Stratus Consulting

Technical Analysis of Baseline Ecological Risk Assessment and Proposed Remedial Action Plan for Mercury in Onondaga Lake
Final Prepared for: The Onondaga Nation Nedrow, NY 13120

Prepared by: Stratus Consulting Inc. PO Box 4059 Boulder, CO 80306-4059 (303) 381-8000

Report Number 5-BD-***June 28, 2005

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Technical Analysis of Baseline Ecological Risk Assessment and Proposed Remedial Action Plan for Mercury in Onondaga Lake
Final

Prepared for: The Onondaga Nation Nedrow, NY 13120

Prepared by: Stratus Consulting Inc. PO Box 4059 Boulder, CO 80306-4059 (303) 381-8000

June 28, 2005

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Contents
List of Figures...............................................................................................................................v List of Tables ............................................................................................................................. vii List of Acronyms and Abbreviations ........................................................................................ix Executive Summary ................................................................................................................. S-1 Chapter 1 1.1 1.2 1.3 Chapter 2 2.1 2.2 2.3 2.4 2.5 2.6 Introduction...................................................................................................... 1-1 Background and Purpose of Report ................................................................... 1-1 Site Description and History.............................................................................. 1-2 Organization of Report ...................................................................................... 1-5 The Evaluation of Ecological Risks in Sediments is Not Sufficiently Protective...................................................................................... 2-1 The Evaluation of Sediment Toxicity Studies Excluded Important Data and Literature ............................................................................................ 2-2 The Methods Used to Develop SECs Include Only a Subset of Relevant Toxicity Metrics................................................................................................. 2-3 The Methods Used to Develop PECs Include Inappropriate SECs and Geometric Means Leading to Artificially High (Less Protective) PECs........... 2-5 The Methods Used to Develop PECQs Include Inappropriate Averaging, Likely Leading to Artificially Low (Less Protective) Average PECQs ................................................................................................. 2-7 Explanation for Why Risk Averaging to Develop Mean PECQs is Inappropriate .................................................................................................. 2-9 Additional Issues Related to the Calculation and Use of SECs, PECs, and PECQs ....................................................................................................... 2-10 2.6.1 Chronic toxicity ................................................................................... 2-10 2.6.2 Evaluation of surface sediments only .................................................. 2-11 2.6.3 Reference sites ..................................................................................... 2-12 The Evaluation of Bioaccumulation in Onondaga Lake Fish is Not Sufficiently Protective...................................................................................... 3-1 The Onondaga Lake Fish Community Has Been Degraded and Fish Are Unsafe to Eat because of Contamination ........................................................... 3-2 Mercury Moves throughout Onondaga Lake..................................................... 3-2 Evaluation of Surface Sediments, Only, Leads to Under-Protectiveness.......... 3-3
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Chapter 3 3.1 3.2 3.3

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Contents (Final, 6/28/2005)

3.4

3.5 3.6 Chapter 4 4.1 4.2 4.3 4.4 4.5 Chapter 5 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 Chapter 6

The Calculation of Biota-Sediment Accumulation Factors Includes Inappropriate Averaging and Extrapolations..................................................... 3-3 3.4.1 Problems with averaging contaminant concentrations in fish based on size alone........................................................................................... 3-4 3.4.2 Problems with extrapolation of fillet concentrations to whole body concentrations ............................................................................... 3-4 The Mercury BSQV is Based on Low Effect Levels Rather than No Effect Levels ...................................................................................................... 3-5 BSQVs Were Not Developed for Critical Bioaccumulative Substances Other than Mercury............................................................................................ 3-6 A More Thorough and Protective Risk Assessment Justifies More Dredging than the Preferred Alternative ...................................................... 4-1 The Remediation Objectives Are Elimination or Reduction of Potential Health and Environmental Impacts.................................................................... 4-1 PECQs Are Used to Evaluate Remedial Alternatives ....................................... 4-1 Summary of the Main Features of the Different Remediation Alternatives...... 4-2 Summary of the Preferred Remedy.................................................................... 4-3 The Preferred Remedy is Not Sufficient............................................................ 4-3 Residual Risk Calculations Must be Improved Before Remedial Alternatives Are Compared ............................................................................ 5-1 Reductions in Contaminant Loadings................................................................ 5-2 Aeration of Hypolimnion................................................................................... 5-2 Sediment Remediation ....................................................................................... 5-3 5.3.1 Effectiveness of isolation capping ......................................................... 5-3 Mercury Mass Balance ...................................................................................... 5-4 Chronic Toxicity ................................................................................................ 5-4 Uncertainty Analysis and Sensitivity Analysis.................................................. 5-5 5.6.1 Uncertainty analysis............................................................................... 5-5 5.6.2 Sensitivity analysis ................................................................................ 5-5 Failure to Consider All Potential Risk Drivers.................................................. 5-6 High Residual Levels of Numerous Chemicals ................................................. 5-6 Summary and Recommendations................................................................... 6-1

References.................................................................................................................................R-1

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Figures
1.1 2.1 2.2 Onondaga Lake eight sediment management units ....................................................... 1-4 Conceptual diagram illustrating conceptual groupings of sediment effects to thresholds adopted in the Onondaga Lake RI................................................................ 2-4 Maximum total mercury concentrations in 1992 in Onondaga Lake by depth ........... 2-11

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Tables
2.1 2.2 2.3 3.1 3.2 Site-specific sediment effect concentrations for mercury in Onondaga Lake based on 1992 acute toxicity data .................................................................................. 2-4 Site-specific sediment effect concentrations for mercury in Onondaga Lake based on 2000 chronic toxicity data .............................................................................. 2-5 SEC and PEC results for total mercury in Onondaga Lake sediments compared to the mercury PEC in MacDonald et al. (2000) ........................................................... 2-5 Mercury BSAFs calculated for Onondaga Lake............................................................ 3-4 Target fish tissue and sediment concentrations for mercury in Onondaga Lake expressed as NOAEL and LOAEL values for different ecological receptors as derived in the FS ............................................................................................................ 3-6 Comparison by the NYSDEC of the remedial alternatives presented in the PRAP ...... 4-4 Residual concentrations and hazard quotients left behind by the preferred alternative....................................................................................................... 4-5 Concentrations in Onondaga Lake fish of contaminants considered risk drivers and calculated target concentration to avoid risk .......................................................... 5-7

4.1 4.2 5.1

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Acronyms and Abbreviations

AET AVS BERA BSAF BSQV BTEX cm COC CPOI cy dw EEC ER-L ER-M FS HHRA km km2 ILWD LOAEL m MEC MNR apparent effects threshold acid-volatile sulfide Baseline Ecological Risk Assessment biota-sediment accumulation factors bioaccumulation-based sediment quality value benzene, toluene, ethylbenzene, and xylenes centimeter contaminants of concern chemical parameter of interest cubic yards dry weight extreme effect concentration effects range-low effects range-median Feasibility Study Human Health Risk Assessment kilometer square kilometer in-lake waste deposit lowest observed adverse effect level meter mid-range effect concentration monitored natural recovery

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Stratus Consulting

Acronyms and Abbreviations (Final, 6/28/2005)

NAPLs NCP NOAEL NYSDEC PAHs PCBs PCDDs PCDFs PECs PECQs PEL ppm PRAP RI ROD SCA SECs SEDQUAL SMUs SQGs TEC TEL TOC ww

non-aqueous phase liquids National Oil and Hazardous Substances Pollution Contingency Plan no observed adverse effect level New York State Department of Environmental Conservation polycyclic aromatic hydrocarbons polychlorinated biphenyls polychlorinated dibenzo-p-dioxins polychlorinated dibenzofurans probable effects concentrations PEC quotients probable effect level parts per million Proposed Remedial Action Plan Remedial Investigation record of decision sediment consolidation area sediment effects concentrations Sediment Quality Information System sediment management units sediment quality guidelines threshold effect concentration threshold effect level total organic carbon wet weight

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Executive Summary
Onondaga Lake in New York State is one of the most polluted lakes in the United States.1 Honeywell Inc., its predecessors (including AlliedSignal), and others discharged large volumes of contaminants, including mercury, polychlorinated biphenyls (PCBs), polycyclic aromatic hydrocarbons, dioxins, and other substances into the lake and its tributaries for over a century.2 The U.S. Environmental Protection Agency (EPA) has placed Onondaga Lake and certain adjacent areas on the National Priorities List as the Onondaga Lake Superfund Site, and the New York State Department of Environmental Conservation (NYSDEC) has taken the lead in developing a remedial plan for the Site. As part of this effort, NYSDEC released in November 2004 a Proposed Remedial Action Plan (PRAP) for the Onondaga Lake Bottom Sub-site of the Onondaga Lake Superfund Site. These comments on the PRAP are submitted on behalf of the Onondaga Nation, a federally recognized Indian nation. Based on our initial analysis of the PRAP,3 the preferred alternative is not sufficiently protective of human health and the environment. The PRAP is based on an inadequate assessment of the risks posed by the current contamination in Onondaga Lake. It also underestimates the risk that the public and the environment will still face after the proposed remedy is implemented. As set forth in these comments, many of the assumptions and analyses underlying the PRAP, taken together, may result in substantial underestimation of environmental risks. This leads to an inaccurate and inflated picture of the potential effectiveness of the proposed remedy. The most important issues are: The evaluation of ecological risks posed by contaminants in Onondaga Lake sediments underestimates those risks by: Failing to include important data and literature concerning toxicity Utilizing only a subset of relevant toxicity metrics

1. Onondaga Lake Partnership. 2005. Onondaga Lake Pollution. Available: http://www.onlakepartners.org/olpoll/index.cfm. Accessed June 27, 2005. 2. Parsons. 2004. Draft Final Onondaga Lake Feasibility Study Report, Onondaga County, New York. Prepared for Honeywell, Morristown, NJ. November. 3. NYSDEC. 2004. Proposed Plan: Onondaga Lake Bottom Subsite of the Onondaga Lake Superfund Site, Syracuse, New York. New York State Department of Environmental Conservation, Albany. November

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Executive Summary (Final, 6/28/2005)

Averaging risks between contaminants, thereby masking any high levels of risk posed by individual contaminants and likely resulting in artificially low risk calculations. The evaluation of bioaccumulation of contaminants in Onondaga Lake fish is not sufficiently protective because: The evaluation was too limited to surface sediments, not accounting for relevant high levels of contamination in deeper sediments, thereby leading to underestimation of risks The calculation of sediment-biota accumulation factors includes inappropriate averaging and extrapolations The target level for post-cleanup mercury concentrations is based on sediment toxicity only, not the more protective level based on bioaccumulation Bioaccumulation of other critical contaminants, including PCBs, hexachlorobenzene, and PCDD/PCDFs, all of which are proven to bioaccumulate, was not included in the analysis. The preferred remedy calls for dredging of some highly contaminated sediments, but leaves behind other highly contaminated sediments. Under the preferred alternative: benzene will be left at 1,387x of the purported safe level calculated by the PRAP; chlorobenzene 266x; dichlorobenzenes 377x; naphthalene 22,435x; xylenes 253x; ethylbenzene 9,403x; toluene 62,524x; and mercury 1,329x. These highly contaminated sediments are proposed for capping even though the dredging equipment will already be in place and functioning when these sediments are left behind under the preferred alternative. Furthermore, the justification for dredging instead of capping applies to these sediments as much as the other sediments that will be dredged under the preferred alternative. The residual contaminant levels left in place under the preferred remedy are themselves high enough to justify remedial action at most other sites. Capping, as described in the preferred alternative, will foreclose many opportunities to redesign, change, or improve the remedy if the cleanup does not eliminate risks as the PRAP assumes. The PRAP fails to identify real-life goals for the preferred remedy, such as when fish from Onondaga Lake will again be edible, or when it will be safe to swim in the lake again. Given the large number of calculations that underestimate risk, described throughout these comments, the PRAP should include a much better program for monitoring success and requiring remedial efforts to continue until success is reached,

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Executive Summary (Final, 6/28/2005)

particularly given the tremendous uncertainties of predicting long-term cap effectiveness. Furthermore, planning now to cease dredging operations while very high concentrations of contaminants remain just below the last dredge cut is a risky strategy that does not appear to be rooted in scientific analysis or good public policy. Based on this review, it is our opinion that the PRAP should be revised before a ROD is issued. As currently drafted, the PRAP contains risk calculations that include multiple levels of bias that fail to adequately protect human health and the environment. The comparison of alternatives that made Alternative 4 the preferred alternative is based on the biased risk assessment. Correcting the risk assessment will justify additional dredging and less reliance on capping than proposed by Alternative 4.

