Commonwealth of Massachusetts United States Western ...

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Commonwealth of Massachusetts Department of Environmental Protection Western Regional Office 436 Dwight Street Springfield, Massachusetts 01103 (413)784-1100

United States Environmerrral Protection Agency New England Region J.F. Kennedy Federal Building Boston. Massachusetts 02203 (617)565-3420

November 1, 1996

Ronald F. Desgroseilliers General Electric Company Area Environmental and Facility Operations 100 Woodlawn Avenue Pittsfield, Massachusetts 01201

Re: DEP: 1-0147 Pittsfield; EPA: Area 6; GE/Housatonic River; Ecological Work Plan comments and requirements for resubmittal

Dear Mr. Desgroseilliers:

The Massachusetts Department of Environmental Protection (DEP) and the United States Environmental Protection Agency (EPA) (the Agencies) have reviewed the following document:

Work Plan for the Ecological Risk Assessment of the Housatonic River Site (Work Plan), February 28, 1995, prepared by ChemRisk for the General Electric Company (GE).

Based on earlier correspondence from GE to the Agencies, the Agencies have reviewed the Work Plan as the environmental risk assessment portion of the Supplemental Health and Environmental Assessment Proposal (SHEAP) for the Housatonic River. The SHEAP is required by EPA's RCRA Corrective Action Permit's Special Permit Condition A. 7 and is intended to fulfill the requirements of DEP's and GE's Administrative Consent Order and the Massachusetts Contingency Plan (MCP).

In accordance with the Public Involvement Plan, notifications of this document being placed in the public repositories was sent to the parties on the notification mailing list at the tune of the submittal, along with notifications of how and to whom to submit comments during the public comment period.

Notwithstanding the determinations described below, the Agencies reserve the right to

require additional studies, sampling or analysis if new information indicates that such work is necessary to comply with the EPA RCRA Corrective Action Permit (the Permit), j

a!0n l-b

Mr. Ronald F. Desgroseillicrs November 1, 1996 Page 2

the Massachusetts Contingency Plan, the National Contingency Plan, or as otherwise appropriate.

Enclosed are the joint comments of the Agencies. The Agencies note that representatives from the following agencies contributed in developing the attached joint comments: Connecticut Department of Environmental Protection, U.S. Fish and Wildlife Service, U.S. Department of Interior, National Oceanic and Atmospheric Administration, and Massachusetts Division of Fisheries and Wildlife. Most of these governmental organizations are or represent Natural Resources Trustees and although they have reviewed the Work Plan and their preliminary concerns have been addressed, the Agencies note that the attached comments are only intended to provide GE with requirements for submittal of a revised SHEAP for an ecological risk assessment.

The Agencies also note that in preparing the attached comments, they have considered two sets of comments from the Housatonic River Initiative (HRI), prepared by Anne Marie C. Desmarais of Tufts University on behalf of HRI.

GE shall incorporate or address the attached comments in a revised SHEAP for ecological risk assessment and shall submit the revised SHEAP within 60 days of the date of this letter.

If you have any questions regarding these matters, please contact J. Lyn Cutler at (413) 784-1100 extension 316 or Bryan Olson at (617) 573-5747.

Sincerely,

Lyn Cutler Section Chief Special Projects Bureau of Waste Site Cleanup Massachusetts Department of

Environmental Protection

,_

Bryan Olson Environmental Engineer Corrective Action Section Office of Site Remediation and

Restoration U.S. EPA New England Region

Enclosure

cc: Andrew Silfer, GE John Ciampa, GE James R. Bieke, Esq., Shea & Gardner

Mr. Ronald F. Desgroseilliers November 1, 1996 Page 3

Robert Goldman, Blasland, Bouck & Lee Linda Murphy, EPA New England Region Matt Hoagland, EPA New England Region Douglas Luckennan, Esq., EPA New England, ORC Leo Pierre Roy, Undersecretary, EOEA Mary Holland, Regional Director, DEP WERO Alan Weinberg, Regional Engineer, DEP WERO Robert Bell, Esq., DEP OGC Stephen Winslow, Esq., DEP BWSC, Boston Margaret Harvey, DEP ORS Susan Steenstrup, DEP WERO Mayor Edward Reilly, City of Pittsfield Commissioner of Health, Pittsfield Pittsfield Conservation Commission Housatonic River Initiative State Senator Jane M. Swift State Representative Daniel E. Bosley State Representative Christopher J. Hodgkins State Representative Shaun P. Kelley State Representative Peter J. Larkin Public Information Repositories Charles Fredette, Connecticut DEP Robert Smith, Connecticut DEP John Looney, Esq., Conn. AG's Office Richard Webb, Esq., Conn. AG's Office Betsy Harper, Esq., Mass. AG's Office Ken Finkelstein, Ph.D., NOAA Anton P. Giedt, Esq., NOAA OGC Mark Barash, Esq., U.S. DOI Steve Gold, Esq., U.S. DOJ Addie Fiske, Esq., U.S. DOJ Kenneth Carr, Ph.D., U.S. F&WS Molly Sperduto, U.S. F&WS Dick Keller, MA DFW

