at a later date for the Department's review, perhaps the development of target levels should be included in that submittal. AGENDA PROGRAM LAKE WABAN ANALYTICAL September 15, 1997 Wall Experiment Station LIMITS AND METHODS I. SELECTION OF DETECTION ON AVAILABLE LABORATORIES BASED II. SELECTION OF APPROPRIATE FUNDING FOR INTERNS III. SAMPLING PLAN TIMELINE/SCHEDULE IV. LOGISTICS AND EQUIPMENT' V. TRIAL RUN VI. 'CLEAN" SAMPLING TECHNIQUES -C 0 & C$ d) LO E _!n cu (n VD ev C0) x I U- e o0 c C: CO 00LLL cU 's < IL L..)E 115 -C In CU L et 010 OL C)U. 8K E 0 U)C' < 0 0 O CL U I- V) W - 0 Sheet2 Page 2 Required Methodology for Metals - Lake Wabin Asseoment Piosar I SEDIMENTS - METALS* HUMAN HEALTH Analyte Method Holding Acceptable Number Plan A* Plan A Plan B*"' Plan B Time Detection I (WES) (contract (WES) (contract Limit (mgl<.g) lab) 'lab) Pb 6010A 6 months 0.35 200 Cr (tot) 6010A 6 months 0.05 200 Cr (V) 3060A 40-200 Al 6010A 6 months 0.35 40 As 6010A 6 months 0.15 40 Ba 6010A 6 months 0 05 40 Cd 6010A 6 months 0.06 40 Cu 6010A 6 months 01 40 NI 6010A 6 months 0.15 40_ Se 6010A 6 months 0.5 40 Ag 6010A 6 months 0.05 40 Zn 6010A 6 mpjb, 0.05 40 CN (tot) 90108 (' months ) 5 40 PAC I 0.27 40 ECOLOGICAL (all samples also analyzed for grain size and SEMIAVS) Anatyte Method Holding Acceptable Number Plan A" Plan A Plan BI" Plan B Time Detection I (WES) (contract (WES) '(contract Limit (mg/kg) lab) Ilab) Pb 6010A 6 months 0.35 52 Cr (t) 6010A 6 months 0.05 Cr (VI) 3060A Al 6010A 6 months 0.35 As 1600A 6 months 0.15 Ba 601OA 6 months 0.05 Cd 6010A 6 months 0.05 Cu 6010A 6 months 0.1 Ni 6010A 6 months 0.15 Se 6010A 6 months 0.5 Ag 6010A 6 months 0.05 Zn 6010A 6 months 0.05 CN (tot) 90108 6 months 51 EXTENT Analyte Method Holding Acceptable Number Plan A** Plan A Plan B* Plan B Time Detection (WES) (contract (WES) (contract Limit (mg/kg) lab) Ilab) Pb 6010A 6 months 0.35 92 Cr (tot) 6010A 6 months 0,05 92 Cr (VI) 3060A 18-92 Al 6010A 6 months 0,35 18 As 6010A 6 months 0.15 18 Ba 6010A 6 months 0.05 1 16 Cd 6010A 6 months 0.05 16 Cu 6010A 6 months 0.1 18 Ni 6010A 6 months 0.15 18 So 601OA 6 months 0.5 16 Ag 601DA 6 months 0.05 18 Zn 6010A 6 months 0.05 18 ON (tot) 901DB 6 months 5 18 TOTAL SEDIMENT SAMPLES Program Requirements: All sediment samples will be analyzed for total chromium and total lead.
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