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1. Introduction
1.1 Background and Purpose of Report
The Onondaga Nation retained Stratus Consulting on April 15, 2005 to review key documents related to the cleanup of Onondaga Lake before the New York State Department of Environmental Conservation (NYSDEC) issues a record of decision (ROD) that will select a remedial alternative for Onondaga Lake proper. That ROD is currently scheduled for finalization on July 1, 2005, and submittal to the U.S. District Court for the Northern District of New York. This report provides technical analysis of, and comments on, the following key reports: Onondaga Lake Baseline Ecological Risk Assessment (BERA; TAMS, 2002a), Remedial Investigation (RI; TAMS, 2002c), Feasibility Study (FS; Parsons, 2004), and the Proposed Remedial Action Plan for addressing risks (NYSDEC, 2004). These documents were produced pursuant to a March 16, 1992 judicial consent decree (subsequently amended) between NYSDEC and Honeywell (formerly AlliedSignal). There has not been sufficient time to acquire and review many of the relevant documents produced by Honeywell or NYSDEC, including all of the documents for operable units or connected sites other than Onondaga Lake itself, all of the previous documents and comments for Onondaga Lake proper, and most of the underlying original data for the current Onondaga Lake RI, FS, BERA, Human Health Risk Assessment (HHRA; TAMS, 2002b), and Proposed Remedial Action Plan (PRAP). Furthermore, NYSDEC disapproved Honeywells 1998 and 2001 RI, BERA, and HHRA submittals (State of New York and Thomas C. Jorling v. Allied-Signal, Inc., 2002), creating a lengthy documentary history of data, reports, and comments, which is not currently available to Stratus Consulting. To ensure that our review of critical data and reports was completed before the July 1, 2005 ROD deadline, we have restricted this analysis to issues related to risk assessment, particularly ecological risk assessment, and more particularly emphasizing mercury risk assessment, as presented in the most recent RI, BERA, FS, and PRAP. We have not attempted to review the underlying data or literature, nor the previous documents and comments that led to the current versions of these documents. These comments should be viewed as an opening for discussions about critical issues related to the risk assessment, and required risk management at the site. Although we identify several technical issues of concern in the BERA, FS, and PRAP, we have focused most of our review on three primary issues of obvious, immediate importance in the BERA, FS, and PRAP:

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Stratus Consulting

Introduction (Final, 6/28/2005)

A series of evaluations led to cleanup numbers that were biased toward under-protection Selection of remedial alternatives was based on reliance on the biased cleanup numbers, as well as inappropriate reliance on capping, particularly of highly toxic sediments that could be dredged with equipment already in place, which will foreclose future options to test and improve the remedy Residual risk under the preferred alternative is underestimated.

1.2 Site Description and History

Onondaga Lake is a 12-square kilometer (km2) lake northwest of the city of Syracuse in central New York State (TAMS, 2002c). The lake is about 7.2 kilometer (km) long and 1.6 km wide, with an average water depth of 11 meters (m). The eastern shore of the lake is primarily urban and residential, while the northern shore is mostly parkland, wooded areas, and wetlands. The lake has two deep basins, a northern basin and a southern basin, with maximum depths of 19 and 20 m, respectively (TAMS, 2002c). A saddle region at a depth of about 17 m divides the two basins. Most of the lake has a broad nearshore shelf with depths less than 3.7 m. The two largest tributaries to the lake are Ninemile Creek and Onondaga Creek. In addition to tributaries to the lake, treated effluent from the Onondaga County Metropolitan Wastewater Treatment Plant provides about 19% of the water entering the lake. From 1884 to 1986, Allied Chemical and AlliedSignal (now Honeywell) operated chemical production facilities on the southwest side of the lake (TAMS, 2002c). These operations, collectively known as the Syracuse Works, used the regions natural salt brines and limestone to produce four major product lines: Soda ash and related products Benzene, toluene, ethylbenzene, and xylenes (collectively known as BTEX), and tar products from the recovery of coal distillation (coking) byproducts Chlorinated benzenes and the byproduct hydrochloric acid from the chlorination of benzene Chlor-alkali products (e.g., chlorine, caustic potash). The main releases of contaminants resulting from manufacturing processes were mercury, organic contaminants, and calcite-related contaminants (TAMS, 2002c). The main organic contaminant releases were of BTEX compounds; chlorinated benzenes; polycyclic aromatic hydrocarbons (PAHs), especially naphthalene; polychlorinated biphenyls (PCBs); and polychlorinated dibenzodioxins/polychlorinated dibenzofurans (PCDD/PCDFs). Mercury, mostly from chlor-alkali plants that used mercury in the production of chlorine and caustic soda, is the primary contaminant of concern (NYSDEC, 2004).

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Introduction (Final, 6/28/2005)

Onondaga Lake is a sink for contaminants. For every chemical parameter of interest (CPOI) examined, estimated loads of contaminants entering the lake are at least five times greater than loads leaving the lake (U.S. EPA, 2005). Manufacturing wastes were discharged from three plants to four main waste disposal sites: the Semet Residue Ponds, Geddes Brook and Ninemile Creek, the Solvay wastebeds, and directly into the lake (TAMS, 2002c). Wastes discharged directly to the lake through the East Flume tributary resulted in the formation of a large in-lake waste deposit (ILWD) that extends about 610 m into the lake and 1,219 m along the lakeshore. The ILWD contains waste up to 13.7 m thick (TAMS, 2002c). In 1992, Honeywell entered into a consent decree with the state of New York to conduct a RI and FS for Onondaga Lake. The RI was conducted by Honeywell from 1992 to 2000, with additional work by NYSDEC in 2001. Two drafts of the RI prepared by Honeywell were rejected on technical grounds by NYSDEC (State of New York and Thomas C. Jorling v. Allied-Signal, Inc., 2002). The final RI was completed by TAMS Consultants, Inc. with assistance from NYSDEC in December 2002 (TAMS, 2002c). The FS, completed in November 2004, evaluated a range of potential remedial technologies and alternatives to develop a recommended remedy for chemicals found to pose ecological or human health risks (Parsons, 2004). The FS divided Onondaga Lake into eight sediment management units (SMUs) based on location, water depth, contaminant type, and other physical characteristics (Parsons, 2004; see Figure 1.1). Sediment located above the lakes seasonal thermocline, which occurs at a depth of about 9 m during thermal stratification in summer, was defined as nearshore (littoral) sediment. Sediment below the thermocline was defined as profundal sediment (Parsons, 2004). These designations were made to distinguish between the epilimnion and hypolimnion, which have different biological, physical, and chemical processes. The epilimnion is the warm, upper layer of circulating water during summer stratification of the lake. The hypolimnion is the cooler, noncirculating water below the thermocline. Organic and inorganic solids from the epilimnion settle by gravity toward the lake bottom. Over the summer, biodegradation of the organic solids depletes the oxygen in the hypolimnion, sometimes creating depleted, hypoxic, or anoxic conditions. It is thought that the primary source of methylmercury to the water column is the methylation of mercury in the hypolimnion during summer when conditions in the hypolimnion are anoxic (NYSDEC, 2004).

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Introduction (Final, 6/28/2005)

SMU 5

SMU 8 N SMU 4 SMU 3 SMU 6

SMU 2

SMU 1

SMU 7 Harbor Brook

SOLVAY

Figure 1.1. Onondaga Lake eight sediment management units.

SMUs 1 through 7 include littoral areas that extend from the lakeshore to a depth of 9 m. These SMUs are: SMU 1: ILWD SMU 2: Causeway SMU 3: Wastebeds 1 through 8 SMU 4: Mouth of Ninemile Creek SMU 5: Northern Shore SMU 6: Ley Creek to 700 feet south of Onondaga Lake SMU 7: 700 feet south of Onondaga Creek to the ILWD. SMU 8, the Profundal area, encompasses the lake bottom in the deeper parts of the lake at depths greater than 9 m (Parsons, 2004).

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Introduction (Final, 6/28/2005)

1.3 Organization of Report

The remainder of this report is organized as follows: Chapter 2 reviews the sediment toxicity analysis Chapter 3 reviews the evaluation of the bioaccumulation of contaminants in fish Chapter 4 discusses proposed alternatives for remediation and the preferred remedy Chapter 5 discusses residual risks Chapter 6 presents a summary of major findings and recommendations for next steps.

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2. The Evaluation of Ecological Risks in Sediments is Not Sufficiently Protective

This chapter discusses methods used in the BERA (TAMS, 2002a), the RI (TAMS, 2002c), the FS (Parsons, 2004), and the PRAP (NYSDEC, 2004) to calculate ecological risks associated with direct toxicity to benthic organisms in lake sediments, which currently captures most of the risk calculations in the BERA and applies to sediment remedial decisions throughout Lake Onondaga. We would like to discuss with the response agencies whether we have accurately interpreted their evaluation of sediment toxicity and its use in risk calculations, before offering detailed comments on potential improvements to the methodologies, or incorporation of additional information from the literature. Based on our initial review of the documents listed above, our primary comments regarding the evaluation of sediment toxicity include: The evaluation of risk to benthic organisms was based only on acute toxicity in one sitespecific study. Additional site-specific data are available, however, including data on chronic toxicity. In addition, toxicity literature is available for many of the chemicals found in Lake Onondaga sediments. These additional sources of information should be used to derive robust PECs and PECQs that can be applied independently to lake sediments. This evaluation is likely to lead to a more protective risk assessment and remedial decisions. The methods used to develop PECs included sediment effects concentrations (SECs) that represent concentrations that always cause toxicity. This is inappropriate because protective thresholds like PECs should eliminate toxicity. Furthermore, PECs are based on an inappropriate series of geometric means of different SECs. Combined, these two problems lead to PECs that are numerically higher and less protective of human health and the environment. Rather than deriving PECs and PECQs for each chemical, based on all of the site-specific data and relevant literature, PECQs are averaged within and between chemical classes. This averaging likely reduces the protectiveness of the resultant average PECQs, and certainly obscures whether single chemicals are driving the true risk in any given sediment sample.