Celeste Philbrick-Barr

Tom Decker, MA DFW

Traci Anne lott, CTDEP Carol Rowan West, DEP, ORS

Nancy Bettinger, DEP, ORS

Jane Rose, DEP, ORS Gary Gonyea, DEP

TECHNICAL AND REVIEW COMMENTS

of

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

and

MASSACHUSETTS DEPARTMENT of ENVIRONMENTAL PROTECTION

GENERAL ELECTRIC COMPANY

Pittsfield, Massachusetts

EPA I.D. MAD002084093, Area 6

MCPSiteNo.: 1-0147

WORK PLAN FOR THE ECOLOGICAL RISK ASSESSMENT

OF THE HOUSATONIC RIVER SITE

Submitted: February 28, 1995

I. GENERAL COMMENTS

1. The Work Plan represents a good first step toward development of a plan for evaluating risks to ecological receptors in the Housatonic River Valley caused by chemical releases from the General Electric facility. However, steps outlined in the Work Plan as currently written will not provide all of the information necessary to adequately characterize risks to the environment. The Work Plan needs substantial revision hi order for the U.S. Environmental Protection Agency and the Massachusetts Department of Environmental Protection (the Agencies) to consider it an acceptable Scope of Work for an ecological risk assessment. The specific revisions that the Agencies believe are necessary are detailed hi the Technical Comments Section.

2. It is the Agencies' understanding that GE will submit separate Scopes of Work for evaluating potential ecological risks in Silver Lake and other GE Pittsfield Disposal Sites.

3. The Work Plan focuses on PCBs as the principal chemical stressor of concern in the Housatonic River system. The risk assessment must evaluate the cumulative impacts from PCBs and other contaminants which have been found hi the River. If GE wants to exclude other contaminants from the risk assessment, it must provide adequate documentation hi the risk assessment to support such a decision. An example might be a determination that metals are present in the Housatonic River system at levels which are consistent with background.

4. GE must not limit the assessment to a retrospective approach (i.e. field studies attempting direct measurement of harmful effects) to evaluate potential ecological risks. The risk assessment must incorporate some predictive techniques in order to fully develop multiple lines of evidence. As previously communicated to GE, (meeting on August 18, 1994, to discuss the Aquatic and Terrestrial Ecology Documents prepared for GE by contractors) the Agencies expect GE to conduct predictive studies and to incorporate the results in the risk characterization. Results from predictive studies constitute important lines of evidence even for evaluating effects from historical contamination because field studies are not always sensitive enough to detect adverse changes that are biologically important against a background containing other interferences.

GE's basis for rejecting a predictive approach is that the level of uncertainty associated with predictive techniques is very high. There are uncertainties associated with both predictive and retrospective techniques, and consideration of uncertainties associated with different measurement approaches must be balanced. Uncertainties associated with field studies should not be underestimated. As noted in the Work Plan, an evaluation of uncertainties and of the weight of the evidence from different measurement approaches is typically conducted during risk characterization.

The Agencies believe that there are activities that GE can undertake that will help minimize the uncertainties inherent in predictive techniques. An example is the use of site-specific data to develop PCB bioaccumulation factors for specific species. Using site-specific bioaccumulation factors will help minimize extrapolation and uncertainties associated with some predictive techniques.

5. The Agencies have decided that results of predictive techniques are to be considered in the risk assessment as lines of evidence in the weight of evidence approach. It is not acceptable to the Agencies for GE to temper or reject the results of foodchain modeling which indicate potential risk, based on field smdy results which fail to find the same positive indication of risk.

6. GE must provide a detailed discussion of the statistical designs it intends to use in the proposed studies and how uncertainties will be evaluated. The Agencies note that discussions of statistical significance and power are very limited hi most of the previously conducted field work (ChemRisk, 1994; Chadwick, 1994). The revised Work Plan should specify that the risk assessment will provide a detailed discussion about the statistical significance and power associated with data proposed for use hi the risk assessment. Factors such as sample size and variability may limit the power and significance of an inferential statistical test. For studies that do not use formal statistics, the effect of these factors on the study must be evaluated.

7. GE has stated that the risk assessment will focus on the portions of the Housatonic River and floodplain where the highest PCB concentrations occur because it is in these areas that the most substantial PCB exposures to ecological receptors are expected. GE has defined these areas as "Study Areas." The Agencies agree that it makes sense to evaluate receptors that are exposed in portions of the river with the highest concentrations of PCBs. Such exposure estimates will provide a conservative estimate of the exposure received by those organisms. However, it does not necessarily follow that the absence of significant risk in the most contaminated portion of the river means an absence of significant risk in lesser contaminated areas of the river. Organisms with greater sensitivity to PCBs may experience significant risk in areas of lower contamination. Thus, it is inappropriate for GE to rule out the need to evaluate receptors simply because the receptors do not receive exposures in highly contaminated areas of the river. Rather, GE should determine whether receptors with greater sensitivity to PCBs are present in areas of lower contamination and, if so, should include such areas in the risk assessment. In the Technical Comments which follow, the Agencies have identified situations in which additional areas of the river and additional receptors must be considered by GE.

8. GE has not discussed how it intends to evaluate potential ecological risks in the Connecticut portion of the Housatonic River. The Work Plan must be revised to address what steps GE plans to take to adequately characterize potential risks to ecological receptors in Connecticut. Specific activities that the Agencies believe should be undertaken are discussed in the Technical Comments.

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