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Ecological Risks: Sediments (Final, 6/28/2005)

2.1 The Evaluation of Sediment Toxicity Studies Excluded Important Data and Literature
The overall objective of the Onondaga Lake sediment toxicity studies performed as part of the BERA was to evaluate the toxicity of surface sediments to sensitive and representative test species in relation to chemical concentrations and conventional sediment parameters, such as grain size distribution, total organic carbon (TOC), and acid-volatile sulfide (AVS) (TAMS, 2002a). Laboratory tests of sediment toxicity used the amphipod Hyalella azteca and the chironomid Chironomus tentans. The amphipod was selected to represent epibenthic macroinvertebrates and the chironomid was intended to be representative of infaunal macroinvertebrates. Laboratory tests involved exposure of lake sediments containing contaminants of concern (COC) to C. tentans and H. azteca, with subsequent observation of effects on growth and survival (TAMS, 2002a). In 1992, acute (short-term) sediment toxicity was evaluated at 79 sites in Onondaga Lake and at five sites in Otisco Lake, which was used as a reference lake (TAMS, 2002c). All sites sampled for toxicity testing in 1992 were at locations with a water depth shallower than 4.5 m. Sampling was conducted in July and August. Toxicity tests were conducted for 10 days. Toxicity results for 1992 from each station in Onondaga Lake were compared with only one site at the reference lake, Otisco Lake, based on sediment type. Paired comparisons were made statistically using the Sediment Quality Information System (SEDQUAL) program.1 Endpoints evaluated were growth (biomass) and survival for each of the species tested. Results indicated that chironomids were more sensitive than amphipods and that the chironomid survival endpoint was the most sensitive endpoint [significant lethality effects (p 0.05) were seen in 35 of the 79 stations]. Additional chronic sediment toxicity testing was then conducted at 15 locations in Onondaga Lake in 2000 (TAMS, 2002c). Forty-two day (42 d) chronic toxicity tests were conducted on samples collected from the top 15 centimeter (cm) of the sediment column. Toxicity endpoints were growth, survival, and reproduction for H. azteca and the chironomid C. tentans. All sites sampled in 2000 were at locations with a water depth shallower than 5 m. The same statistical methods were used to evaluate toxicity for the chronic tests as were used for the 1992 acute tests. As in 1992, the 2000 study found that chironomids were more sensitive than amphipods, and that
1. SEDQUAL is a computer program developed by the Washington State Department of Ecology that performs statistical comparisons among test, reference, and control samples for assessment of sediment toxicity.

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Ecological Risks: Sediments (Final, 6/28/2005)

the chironomid survival endpoint was more sensitive than growth or reproduction [significant lethal effects (p 0.05) were seen in 9 of the 15 sites]. Results of the sediment toxicity studies were used to develop SECs, PECs, and mean PECQs, as discussed in the following sections.

2.2 The Methods Used to Develop SECs Include Only a Subset of Relevant Toxicity Metrics
To evaluate potential risks to benthic invertebrates resulting from exposure to COCs in surface sediments, site-specific SECs were determined for each COC (TAMS, 2002a, 2002c). Five types of SECs were developed for each COC: Effects range-low (ER-L): the contaminant concentration in sediment representing the lowest 10th percentile of the values at which toxic effects on benthic invertebrates were observed. Threshold effect level (TEL): the geometric mean of the lowest 15th percentile of the concentration at which toxic effects on benthic invertebrates were observed, and the 50th percentile of the concentration at which no toxic effects were observed. Effects range-median (ER-M): the 50th percentile of concentration at which toxic effects on benthic invertebrates were observed. Probable effect level (PEL): the geometric mean of the ER-M and the 85th percentile of the no-effects concentrations. Apparent effects threshold (AET): the concentration above which a particular toxic effect in benthic invertebrates is always significant compared to reference samples. The BERA considered these five SECs to be representative of three conceptual adverse effects thresholds for benthic invertebrates: (1) the ER-L and TEL were considered to be sediment concentrations below which toxic effects are expected to rarely occur; (2) the ER-M and PEL were considered to be sediment concentrations above which toxic effects are predicted to frequently occur; and (3) the AET was considered to be a threshold above which toxic effects are predicted to always occur (TAMS, 2002a; Figure 2.1).

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Ecological Risks: Sediments (Final, 6/28/2005)

Sediment effect threshold Expected effect

ER-L/TEL Rarely

ER-M/PEL Frequently

AET Always

Contaminant concentration low

high

Figure 2.1. Conceptual diagram illustrating conceptual groupings of sediment effects to thresholds adopted in the Onondaga Lake RI.

Results for mercury presented in the BERA (TAMS, 2002a) illustrate the development of SECs (TAMS, 2002c). Dry weight (dw) mercury concentrations in sediment were used to develop the SECs for each toxicity endpoint from the acute 1992 study (Table 2.1) and from the chronic 2000 study (Table 2.2). The final SECs were selected from the 1992 data as follows: the final AET was the lowest of all four AETs; the final value for the four other SECs (ER-L, ER-M, TEL, and PEL) was the value based on chironomid survival only. The 2000 results for chronic toxicity were not incorporated into the final SECs because it was thought that there were insufficient data from the 2000 sampling (NYSDEC, 2004). Table 2.1. Site-specific sediment effect concentrations for mercury in Onondaga Lake based on 1992 acute toxicity data (in mg/kg dw)
Endpoint Amphipod biomass Amphipod survival Chironomid biomass Chironomid survival ER-L 0.6 5.2 0.8 0.5
b

TEL 1.2 3 1.3 1.0

b

ER-M 6 5.2 5.2 2.8

b

PEL 4.3 5.7 4.1 2.8

b

AET 20.4 a 30 13b

a. No value calculated due to limited effects. b. Selected as final SEC. Source: Table 9-11 of TAMS (2002a).

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Ecological Risks: Sediments (Final, 6/28/2005)

Table 2.2. Site-specific sediment effect concentrations for mercury in Onondaga Lake based on 2000 chronic toxicity data (in mg/kg dw)
Endpoint Amphipod biomass Amphipod survival Amphipod reproduction Chironomid biomass Chironomid survival Chironomid reproduction ER-L 3.2 0.7 0.7 0.7 0.7 1.6 TEL 3.4 1.4 1.4 1.5 1.6 2.5 ER-M 9.4 9.2 0.7 2.3 3.0 3.3 PEL 10.1 7.1 2.8 3.9 5.9 5.3 AET a 9.6 17.2 9.6 17.2 17.2

a. No value calculated due to limited effects. Source: Table 9-12 in TAMS (2002a).

2.3

The Methods Used to Develop PECs Include Inappropriate SECs and Geometric Means Leading to Artificially High (Less Protective) PECs

The five SECs for each contaminant (Table 2.3) were used to derive a PEC for a contaminant to identify areas of the lake bottom that could pose a risk to benthos (TAMS, 2002a, 2002c). TAMS (2002a) calculated the PEC as the geometric mean of the five SEC values. The PEC was defined as the contaminant concentration in sediments above which adverse effects in benthic invertebrates are expected to frequently occur based on the geometric mean of the five SECs for that contaminant (TAMS, 2002a). Table 2.3. SEC and PEC results for total mercury in Onondaga Lake sediments (in mg/kg dw) compared to the mercury PEC in MacDonald et al. (2000)
Year of sediment sampling 1992 ER-L 0.51 TEL 0.99 ER-M 2.8 PEL 2.84 AET 13 Onondaga Lake consensus PEC 2.2 MacDonald et al. (2000) PECa 1.1

a. TAMS (2002a) cites Ingersoll et al. (2000), however, the original source for this PEC is MacDonald et al. (2000). Source: 1992 toxicity test results, as presented in Table 11-8 of TAMS (2002a).

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The final SEC and PEC estimates for total mercury in sediments are presented in Table 2.3, based solely on the 1992 results for chironomid survival. Data for the other years were excluded from the analysis (NYSDEC, 2004). Note that the number derived in the BERA is double (less protective than) the number derived by MacDonald et al. (2000). This is an indication that the PECs derived in the BERA should be more thoroughly evaluated, using all site-specific data and all relevant toxicity literature. Although the general method used in the BERA (TAMS, 2002a) to develop a final PEC value appears to be based on MacDonald et al. (2000) and Ingersoll et al. (2001), there are important differences in the methodologies. MacDonald et al. (2000) compiled and screened published sediment quality guidelines (SQGs), based on empirical data from multiple unique sources. The intent was to provide a unifying synthesis (consensus) of the existing guidelines that would reflect causal effects and account for the effects of contaminant mixtures in sediments. Further, MacDonald et al. (2000) grouped published SQGs into two categories according to their original intent: those that attempted to identify concentrations below which no toxicity was expected (termed threshold effect concentrations, or TECs), and those that attempted to identify concentrations above which harmful effects were expected to occur frequently (termed probable effect concentrations, or PECs). Separate consensus-based TEC and PEC values were then developed by calculating the geometric mean of all TECs and PECs from each source, respectively. TECs were not included in the calculation of the consensus-based PEC. In contrast, the BERA (TAMS, 2002a) developed consensus-based PECs based on the results of a single toxicological study. A better approach would be to evaluate all of the site-specific data in the context of the relevant toxicity literature for each chemical. The PECs in the BERA combine values for threshold effects (ER-L, TEL), probable effects (ER-M, PEL), and expected effects (the AET). In addition, the BERA incorporates the AET value into the PEC calculation. MacDonald et al. (2000) did not include AET values in the calculation of PECs because they do not represent toxicity thresholds, but rather are concentrations above which harmful effects always occur. As shown in Tables 2.1 and 2.2, both acute and chronic tests conducted on Onondaga Lake sediments resulted in AET values higher than the thresholds above which harmful effects are expected to occur frequently (the ER-M and the PEL). The inclusion of the AET in the calculations thus increases the resulting PEC value and reduces the protectiveness of the risk assessment. This is illustrated by the fact that the Onondaga PEC for mercury, 2.2 mg/kg, is two times greater than the PEC developed by MacDonald et al. (2000; Table 2.3).

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2.4

The Methods Used to Develop PECQs Include Inappropriate Averaging, Likely Leading to Artificially Low (Less Protective) Average PECQs

The Onondaga Lake FS and PRAP integrate the PECs from the BERA into a mean PECQ as follows: 1. The concentration for each individual chemical in a sample was divided by its PEC to determine the PECQ for that contaminant in the sample (e.g., a mercury concentration in a sample of 4.4 mg/kg divided by the mercury PEC of 2.2 mg/kg yields a PECQ of 2 for mercury in the sample). Note that the PECQ is equivalent to a hazard quotient, and values over 1 indicate potential risks because the concentration in the sample is higher than the calculated toxic threshold level. All CPOIs in a sample were separated into five groups, based on chemical class (metals, aromatics, chlorinated benzenes, PAHs, and PCBs), and the average PECQ for that group was determined [e.g., (PECQethylbenzene + PECQxylenes)/2 = Mean PECQaromatics]. For each sample, the chemical group mean PECQs were then averaged to yield a Sample PECQ [e.g., (Mean PECQaromatics + Mean PECQmetals + Mean PECQPAHs)/3 = Sample PECQ].

2.

3.

The sample PECQs were evaluated to determine the relative risk throughout the lake (NYSDEC, 2004; Parsons, 2004). This approach was used in an attempt to compare the acute toxicity risk from the mixture of contaminants at the various sampling locations, and also to select a level of remediation that would address the overall risk of direct acute toxicity to the benthos from sediment contamination. However, each individual PECQ (equivalent to a hazard quotient) should itself be a direct indication of risk. Again, a better approach would be to place all of the site-specific toxicity in the context of the relevant toxicity literature for each chemical to derive PECs and PECQs that can be applied independently to lake sediments. Averaging the individual risk metrics, however, can substantially underestimate risk in the mixture, and obscures situations where specific chemicals become strong risk drivers within the mixture. In addition, when various chemicals within chemical classes have similar modes of toxicity and can act independently and additively to harm organisms in the environment, PECQs should be summed within chemical classes. Each chemical class PECQ-sum then should be used independently to evaluate risk, pre- and postremedy. Such procedures would ensure that the risk of each chemical is evaluated, rather than potentially masking high-risk chemical concentrations via risk averaging.

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In the FS, NYSDEC recalculated the PECQs developed by Honeywell to include only CPOIs that demonstrated a statistical relationship with the PECQs (23 of the original 46 CPOIs) (Parsons, 2004). This improved the predictive ability of the PECQs and reduced the amount of inappropriate risk averaging. A regression of the revised PECQs against chironomid mortality had an r2 value of 0.52, as opposed to an r2 value of 0.41 for the regression of the original PECQs against chironomid mortality. The final list of CPOIs used in the revised PECQs included: BTEX (ethylbenzene and xylenes) Chlorinated benzenes (monochlorobenzene, dichlorobenzenes, and trichlorobenzenes) PAHs (all 16 individual compounds) PCBs (total PCBs) Metals (mercury). We note that NYSDEC partially rectified the problem of risk-averaging by applying the mercury PECQ, independently, and also calculating a bioaccumulation-based sediment quality value (BSQV) because mercury bioaccumulates (see Chapter 3 for our comments on the mercury BSQV). However, the rationale for assessing risk independently for mercury applies equally to the other CPOIs in Lake Onondaga, as does the rationale for calculating BSQVs to the other CPOIs that bioaccumulate, such as PCBs, dioxins, furans, and hexachlorobenzene. Furthermore, the rationale presented in the proposed plan for limiting these independent and additional analyses that the other chemicals are co-located with mercury and will therefore be adequately addressed is highly suspect given the levels of chemicals that would be left behind under the preferred alternative [benzene 208 parts per million (ppm); chlorobenzene 114 ppm; dichlorobenzenes 90 ppm; naphthalene 20,573 ppm; xylene 142 ppm; ethylbenzene 1,655 ppm; toluene 2,626 ppm; mercury 2,924 ppm] (NYSDEC, 2004). Instead, the PRAP should analyze the residual risk of these and other chemicals that would be left in place under each alternative, particularly in light of the fact that many of the alternatives contemplate a cessation of dredging operations just as highly contaminated sediments are being exposed. Finally, although the Nations comments regarding cap effectiveness are presented elsewhere, we note that these are very high levels to be left in place (see Table 4.2), calling into question the rationale for a cap. If capping cannot protect human health and the environment from most high concentrations throughout the lake where dredging will be required, how can capping be protective for these very high residual concentrations? Furthermore, capping forecloses the opportunity to monitor remedial effectiveness and continue dredging, if needed (capping will make subsequent dredging quite difficult and expensive, even if the cap fails).

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2.5 Explanation for Why Risk Averaging to Develop Mean PECQs is Inappropriate
A risk assessment should clearly identify the various sources of risk to human health and the environment, and risk management decisions should clearly explain any residual risks that result from various potential remedial decisions. However, the mean PECQ approach adopted by NYSDEC has multiple levels of risk averaging that potentially obscure the evaluation of risk in Onondaga Lake sediments. We describe the problems with each level of risk averaging used to derive PECQs below. However, the reason that risk averaging, particularly multiple levels of risk averaging, is potentially so problematic can be seen by simple analogy. If a person wants to know whether a glass of water is safe to drink, the key issue is whether any contaminant is present in quantities high enough to cause harm. If the water contains enough lead to cause harm, then drinking the water is a poor choice, even if the amount of cadmium in the water is far below the level that causes harms. If the water also contains many other metals, many PAHs, many PCBs, many dioxins and furans, and many other kinds of hazardous substances, as do the sediments, waters, and biota of Onondaga Lake, then a reasonable person would want to know whether any one of the chemicals is present at levels high enough to cause harm. Knowing something about how many different contaminants in the sediment could cause harm is also useful, but calculating the average risk of all of the chemicals in a sample is worse than inadequate; it is misleading. This can be seen clearly from the fact that adding more and more chemicals that happen to be present at low levels has the effect of lowering the average risk even when chemicals are present at clearly harmful levels. If our hypothetical glass of water has 10 times too much lead to be safe, but 10 other metals are present at 1/10th of their harmful levels, then, on average, the metals are just at the threshold of being safe, even though the lead still makes the water unsafe to drink. In theory, one could include hundreds of individual PCBs, dioxins, furans, PAHs, and metals at very low levels to make the glass of water seem safe, according to average risk, even if lead (or any other contaminant) concentrations were hundreds of times higher than safe levels. Certainly, complicated sites like Onondaga Lake require a variety of techniques to summarize complex data and allow practical decision-making. However, risk factors for different locations within Onondaga Lake sediments could easily be shown as the highest hazard quotient (i.e., the ratio of: contaminant concentration divided by the harmful concentration), or PECQ, for any chemical in each sediment sample, or perhaps even the sum of all hazard quotients (or PECQs) for all chemicals in a sediment sample, rather than the average hazard quotient for each sample.

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Evaluations of ecological risk for other sites in New York State have not relied on methods that average hazard quotients as in the Onondaga Lake PRAP. For example, at the Hudson River site, the National Oceanic and Atmospheric Administration developed SECs for PCBs that would be applicable to the system (which includes freshwater, estuarine, and marine sediments) using a methodology similar to that of MacDonald et al. (2000), discussed in Section 2.3 of this report (MacDonald Environmental Sciences, 1999). Three levels were developed: a TEC below which effects are unlikely to be observed, a mid-range effect concentration (MEC) above which effects are likely to be observed, and an extreme effect concentration (EEC) above which adverse effects are expected to usually or always be observed. In the Hudson River Ecological Risk Assessment, observed sediment concentrations were compared to these SECs and the New York State benthic aquatic life chronic toxicity value (TAMS and Menzie-Cura & Associates, 2000). These thresholds were then considered directly in the Hudson River Feasibility Study along with other criteria, rather than attempting to develop a mean PECQ value for all contaminants (TAMS, 2000). MacDonald et al. (2000) used the PECQ methodology to evaluate the predictability of their consensus-based SQGs. They found that the average PECQ of all contaminants for which they developed SQGs was highly correlated with the incidence of toxicity (r2 = 0.98). Although mean quotients are positively correlated with the overall toxicity of samples, individual quotients are useful in identifying substances that may be causing or substantially contributing to the observed toxicity (Ingersoll et al., 2001). Further, these authors do not suggest that PECQs be used to establish target remediation objectives; rather, Ingersoll et al. (2001) suggest that SQGs be used along with other tools (e.g., sediment toxicity tests, bioaccumulation evaluations, and benthic community surveys) to assess particular hazards from contaminated sediments. For Onondaga Lake, the underlying data that indicate how much of each chemical is present, and how much is harmful, is summarized in a manner that does more to obscure the individual risk of each chemical than to clarify the overall risk picture.

2.6 Additional Issues Related to the Calculation and Use of SECs, PECs, and PECQs
2.6.1 Chronic toxicity NYSDEC has acknowledged that the mean PECQ approach does not address the potential chronic toxicity of lake sediments (U.S. EPA, 2005). The available Onondaga Lake site-specific sediment toxicity data clearly indicate that sediments are toxic to the benthos on both an acute and chronic basis (TAMS, 2002a). However, all PECQ calculations were based on acute toxicity data only (TAMS, 2002a). To address chronic toxicity, one remediation alternative (Alternative 7) was developed using the ER-L as the sediment toxicity remediation goal

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(Parsons, 2004). Because the ER-L is the concentration at which acute effects are rarely expected, it was thought that using the ER-L would likely protect the benthos from chronic as well as acute effects (NYSDEC, 2004). However, the ER-L was not used for any of the other alternatives, including the preferred remedy, and no other method was used to address chronic toxicity in selecting remedial alternatives. There is no reason why chronic toxicity cannot be addressed directly for all alternatives, using existing data from the site, and other relevant, published literature. It was also assumed that there would be a reduction in chronic toxicity in those areas of the lake where existing contaminated littoral sediments would be capped, assuming the cap is effective in keeping levels below the PECs (NYSDEC, 2004). However, cap effectiveness is subject to debate, as discussed in Chapter 5 of this document concerning residual risks, and elsewhere in the Nations comments. 2.6.2 Evaluation of surface sediments only

Only surface sediments less than 2 cm were evaluated, but the highest levels of some contaminants are found at greater depths. Figure 2.2 presents maximum concentrations of mercury measured in depth segments from Onondaga Lake.

Maximum total mercury (mg/kg) -

80 70 60 50 40 30 20 10 0 0-5 1 5-15 2 15-30 3 30-100 4 100-200 5 200-300 6

Depth (cm)

Figure 2.2. Maximum total mercury concentrations (mg/kg) in 1992 in Onondaga Lake by depth.
Source: Appendix G1 of the RI (TAMS, 2002c).

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In our preliminary review of the RI, BERA, FS, and PRAP, we did not identify any text addressing this issue, and sediment mixing typically occurs throughout a greater depth than 2 cm of sediment because of bioturbation, storms and waves, propeller wash from boats, and shoreline or lake bottom construction. Furthermore, several remedial alternatives, including the preferred alternative, dredge surface sediments, potentially leave behind very high levels of contamination. Again, the rationale that capping will be effective for these deeper sediments is suspect, given the rationale for dredging instead of capping of the current surface sediments. 2.6.3 Reference sites

Chapter 11 of the BERA indicates that only one site at one reference lake was used for sediment toxicity comparisons (TAMS, 2002a). We believe that should be explored further in future discussions between the Nation and the response agencies, particularly since there are questions, raised elsewhere, about whether all of the existing data for the site and all of the relevant literature have been used in the Onondaga Lake risk assessment. There is a possibility that other appropriate reference data are available.

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3. The Evaluation of Bioaccumulation in Onondaga Lake Fish is Not Sufficiently Protective

This chapter discusses the methods that were used in the RI (TAMS, 2002c) and BERA (TAMS, 2002a) to evaluate human health and ecological risks associated with the bioaccumulation of mercury in fish, which currently is a primary risk driver for remedial decisions in the PRAP. We would like to discuss with the response agencies whether we have accurately interpreted their evaluation of mercury bioaccumulation and its use in risk calculations, before offering detailed comments on potential improvements to the methodologies, or the incorporation of additional information from the literature. However, our primary initial comments regarding the evaluation of bioaccumulation in the BERA and FS include: Only mercury bioaccumulation is addressed, but there are many additional contaminants that were identified as risk drivers for human health and wildlife, including PCBs, hexachlorobenzene, and PCDD/PCDFs. Bioaccumulation of these persistent, toxic compounds could be as important as mercury for determining current and residual risk. We strongly recommend that these evaluations be undertaken and included in any decision about remedial alternatives. A BSQV was only developed for mercury. Because BSQVs are used to define remediation goals, we strongly recommend that BSQVs be developed for all of the other bioaccumulative substances of concern in Onondaga Lake. The rest of this chapter presents our current understanding of the evaluation in the RI (TAMS, 2002c) and BERA (TAMS, 2002a) of mercury bioaccumulation in fish. We raise several questions and issues throughout this summary and would like to discuss this critical issue further with the response agencies.

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3.1 The Onondaga Lake Fish Community Has Been Degraded and Fish Are Unsafe to Eat because of Contamination
Historically, Onondaga lake supported a coldwater fishery for Atlantic salmon (Salmo salar), cisco (Coregonus artedii), American eel (Anguilla rostrata), and burbot (Lota lota) (NYSDEC, 2004). Today, the lake supports a lower quality warmwater fish community dominated by pollution-tolerant species such as gizzard shad (Dorosoma cepedianum), freshwater drum (Aplodinotus grunniens), carp (Cyprinus carpio), and white perch (Morone americana). Nevertheless, the lake still has a sportsfishery for channel catfish (Ictalurus punctatus), largemouth bass (Micropterus salmonides), smallmouth bass (Micropterus dolomieui), and walleye (Stizostedion vitreum) (NYSDEC, 2004). However, a restrictive fish consumption advisory warns against any consumption of walleye, with all other species to be eaten no more than once per month, because of contamination in the lake (NYSDOH, 1999, 2002, as cited in U.S. EPA, 2005). The general advisory which is based on risks to consumers from mercury also carries the stipulation that infants, children under the age of 15, and women of childbearing age should eat no fish from the lake (NYSDOH, 2002, as cited in U.S. EPA, 2005). In addition to mercury, PCBs and dioxins are cited as restricting consumption of carp, channel catfish, and white perch to one meal per month for members of the general population.

3.2 Mercury Moves throughout Onondaga Lake

Mercury exposure pathways to biota include surface water, sediment, and dietary routes of exposure (U.S. EPA, 1997b). Dietary pathways of mercury exposure to fish include consumption of benthic invertebrates exposed to mercury from sediments, pore water, and upwelling groundwater, as well as consumption of fish contaminated through surface water and dietary pathways. The primary form of mercury that is bioaccumulated is organic methylmercury, the most toxic form of mercury (U.S. EPA, 1997b). Fish assimilate about 7-12% of methylmercury in water passing across their gills (Wiener and Spry, 1996). Methylmercury accumulates rapidly in the food chain and concentrations magnify in increasingly higher trophic levels (U.S. EPA, 1997b). Organic mercury (as methylmercury) can have a number of adverse effects on aquatic organisms. Documented impairments include inhibition of reproduction, reduction in growth, tissue histopathology, reduced success in prey capture, alterations in blood chemistry and thyroid function, and a number of other adverse effects on metabolism and biochemical functioning (U.S. EPA, 1997b). Adverse effects of mercury on humans can include neurotoxicity in the developing fetus, including impairment of motor skills and sensory function, and death at extremely high

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exposures (U.S. EPA, 1997b). In children and adults, impaired growth and development, behavioral abnormalities, and reduced reproductive success have also been documented (NYSDEC, 2004).

3.3 Evaluation of Surface Sediments, Only, Leads to Under-Protectiveness

There are several problems with evaluating only the 1992 Onondaga Lake sampling data. First, the 1992 sampling only measured contaminant concentrations in the uppermost layer (0-2 cm) of lake sediments, although it was acknowledged that the bioactive layer typically extends at least 15 cm (TAMS, 2002c). In addition, the RI found that mercury contamination is widespread in the upper 2 m of sediments, and extends as deep as 2 m and 8 m in the Ninemile Creek delta and the ILWD, respectively (TAMS, 2002c). Basing sediment target values on extrapolated uptake into fish tissue using 1992 surface sediment data is not protective of benthic biota, fish, or piscivores. Furthermore, deeper sediments are of considerable concern, both because of dredging proposed under various remedial alternatives, and the realistic possibility of storms, waves, propeller wash, construction, etc., that could reduce the effectiveness of capping.

3.4 The Calculation of Biota-Sediment Accumulation Factors Includes Inappropriate Averaging and Extrapolations
Biota-sediment accumulation factors (BSAFs) are unitless factors that describe the relationship between sediment and fish tissue concentrations of a contaminant, and are intended to serve as a simplified model of contaminant uptake (accumulation) from sediments to biota. BSAFs for fish are calculated as: [contaminant concentration in fish]/[contaminant concentration in sediment] To calculate BSAFs for Onondaga Lake fish, sampled fish were divided into two size classes (small fish, 3-18 cm in length; and large fish, 18-60 cm in length) and lake sediment concentrations for each group of each were averaged across either (1) the littoral zone only, or (2) the entire lake. Thus, two BSAFs were calculated for each fish size class: one for the littoral zone and one for the whole lake. Results for mercury are presented in Table 3.1. All mercury in fish was assumed to be in the form of methylmercury, which was considered a conservative assumption because methylmercury is more harmful than inorganic mercury (Parsons, 2004).

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Table 3.1. Mercury BSAFs calculated for Onondaga Lake

Lake sediment averages Littoral Lakewide Mean Source: Parsons (2004). Small fish (3-18 cm) 0.077 0.093 0.085 Large fish (18-60 cm) 0.194 0.235 0.215

We noted several problems with the approach used to calculate the Onondaga BSAFs, as discussed in the following sections. 3.4.1 Problems with averaging contaminant concentrations in fish based on size alone

Averaging contaminant concentrations over all fish on the basis of size alone obscures the influence of highly significant factors that affect contaminant accumulation in fish, such as the degree of physical association with contaminated sediments, age, gender, species, feeding habits, trophic level, prey choice, time of year, water temperature, and pH. For example, small largemouth bass are likely to accumulate more methylmercury than large bluegill. This single factor also impacts the calculation of protective fish tissue concentrations. A better approach would be to separate species into trophic levels before performing any size-based differentiation. For assessing risks to wildlife, the U.S. Environmental Protection Agency recommends classifying fish into trophic level 3 (forage fish) and trophic level 4 (higher level predators) in its Mercury Study Report to Congress (U.S. EPA, 1997b). This approach would permit a more comprehensive and protective evaluation of risk and alternative remedies. 3.4.2 Problems with extrapolation of fillet concentrations to whole body concentrations

The whole fish bodies consumed by fish-eating birds and mammals have higher concentrations of contaminants (particularly bioaccumulating chemicals) than fish fillets. The BERA extrapolated fillet concentrations to whole body concentrations by multiplying by a factor of 0.7, because that was the consensus of two literature values, instead of using the site-specific observed ratio of 1.1 for mercury (TAMS, 2002a). This has the effect of reducing the predicted whole-body mercury burden for fish by 30-40%. In addition, averaging concentrations across all fish obscures how the ratio of fillet concentration versus whole body concentration varies between different ages, species, genders, trophic levels, and prey choices of fish (Wiener and Spry, 1996). This obscures the highest uptake rates and reduces the protectiveness of the assessment.

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Furthermore, the distribution of concentrations should be investigated to see whether it is normal. If it is lognormal, then the geometric mean of the concentrations is more representative of the range of concentrations than the arithmetic mean.

3.5 The Mercury BSQV is Based on Low Effect Levels Rather than No Effect Levels
Similar to the mean PECQ that is used to predict the acute toxicity of sediments to benthic biota, a BSQV is intended to protect top-level consumers. The BSQV formula is: Target sediment concentration (BSQV) = [target fish tissue concentration/BSAF]. A BSQV value for mercury in sediments was back-calculated using the lowest observed adverse effects values (LOAELs) for target fish tissue concentrations for mercury, together with the highest lake-wide BSAF (Parsons, 2004). A BSQV value of 0.8 mg/kg was calculated by weighting the dietary consumption of each ecological receptor by its estimated percent consumption of fish by size class. This size-class dietary weighting is not a protective assumption, because trophic level is a better predictor of a BSAF than size (U.S. EPA, 1997b). Additional protection could easily be afforded by examining the risks to predators of consuming a diet of 100% fish from trophic level 4. In addition, the LOAEL is the value above which adverse effects are expected to occur, whereas the no observed adverse effect level (NOAEL) is the level at which no adverse effects are expected to occur. Therefore, use of the LOAEL is less protective than the NOAEL. It would be more appropriate to use either the NOAEL, or a value intermediate between the NOAEL and the LOAEL, or a range made up of the two values, rather than the LOAEL alone. Mercury NOAEL and LOAEL values for different ecological receptors for Onondaga Lake range from 0.009 mg/kg wet weight (ww) to 0.6 mg/kg ww in fish tissue and 0.08 mg/kg dw to 2.00 mg/kg dw in sediment (Table 3.2). By relying only on LOAELs, the PRAP is not adequately protecting consumers of fish from mercury toxicity in the environment.

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Table 3.2. Target fish tissue and sediment concentrations for mercury in Onondaga Lake expressed as NOAEL and LOAEL values for different ecological receptors as derived in the FS
Fish issue mercury (mg/kg ww) Target receptor Belted kingfisher Great blue heron Osprey Mink River otter Piscivorous wildlife Humans Source: Parsons (2004). NOAEL 0.011 0.035 0.032 0.009 0.014 0.01 0.2 LOAEL 0.112 0.345 0.318 0.093 0.136 0.3 0.6 Sediment mercury (mg/kg dw) NOAEL 0.13 0.20 0.16 0.11 0.08 LOAEL 1.32 2.00 1.57 1.09 0.83

3.6 BSQVs Were Not Developed for Critical Bioaccumulative Substances Other than Mercury
The FS did not calculate BSQVs for bioaccumulative contaminants other than mercury (e.g., PCBs, hexachlorobenzene, and PCDD/PCDFs) to drive remedial decisions. NYSDEC assumed that all of the bioaccumulating substances would be sufficiently addressed by addressing mercury (TAMS, 2002a). However, very high levels of many compounds, including bioaccumulating substances, will be left behind under the preferred remedy (see Chapter 5 of this document). There are sufficient data to calculate the residual risk for the other bioaccumulating compounds under various remedial scenarios, including an evaluation of potential capping failure. Furthermore, many of the other bioaccumulating substances are even more toxic and bioaccumulate more strongly than mercury. Therefore, the residual risk under the preferred alternatives, and under realistic cap failure scenarios is higher than an evaluation of mercury alone would indicate.

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4. A More Thorough and Protective Risk Assessment Justifies More Dredging than the Preferred Alternative
The main purpose of remedial investigations, risk assessments, and feasibility studies is to evaluate realistic alternatives for cleaning up contaminated sites. The PRAP then presents the response agencies position and justification to the public regarding the preferred alternative, and the ROD will finalize the response agencies remedial decisions after considering public comments. Although all nine Superfund criteria must be weighed, the primary motivation for more complete, more reliable, and faster cleanup is reduction of current and future risk to human health and the environment, while the primary motivation for less complete, less reliable, and slower cleanup is cost and cost-effectiveness. In this chapter, we present the reasons why a more thorough and protective risk assessment, as described in Chapters 2 and 3, would provide additional motivation and justification for a more complete and more reliable cleanup through additional dredging, as represented by Alternatives 5 through 7.

4.1 The Remediation Objectives Are Elimination or Reduction of Potential Health and Environmental Impacts
According to the PRAP, the primary objective of remediation in Onondaga Lake is to remediate sources of contamination, particularly in sediments, such that any potential future health and environmental impacts are eliminated or reduced, to the extent practicable (NYSDEC, 2004, p. 24). This chapter discusses the criteria that were used to select remedial alternatives, the main features of the alternatives that were evaluated, the relative effectiveness of the different alternatives, and the preferred remedy approved by NYSDEC.

4.2 PECQs Are Used to Evaluate Remedial Alternatives

For all but one of the lake-wide remediation alternatives, the primary criteria used for the remediation of sediment toxicity are a mean PECQ of 1 and a mercury PEC of 2.2 mg/kg (NYSDEC, 2004). A mean PECQ of 1 was interpreted to indicate that, on average, the concentrations of all the CPOIs in the sediments do not exceed their corresponding PECs (NYSDEC, 2004). However, as discussed in Chapter 2, the derivation of the SECs and PECs was not sufficiently protective, and risk averaging of the resultant PECQs further reduced the protectiveness and transparency of the critical criteria used to evaluate alternatives. For a more

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protective analysis, all hazard quotients (PECQs) should be based on the complete site-specific data and relevant literature, and then, instead of averaged, summed, summed by chemical class, or at a minimum, evaluated separately, with the highest hazard quotient driving risk management decisions. Even in places where mercury has the highest hazard quotient, this analysis would be much more transparent and meaningful than risk averaging.

4.3

Summary of the Main Features of the Different Remediation Alternatives

As discussed in the PRAP (NYSDEC, 2004), each of the remedial alternatives involves some combination of: Dredging Disposal and treatment at a sediment consolidation area (SCA) Isolation capping Thin-layer capping Aeration of the hypolimnion Monitored natural recovery (MNR) Habitat enhancement. With the exception of Alternative 1, the no action alternative, the different alternatives involve successively greater depths of excavation and therefore increasing volumes of waste removal (NYSDEC, 2004). Alternatives 2 through 6 involve removal of depths up to 1, 2, 3, 5, and 8 m within the ILWD in SMU 1, the most significant area of contamination. The PRAP notes that the long-term effectiveness of the alternatives increases with increasing amounts of waste removed, and that the reliability of the cap increases with removal of the more concentrated wastes. Alternative 4 includes hot spot removals to a depth of 3 m and provides greater reliability than Alternatives 2 and 3. Alternative 5 increases the area of removal to a depth of 5 m, but does not target hot spots, and therefore is not considered more reliable than Alternative 4. Alternatives 4 through 6 would also remove non-aqueous phase liquids (NAPLs), which are a concern in SMU 2, to a depth of 9 m (NYSDEC, 2004). This would further reduce contamination and increase cap reliability. Alternatives 6 and 7 would remove the most material, but this would exceed the capacity of the SCA, resulting in higher costs. Alternative 7 is the most costly alternative, but it is also the only alternative that attempts to address chronic toxicity by use of a lower cleanup criterion, the acute ER-L, which is the sediment concentration below which acutely toxic effects are expected to rarely occur.

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4.4 Summary of the Preferred Remedy

The preferred remedy would include a combination of dredging and capping of the main contaminants of concern in Onondaga Lake, including mercury, BTEX, napthalene, chlorinated benzenes, and PCBs. Dredging would remove about 2,653,000 cubic yards (cy) of the nearshore sediments containing toxic contaminants, with the majority of dredging in the southern portion of the lake near the former Honeywell facilities. In addition to dredging, there would be isolation capping of about 1.72 km2 of the littoral zone of the lake out to water depths of 9 m. The area of proposed isolation capping includes about 42% of the surface area of the littoral zone of the lake. There would also be thin-layer capping of about 0.6 km2 of contaminated sediments in the profundal (deep) zone of the lake. This amounts to about 8% of the surface area of the profundal zone. In addition to these remedial activities, an aeration (oxygenation) pilot study would be conducted to address methylation of mercury in the water column of the deep zone of the lake (NYSDEC, 2004). If found to be effective, aeration would be fully implemented, followed by monitoring of natural recovery. Contaminated sediments and wastes removed from the lake would be disposed of in an SCA in an existing waste location (NYSDEC, 2004). The sediment and waste consolidation would produce effluent water, which would be treated to remove solids and contaminants at a water treatment facility to be constructed as part of the remediation. The treated water would then be returned to the lake.

4.5 The Preferred Remedy is Not Sufficient

The comparative analysis by NYSDEC (2004) of the relative effectiveness of the different lakewide remediation alternatives is presented in Table 4.1. However, improvements in the risk assessment (see Chapters 2 and 3) would result in more protective PECQs, which would lead to higher calculations of current risk, and residual risk for areas not dredged under the various alternatives. Therefore, more dredging would be justified, as presented in Alternatives 5 through 7. Furthermore, capping is a risky alternative, particularly in light of the fact that dredging equipment will be mobilized and functioning in the lake under all but the no-action alternative. The proposed capping will greatly increase the cost of additional dredging in the future if the remedy proves insufficient. A much better strategy is to dredge all of the sediments contaminated above reasonable thresholds, followed by adequate monitoring of the sediments, water column, benthic organisms, fish, and fish eating birds and mammals (including humans) of Onondaga

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Table 4.1. Comparison by the NYSDEC of the remedial alternatives presented in the PRAP
Alternative 1a Alternative 2b Alternative 3c Alternative 4d Alternative 5e Alternative 6f Alternative 7g Overall protection of human health and the environment Compliance with applicable or relevant and appropriate requirements Long-term effectiveness and permanence Reduction of toxicity, mobility, or volume through treatment Short-term effectiveness Implementability Present-worth cost (millions) Not protective Not compliant Not effective None Not effective High $0 Moderate Moderate Moderately high High $312 Moderate Moderate Moderately high Moderately high High High

All generally compliant except possibly for the most stringent NY state surface water standard for total mercury (0.7 ng/L dissolved) Moderate Moderate Moderately high High $370 Moderately high Moderately high Moderately high High $451 Moderately high Moderately high Moderately high Moderately high $537 High Moderately high Moderately low Moderate $1,327 High Moderately high Moderately low Moderate $2,157

Note: Alternatives 2 through 6 are based on the mean PEC quotient of 1 plus the mercury PEC of 2.2 mg/kg. Alternative 7 is based on the ER-L. a. No action. b. Dredge for no loss of surface area/human & ecological (NLSA/H&E) + isolation capping in SMUs 1-7; NAPL removal to 4 m in SMU 2; dredge areas with higher groundwater upwelling in SMUs 3 and 6/thin-layer capping, aeration, MNR in SMU 8. c. Alternative 2 plus up to 25% removal of the ILWD in SMU 1. d. Alternative 3 plus removal in hot spot areas to a depth of 3 m in the ILWD and NAPL removal to 9 m in SMU 2. e. Alternative 4 with up to 5 m of removal in the ILWD in SMU 1. f. Full removal (up to 8 m) in SMUs 1, 2, 3, 4, 6, and 7; isolation capping in SMU 5; thin-layer capping, aeration, MNR in SMU 8. g. Same as Alternative 6 but cleanup to ER-L criteria rather than mean PECQ of 1 plus mercury PEC. Source: NYSDEC (2004).

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Lake to determine whether the remedy was sufficient. Then, additional dredging can be performed, as needed. It would be ironic if the dredging equipment were switched off, just as the dredge head reaches sediments so contaminated that they would likely trigger remedial action if discovered at another site. Table 4.2 presents the residual concentrations that would be left behind under the preferred alternative, and calculates how many times above the safe level, as represented by the PECs, that this is. The PEC are themselves too high, because of the inappropriate use of geometric means and because chronic toxicity was not addressed (see Chapter 2); and the PECQs, residual to dredging, are as much as 62,000 times higher than the PECs (i.e., hazard quotients are much higher than 1, even using the PECs). Furthermore, 51% of sediment samples from Onondaga Lake showed actual toxicity (40 of 79 sediment samples collected in 1992; TAMS, 2002a), but only 13% of contaminated sediments from Onondaga would be removed under the preferred alternative (2,653,000 cy removed of 20,091,000 cy contaminated; NYSDEC, 2004). Table 4.2. Residual concentrations and hazard quotients left behind by the preferred alternative
CPOI Benzene Chlorobenzene Dichlorobenzenes Naphthalene Xylenes Ethylbenzene Toluene Mercury Residual concentration with preferred alternative (mg/kg)a 208 114 90 20,573 142 1,655 2,626 2,924 PECs (mg/kg)b 0.150 0.428 0.239 0.917 0.561 0.176 0.042 2.2 Residual hazard quotient with preferred alternativec 1,387 266 377 22,435 253 9,403 62,524 1,329

a. From the PRAP, describing concentrations that trigger additional dredging in the ILWD. b. From the BERA, Table ES-3. c. Calculated as the maximum residual concentration allowed in ILWD, post-dredging, divided by the PEC. Residual hazard quotients above 1 are potentially problematic, particularly if the cap fails. Sources: TAMS (2002a) and NYSDEC (2004).

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5. Residual Risk Calculations Must be Improved Before Remedial Alternatives Are Compared
Chapter 4 shows that removal of contaminants, additional to those targeted by the preferred alternative, is justified. This chapter presents additional comments about how residual risk calculations must be improved to ensure an accurate comparison of remedial alternatives. For example, although the FS acknowledges that water, sediments, and the food chain all transport contaminants, only the sediment pathway was evaluated in determining potential residual risk to fish (Parsons, 2004, Appendix I). In addition to sediment-based exposure pathways, fish accumulate many Onondaga Lake contaminants directly via opercular-uptake as well as via prey that are themselves exposed via opercular uptake. However, the surface water pathway was excluded from the residual risk calculations, both as an independent pathway and as a source of cumulative exposure to contaminants. Furthermore, one form of cap failure is movement of groundwater carrying high levels of contamination, including both NAPLs and dissolved phase chemicals. This groundwater could, in turn, serve as a pathway to surface water, further emphasizing the importance of the water column pathway in calculating residual risk, particularly under cap failure scenarios. In addition, there are uncertainties underlying the estimates of risk reduction presented in the FS (Parsons, 2004, Appendix I). Although these uncertainties were acknowledged, there was no quantitative uncertainty analysis or evaluation of the sensitivity of results to assumptions about the values of key parameters. This is quite important because one of the key differences between in-place remedies like capping and removal remedies like dredging is increased uncertainty about the ultimate fate of in-place contamination, and those uncertainties increase over longer periods into the future. Therefore, even if the cap was as effective as dredging, initially, full accounting of differential uncertainty in residual risk between capping and dredging should be presented. All of the lake-wide remediation alternatives assume that concentrations of contaminants in water and sediment will be reduced as a result of (1) reductions in loadings from upland and inlake sources, (2) aeration of the hypolimnion, and (3) sediment remediation (Parsons, 2004, Appendix I). Some of the issues related to residual risks following these actions are discussed in the following sections, with a focus on mercury. Ideally, a much more extensive analysis of potential residual risks would be conducted, particularly since remedial decisions for other operable units and connected sites could range from inaction and delay, to natural recovery, to in-place immobilization attempts, to aggressive removals. A full accounting of residual risk

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should account for the variability in potential loadings from these other sources, rather than a uniform assumption of complete, quick, and effective cleanup.

5.1 Reductions in Contaminant Loadings

Sources of mercury to Lake Onondaga include groundwater, tributaries, and the Metro Plant (Parsons, 2004, Appendix I). The FS assumed that upland control will reduce or eliminate total mercury and methylmercury from Honeywell-impacted tributaries and groundwater, and that improvements to the Metro Plant have resulted in a 50% reduction to loadings from this source. We were unable to find the underlying justification for assuming that upland controls will reduce or eliminate mercury from tributaries and groundwater, and there are no data on the effectiveness of plant upgrades. Thus, we were unable to determine if these assumptions are reasonable. We also note that the timing of the cleanup of Onondaga Lake, and the effectiveness of remedial decisions there, is directly dependent on the decisions and timing for the operable units adjacent to and upstream of the lake. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) defines an operable unit as a discrete action that comprises an incremental step toward comprehensively addressing site problems (NYSDEC, 2004). If actions in the operable units do not precede actions that are dependent on them, subsequent actions may not achieve the cleanup success that is assumed. In-lake sources of mercury include littoral sediment (mostly in the ILWD, in the southwest portion of the lake) and methane gas ebullition (releases) from the profundal sediments (TAMS, 2002c). The FS assumed that capping or dredging will eliminate mercury releases from the ILWD and that thin-layer capping, aeration (oxygenation), and natural recovery will significantly reduce mercury releases from profundal sediments (Parsons, 2004, Appendix I). Source control is assumed to result in an 81 to 95% reduction in total mercury loadings to the lake, and a combination of source control and aeration is assumed to result in an 82% reduction in methylmercury loading (Parsons, 2004, Appendix I). However, we have not yet reviewed the modeling studies that are the basis for these estimates. Support for these reductions should be provided, together with a reasonable uncertainty/sensitivity analysis.

5.2 Aeration of Hypolimnion

According to information provided in the PRAP, the primary source of methylmercury to the water column is assumed to be the methylation of mercury in the hypolimnion during the summer, when conditions in the hypolimnion are anoxic (NYSDEC, 2004). When the lake stratifies in the summer, bacteria and other organisms are isolated from the epilimnion and

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confined to the hypolimnion. During this time, these organisms deplete the oxygen in the hypolimnion and create anaerobic conditions conducive to the production of methylmercury. Small quantities of methylmercury in the hypolimnion diffuse to the epilimnion in the summer. But during the fall turnover, large quantities of methylmercury are released from the hypolimnion, substantially increasing the methylmercury in the upper layer of lake waters. This results in a large export of mercury to downstream areas of the lake (NYSDEC, 2004). Aeration (oxygenation) of the hypolimnion is intended to reduce the methylation of mercury in the hypolimnion during summer (NYSDEC, 2004). Aeration would involve introducing oxygen to the hypolimnion to reduce the hypoxic conditions that promote methylation. The PRAP notes that aeration has been performed in other lakes, but acknowledges that aeration has rarely been used to control methylmercury production (NYSDEC, 2004). Therefore, the effectiveness of aeration, and the residual risks following aeration, are unknown. According to the PRAP, a pilot study would be conducted in the water column of the deep zone of the lake to determine the effectiveness of aeration, and, if found to be effective, aeration would be fully implemented (NYSDEC, 2004). However, before the pilot study is conducted it is misleading to discuss aeration as though it is known to be effective, as we noted in many sections of the documents we reviewed. Therefore, the evaluation of residual risk must, at a minimum, consider the range of possible effectiveness of aeration to include partial success and failure, both realistic possibilities. In addition, there is the possibility that oxygenation of the water column would have a number of negative effects. As pointed out in Chapter 11 of the BERA (TAMS, 2002a), oxygenation of the hypolimnion could simply shift the anoxic boundary from the water column to the sediment, leaving more contaminants available at the sediment surface. In turn, this would increase the bioavailability of contaminants to the aquatic food web (TAMS, 2002a).

5.3 Sediment Remediation

5.3.1 Effectiveness of isolation capping Isolation capping involves the placement of an engineered cap on top of contaminated sediment, which can help to prevent or slow the movement of contaminated porewater into the water column, minimizing exposure of benthic organisms to contaminated sediment (NYSDEC, 2004). Because there are varying degrees of contamination in the sediments in different parts of the littoral zone in Onondaga Lake, a model was developed to evaluate cap effectiveness in each littoral zone SMU. The effectiveness of capping depends on factors such as contaminant concentrations below the cap and the rate at which groundwater flows up through the capped sediments (NYSDEC, 2004). Therefore, accurate model predictions require good information on

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the rates of these processes, as well as a sensitivity analysis to compare predictions under different rate assumptions. We have not identified such an analysis in the Onondaga Lake documents that we have reviewed to date. Another important assumption concerns the depth of the biologically active zone (bioturbation layer). Contaminants may be transported to the surface of the cap by organisms mixing the sediment. The capping model apparently assumes that the bioturbation layer is less than 15 cm above the chemical isolation area (Parsons, 2004, Appendix I). However, the justification for this assumption is not provided. While many freshwater organisms show bioturbation activity within the top 15 cm of sediments, crustaceans can be found turning over sediments as deep as 3 m (Pennak, 1978). Furthermore, waves, storms, propeller wash, and construction are all certainties, but we have not seen any analysis of the effects of these factors under a range of realistic cap failure scenarios.

5.4

Mercury Mass Balance

The mass balance model for mercury and methylmercury in the RI indicates a net loss of mercury in the lake water, mostly as a result of sedimentation and burial of mercury in the profundal sediments (TAMS, 2002c). This results in a deficit in the mass balance equation equal to all currently identified external inputs, indicating that there are significant unidentified sources of mercury to the system (U.S. EPA, 2005). Two internal sources of mercury are hypothesized: (1) release of mercury from sediments due to releases of methane gas and production of methylmercury in the upper sediment layers, which is subsequently cycled to the hypolimnion; and (2) resuspension of sediments in contaminated nearshore areas, particularly the ILWD (TAMS, 2002c). There are also possible upland sources that are not accounted for, such as inputs from storm water discharges, which cumulatively could be substantial (TAMS, 2002c). Because these potential additional sources are poorly documented, they may not be completely accounted for in the current remedial alternatives, with unknown consequences for residual risks. Again, a residual risk analysis that addresses a more realistic range of potential outcomes, not just the few outcomes that seem most favorable, would capture these uncertainties.

5.5

Chronic Toxicity

As discussed in Chapter 2, the PRAP only attempts to address chronic toxicity in one remediation alternative (Alternative 7) (NYSDEC, 2004). Alternative 7 (the most protective alternative) bases remediation on the ER-L, the concentration at which acutely toxic effects are expected to rarely occur (and therefore assumed to account for chronic toxicity). However, the

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ER-L was not used for any of the other alternatives, including the preferred remedy, and it appears as though no other methods were used to address chronic toxicity. Chronic toxicity is therefore a potentially important source of residual risk that requires further consideration.

5.6

Uncertainty Analysis and Sensitivity Analysis

Numerous models are used in the Onondaga Lake risk analysis. Models are often necessary, in the absence of complete information, to examine how complex processes may influence risks. However, models should be calibrated and validated with sufficiently independent data sets, and model assumptions should be tested by means of uncertainty analysis and sensitivity analysis to determine how inaccuracies in the assumptions influence model results. Sufficient descriptions of model calibration, validation, uncertainty analysis, and sensitivity analysis were not found in our review of the Onondaga RI (TAMS, 2002c), BERA (TAMS 2002a), and FS (Parsons, 2004). Without such analyses, the reasonableness of model predictions is impossible to assess. 5.6.1 Uncertainty analysis

Use of a probabilistic analysis, such as a Monte Carlo analysis, is a common method of performing uncertainty analysis (U.S. EPA, 1997a). While a quantitative uncertainty analysis may not be practical to perform for fate and transport models, it is both feasible and important for loading and food web models. Lack of quantitative uncertainty analysis for the loading and food web models used in the Onondaga Lake assessments makes rigorous review and evaluation of the predictions of these models problematic. 5.6.2 Sensitivity analysis

A sensitivity analysis consists of examining how model predictions change as each input parameter is varied while other parameters are held constant. This makes it possible to identify those variables that most strongly influence model predictions and that are therefore critical to estimate with as much accuracy as possible. Without such information, it is difficult to know how influential particular model assumptions may be, or which model parameters may require more empirical investigation. For example, the analysis in the FS of residual mercury concentrations in water, following source control and aeration, assumes that upgrades to the Metro Plant have resulted in a 50% reduction in mercury loadings from this source (Parsons, 2004). However, because there are no data to establish what the actual reduction is, it is important to consider what a lower (or higher) percent reduction would indicate for loadings, and how estimates of residual mercury concentrations would change.

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5.7 Failure to Consider All Potential Risk Drivers

Table 5.1 summarizes the concentrations in fish of contaminants in Onondaga Lake that are considered risk drivers and compares these concentrations to target risk levels calculated for the site. Based on this summary, we are concerned that important chemicals, especially bioaccumulating chemicals, are not used directly in residual risk calculations.

5.8 High Residual Levels of Numerous Chemicals

The preferred remedy includes removal of contaminant hot spots in SMU 1, which increases cap effectiveness (NYSDEC, 2004). However, the high residual levels of contaminants suggests that substantial residual risks may remain. High levels of contaminants that are expected to remain under the preferred remedy, even after hot spot removal in SMU 1, include 208 ppm benzene, 114 ppm chlorobenzene, 90 ppm dichlorobenzenes, 20,573 ppm naphthalene, 142 ppm xylene, 1,655 ppm ethylbenzene, 2,626 ppm toluene, and 2,924 ppm mercury (also see Chapter 4). In addition, the high residual level of contaminants throughout other parts of the lake under the preferred remedy is a concern. Additional work is required to determine how residual risks would change if these chemicals were included in the analysis.

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Table 5.1. Concentrations in Onondaga Lake fish of contaminants considered risk drivers and calculated target concentration to avoid risk
Fish concentrations 1992 to 2000 data Target tissue concentration range to avoid risk (mg/kg) 95% upper Arithmetic confidence Max mean limit detection

Risk drivers

Human health exposure fish fillets Lower-end Upper-end Mercury (as methylmercury) 0.2 0.6 1.05 1.08 5.07 Total PCBs 0.003 0.2 0.67 0.91 3.90 Arsenic ND ND 0.33 0.80 1.05 PCDD/PCDFs TEQ as 2,3,7,8tetrachlorodibenzo-p-dioxin 4.E-08 5.E-05 1.01E-05 1.95E-05 4.60E-05 Ecological exposure small fish (3 to 18 cm) whole fish NOAEL LOAEL Mercury (as methylmercury) 0.009 0.187 0.27 0.35 0.91 Total PCBs 0.013 3.15 0.98 3.49 3.49 DDT and metabolites (sum) 0.005 0.049 0.05 0.07 0.10 Ecological exposure large fish (18 to 60 cm) whole fish Mercury (as methylmercury) 0.014 0.341 0.68 0.75 2.88 Total PCBs 0.0185 9.6 1.57 2.12 11.1 DDT and metabolites (sum) 0.014 0.15 0.096 0.24 1.44 Notes: 1. Human health exposure data (fish fillets) were taken from Table 3.1 from Appendix B of the Onondaga Lake Human Health Risk Assessment report. 2. Ecological exposure data (whole fish) were taken from Tables H-5 and H-6 from Appendix H of the Onondaga Lake Baseline Ecological Risk Assessment report and converted from dry weight to wet weight based on the average percent solids in fish (24%). 3. Target tissue concentrations were taken from Appendix G of the FS. 4. Mercury and methylmercury fish data from the BERA were combined and converted from dry weight to wet weight. Results are provided in Section I.3.2 of Appendix I of the FS. 5. Contaminant concentrations differ between the various data sets due to factors including the portion of fish analyzed (contaminants accumulate in various body parts) and age and/or species of fish. 6. ND = Not developed because arsenic was only detected in 2 of 11 samples. See Appendix G of the FS for details. 7. NOAELs and LOAELs for small (3 to 18 cm) fish are based on the belted kingfisher and mink. NOAELs and LOAELs for large (18 to 60 cm) fish are based on the great blue heron, osprey, and river otter. 8. Only avian fish target concentrations are presented for DDT and metabolites. Source: Fish table from U.S. EPA (2005).

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6. Summary and Recommendations

Rather than constructing a valid analysis from the ground up, NYSDEC, its consultants, and EPA endeavored to transform Honeywells flawed analysis into a more scientific investigation better rooted in public policy. Many of the flaws, originally identified by NYSDEC and EPA in Honeywells analysis, however, have not yet been adequately addressed. Despite NYSDECs attempt to remedy the flaws in the original Honeywell analysis, there are still several important issues that should be addressed before issuing a ROD. Based on our analysis, the preferred alternative in the PRAP is not sufficiently protective of human health and the environment, and the description of the risk that the public and environment will still face after the cleanup is inadequate to enable scientific and public review. Several elements of the PRAP lead to an underestimation of risk caused by the current contamination in Onondaga Lake, as well as the predicted risk under the preferred alternative. Furthermore, many of these elements compound the underestimation, leading to an inaccurate and inflated picture of the potential effectiveness of the preferred alternative. Based on our initial review, the PRAP should be revised before a ROD is issued. Risk calculations include multiple levels of bias that fail to adequately protect human health and the environment. The comparison of alternatives that made Alternative 4 the preferred alternative is based on the biased risk assessment. Correcting the risk assessment will provide more justification for additional dredging and less reliance on capping than proposed by Alternative 4. The most important issues leading to an underestimation of risk include the following: Sediment effects concentrations (SECs) were based on only a portion of the site-specific toxicity data (excluding certain years and excluding all chronic toxicity data), as well as only a portion of the relevant literature regarding the toxicity of chemicals present in Onondaga Lake. A more thorough investigation of the data and literature, and the inclusion of chronic toxicity effects, would lead to more protective SECs. The SECs used in the PRAP represent only a subset of valid toxicity metrics that could be used to characterize toxicity and risk at the site. Furthermore, the PRAP does not use the SECs to bracket toxicity thresholds directly. Rather, a series of geometric means of different SECs were used to calculate a single probable effects concentration (PEC). Some of the SECs included in this calculation were concentrations sufficiently high to always cause toxicity in the environment. The single PEC was treated as the concentration that represents a safe threshold for a contaminant. This causes two problems. First, the PEC number is set too high (not protective enough). Second, the PEC calculation obscures important information about toxicity, including the levels of

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contamination that just avoid and just start to cause toxicity in the environment. A better and more thorough exploration of the real thresholds of toxicity would lead to more protective, and more justified PECs. The too-high PECs, which were based on too-high SECs, were then converted to PEC quotients (PECQ), which is the concentration of a chemical in a sample divided by the purported safe level (the PEC). A PECQ is equivalent to a hazard quotient, and values over 1 indicate potential risks because the concentration in the sample is higher than the calculated toxicity threshold. Therefore, the PECQ is a number with no units, where 1 represents the safe level, 10 represents 10 times higher than the safe level, etc. In the PRAP, however, cleanup determinations for sediments were not made by examining the PECQs for individual chemicals. Instead, the PECQs were averaged within chemical classes, and all of the chemical class PECQs were averaged with each other. So, many chemicals at low levels cause the average PECQ to be lower, even when one or more chemicals have very high individual PECQs, leading to an artificially low description of risk. Although NYSDEC partially addressed this issue by using the mercury PECQ independently, the PRAP should be modified to apply all of the PECQs independently, or perhaps even as sums by chemical class, or sums across all chemicals (sums would recognize possible additivity between chemicals and would result in higher PECQs and more protective standards). Remedial alternatives were only evaluated by using an average PECQ for all contaminants combined and the PECQ for mercury. These metrics were used to account for acute sediment effects on benthic biota. Mercury was singled out because of its particularly significant toxic effects and high historical loadings to Lake Onondaga. However, the more protective Bioaccumulation-based Sediment Quality Value (BSQV) for mercury was not used to evaluate remedial options in the PRAP. The development of a mercury PECQ and a mercury BSQV recognized the need for independent evaluation of toxicity to benthic invertebrates in the sediment, and toxicity to organisms that bioaccumulate chemicals by eating other contaminated organisms. In addition, PECQs and BSQVs for individual contaminants, other than mercury, were not used to evaluate remedial alternatives in the PRAP. This is particularly problematic for other persistent contaminants that bioaccumulate, like PCBs, dioxins, furans, and hexachlorobenzene, which are present in significant quantities in Lake Onondaga sediment or fish. These chemicals affect highly sensitive fish-eating mink and birds. Therefore, a thorough evaluation of the bioaccumulation of these compounds, including independent application of BSQVs for each chemical, would provide additional justification for cleanup, including cleanup beyond the preferred alternative. The preferred remedy calls for dredging of some highly contaminated sediments, but leaves behind contaminated sediments that are extremely toxic, even when compared to

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the too-high SECs, PECs, and PECQs used in the PRAP. Under the preferred alternative: benzene will be left at 1,387x of the purported safe level calculated by the PRAP; chlorobenzene 266x; dichlorobenzenes 377x; naphthalene 22,435x; xylenes 253x; ethylbenzene 9,403x; toluene 62,524x; and mercury 1,329x. These highly contaminated sediments are proposed for capping even though the dredging equipment will already be in place and functioning when these sediments are left behind under the preferred alternative. Furthermore, the justification for dredging instead of capping applies to these sediments as much as the other sediments that will be dredged under the preferred alternative. To be adequately protective, the PRAP must apply valid SECs, PECs, PECQs, and BSQVs, and must complete the removal task while the dredging equipment is in place and operational. These residual levels are themselves high enough to justify remedial action at most other sites. Capping, as described in the preferred alternative, will strongly foreclose many opportunities to improve the remedy if the cleanup does not eliminate risks as completely or quickly as planned and predicted. Given the large number of calculations that underestimate risk, described throughout these comments, the PRAP should include a much better program for monitoring success and requiring remedial efforts to continue until success is reached, particularly given the tremendous uncertainties of predicting long-term cap effectiveness. Furthermore, planning now to cease dredging operations while very high concentrations of contaminants remain just below the last dredge cut is a risky strategy that does not appear to be rooted in scientific analysis or good public policy. Furthermore, during discussions with the response agencies, we would like to take up several additional topics that were not addressed in our review. These topics include: The timing and likely range of remedial outcomes for other operable units and sites connected to Onondaga Lake More in-depth exploration of ecological risk assessment calculations for mercury and other contaminants Contaminants in surface water Cap failure scenarios and the relationship to residual risk calculations Modeling assumptions and alternative outcomes Data sources for risk calculations Human health risk assessment, including goals for recovery of fishing uses like subsistence fishing that should be protected for the Nation. Given the significance of the issues we raise, we think that meetings with the response agencies are essential to address the comments in this report, both by answering questions to reach resolution on issues, and by changing the PRAP, where appropriate, before issuance of the ROD.

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References
Ingersoll, C.G., D.D. MacDonald, N. Wang, J.L. Crane, L.J. Field, P.S. Haverland, N.E. Kemble, R.A. Lindskoog, C. Severn, and D. E. Smorong. 2000. Prediction of Sediment Toxicity Using Consensus-Based Freshwater Sediment Quality Guidelines. EPA 905/R-00/007. Ingersoll, C.G., D.D. MacDonald, N. Wang, J.L. Crane, L.J. Field, P.S. Haverland, N.E. Kemble, R.A. Lindskoog, C. Severn, and D.E. Smorong. 2001. Predictions of sediment toxicity using consensus-based freshwater sediment quality guidelines. Archives of Environmental Contamination and Toxicology 41:8-21. MacDonald, D.D., C.G. Ingersoll, and T.A. Berger. 2000. Development and evaluation of consensus-based sediment quality guidelines for freshwater ecosystems. Archives of Environmental Contamination and Toxicology 39:20-31. MacDonald Environmental Sciences. 1999. Development and Evaluation of Consensus-Based Sediment Effect Concentrations for PCBs in the Hudson River. MacDonald Environmental Sciences Ltd. Prepared for NOAA, Damage Assessment Center. March. NYSDEC. 2004. Proposed Plan: Onondaga Lake Bottom Subsite of the Onondaga Lake Superfund Site, Syracuse, New York. New York State Department of Environmental Conservation, Albany. November. NYSDOH. 1999. 1999-2000 Health Advisories: Chemicals in Game and Sportfish. New York State Department of Health, Division of Environmental Health Assessment, Troy. NYSDOH. 2002. 2002-2003 Health Advisories: Chemicals in Game and Sportfish. New York State Department of Health, Division of Environmental Health Assessment, Troy. Onondaga Lake Partnership. 2005. Onondaga Lake Pollution. Available: http://www.onlakepartners.org/olpoll/index.cfm. Accessed June 27, 2005. Parsons. 2004. Draft Final Onondaga Lake Feasibility Study Report, Onondaga County, New York. Prepared for Honeywell, Morristown, NJ. November. Pennak, R.W. 1978. Freshwater Invertebrates of the United States. 2nd Edition. John Wiley & Sons, New York. State of New York and Thomas C. Jorling v. Allied-Signal, Inc. 2002. State of New Yorks Determinations Disapproving and Revising Honeywells Remedial Investigation, Baseline

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References (Final, 6/28/2005)

Ecological Risk Assessment, and Human Health Risk Assessment Reports for the Onondaga Lake System. Civil Action No. 89-CV-815, U.S. District Court for the Northern District of New York, Binghamton Division. December 31. TAMS. 2000. Hudson River PCBs Reassessment RI/FS Phase 3 Report: Feasibility Study. TAMS Consultants Inc. Prepared for U.S. Environmental Protection Agency Region 2 and U.S. Army Corps of Engineers Kansas City District. December. TAMS. 2002a. Onondaga Lake Baseline Ecological Risk Assessment. Original document prepared by Exponent, Bellevue, WA for Honeywell, Syracuse, NY. Revision prepared by TAMS Consultants, Inc., New York, for the New York State Department of Environmental Conservation, Albany. December. TAMS. 2002b. Onondaga Lake Human Health Risk Assessment. Original document prepared by Exponent, Bellevue, WA for Honeywell, East Syracuse, NY. Volumes 1 and 2. Revision prepared by TAMS Consultants, Inc. and YEC, Inc. for the New York State Department of Environmental Conservation, Albany. December. TAMS. 2002c. Onondaga Lake Remedial Investigation Report. Original document prepared by Exponent, Bellevue, WA for Honeywell, Syracuse, NY. Revision prepared by TAMS Consultants, Inc., New York for the New York State Department of Environmental Conservation, Albany. December. TAMS and Menzie-Cura & Associates. 2000. Further Site Characterization and Analysis: Volume 2E. Revised Baseline Ecological Risk Assessment: Hudson River PCBs Reassessment. Phase 2 Report. TAMS Consultants Inc. and Menzie-Cura & Associates, Inc. Prepared for U.S. EPA Region 2 and U. S. Army Corps of Engineers, Kansas City District. November. U.S. EPA. 1997a. Guiding Principles for Monte Carlo Analysis. EPA/630/R_97/001. U.S. Environmental Protection Agency, Risk Assessment Forum, Washington, DC. U.S. EPA. 1997b. Mercury Study Report to Congress. EPA Office of Air Quality Planning & Standards and Office of Research and Development. EPA-452/R-008. December. U.S. EPA. 2005. National Remedy Review Board Package: Onondaga Lake Bottom (with attached tables and figures). Prepared for the National Remedy Review Board by U.S. EPA Region II. January. Wiener, J.G. and D.J. Spry. 1996. Toxicological significance of mercury in freshwater fish. In Environmental Contaminants in Wildlife, W.N. Beyer, G.H. Heinz, and A.W. Redmon-Norwood (eds.). Lewis Publishers, New York, pp. 297-339.

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