Document 82QkRmpXwVwL92nK9O99V9G6e

-i ATTACHMENT G P DATE: !UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION V OCT 2 5 s u b j e c t : Proposed Revisions of Region V Site Selections, Appendix E, with Explanation f r o m : W. L. Redmon Permit Section T0: Howard Zar Environmental Scientist Attached are copies of our 10/13/83 proposed revisions of the Region V site selection's in the National Dioxin Study Plan with comments. They are based on our internal discussions and the input from sta ff biologists in each State. In general, we have tried to lim it revisions, but we have replaced some stations that have been sampled in the past year or two (and for which comparable data have already been generated). We also moved a few stations to nearby sites more suited for screening the areas involved or for which tissue samples have been collected and are already available. EPA FORM 1320-6 (REV 3-761 State Illin o is Indiana Mi chi gan APPENDIX E Sampling Location 1. M ississippi River 0 Thebes, IL (NASQAN) River Mile (RM) 44 2. Illin o is River 0 Florence State Station at lower end 3. Big Muddy River 0 5mi E. of Grand Tower Rattlesnake Ferry R iffle is a good collection site in State network 4. Illin o is River 0 Marseilles (NASQAN) 5. Rock River @ Joslin (NASQAN) 6. Kaskaskia River 0 Vandalia State site 7. Des Plaines River 0 Lockport Downstream end of Chicago drainage area 1. Wabash River at Darwin's Ferry State Core Station, RM 190 2. Wabash River 0 Black Rock State Core Station 2mi. below LaFayette, RM 298 3. Ohio River 0 Uniontown, KY (RM 846) Historic fish tissue site below Evansville 4. Ohio River 0 West Point, KY (RM 629) Historic fish tissue site below Louisville 5. White River 0 Petersburg Historic fish tissue site 6. Mississinewa River 0 Mathews Typical rural site without known toxicant sources upstream All sites chosen from State Study Plan; tissue samples collected; historic data available. 1. Kalamazoo River 0 Lake Allegan 2. St: Claire River 0 Marysville 3. Clinton River 0 Mt. Clemens 4. Shawasee River 0 Chesaning Minnesota Ohio 2 5. Flint River @ Fl int 6. River Raisin @ Monroe 7. Pi ne River @ Alma 8. Huron River @ Fiatrock 9. Muskegon Lake (same as Site 22-, Appendix L?) 10. Muskegon River @ Rogers Dam 11. AuSable River @ Mio 1. M ississippi River @ LaCrosse State sampling station; fish have been collected 2. Rainy River @ International Falls State station 3. Minnesota River @ Mankato 4. Cannon River @ Cannon Lake "Clean" site 1. Ohio River @ Marietta (RM 170) Known dioxin site at Marietta; chemical Industry area. 2. Ohio River @ East Liverpool (RM 40) Industrialized area; historic sample site 3. Ohio River @ G a llip o lis (RM 279.2) Below Kanawka River 4. Ohio River @ Portsmouth (RM357) Downstream of industrialized area 5. Muskingum River @ Zanesville H istoric Sampling area with chemical industry. 6. Scioto River @ C irc le v ille 7. Great Miami River @ C a rlisle 8. Tuscarawas River @ Dover H istoric Sampling area with chemical i ndustry 9. Middle Branch, L ittle Beaver Creek @ Salem Downstream of abandoned chemical plant. / > Wisconsin 3 1. Wisconsin River @ Rhinelander Downstream samples had dioxin and furans 2. Fox River @ Waukesha Good urbanized area with no apparent sources. 3. St. Croix River @ St. Croix Falls (NASQAN) very clean area, past sampling for pesticides, PCB's, etc. shows nothing present. this should be an excellent "p ristine " site 4. Black River @ Black River Falls same as (3) except slig h tly more productive waters (nutrients) LABORATORY SUPPORT FOR REGION V DIOXIN STUDY AND REGION V DIOXIN TASK FORCE ISSUE ISSUE: We are close to fin a lizin g the U.S. EPA Region V/Michigan DNR Dioxins/ Furans and other contaminants study plan. At the present time we do not have a laboratory commitment for the Region V Dioxin study. The April 27, 1983 Memo from Edwin L. Johnson {signed hy Mike Canton) only commits the Bay St. Louis, M ississip p i to reviewing existing data and reviewing the Michigan State University data. It is significant to note that the above mentioned memo does not commit Dr. Harless at RTP (Harless works for William Lacey and Michael Dellarco). In fact, Dellarco informed me on 5/4/83 that he had obtained agreement for both Harless and Dupuy to a ssist Region V in the completion of the existing Dow study only... he is supposed to be sending a memo to this effect. The real immediate concern is to secure a formal written commitment to provide analytical laboratory support for the Region V Dioxins/Furans and other contaminants studies. This commitment is needed immediately or we may end up with a study design and no laboratory support. RECOMMENDATION: Request and obtain formal support from Edwin Johnson and William Lacey, to provide full analytical support to the Region V study with the Bay St. Louis and RTP laboratories (D r.'s Dupuy and Harless). Request will require some reprogramming and contracting out some rather easily contractable work at the M ississip p i laboratory. Sufficient capacity exists at both laboratories to start the Region V study, while the reprogramming is worked out... it is sign ific a n t to note that the reprogramming should be funded and worked out at the Headquarter's level rather than at the Regional level. Finally, it is important to know if we can get RTP and M ississip p i laboratories support as soon as possible. I f th is support is not possible then, we must then start considering other alternatives such as staffing and equipping other U.S. EPA f a c ilit ie s , u tiliza tio n of Argonne National Laboratory, sta ffin g and equipping a CRL fa c ility at Argonne, and contracting out. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY W A S H IN G T O N , D.C. 20460 1I MEMORANDUM PR 2 7 1983 OFFICE O F PESTICIDES AND TOXIC SUBSTANCES TO: Valdas V. Adamkus Regional Administrator SUBJECT: Request for Laboratory and Technical Support From Region V This is in response to your April 1 request for laboratory and other J kinds of technical support from OPP. As you may already know, Dr. Dupuy { 1 traveled to Michigan State University on April 11 to discuss the analytical methods and data developed in Dr. Zabik's laboratory and he plans to continue; to provide consulting services to him, once the balance of data is available. 7 , 7 I f you should decide that the effort is no longer necessary, please le t me know. Because of Dr. Dupuy1s re sp o n sib ilitie s at the Environmental Chemistry Laboratory, his time away from the lab must be limited. I have asked him,^ />K however, to provide you with whatever time he can spare in order to assess. ^ the existing dioxin/furan data bases and to a ssist you in the design of a technically cost-effective study to define the extent of dioxins/furan t contamination in the State of Michigan. ' Within the next few months we w ill begin the FY 84 Program Planning 7 'cycle, and, at that time, we would lik e to give an your need for assistance from Bay St. Louis. That explicit consideration to, should give you su fficie n t; fu \ u time to review the data bases, develop a plan and determine the sp ecific pii,,. kinds of support that you need for your dioxin program. That w ill also give me time to evaluate my own FY 84 laboratory requirements and figure out how r/i > to do some of the urine and blood analyses that.we are committed to perform in relation to the HANES Hispanic health. survey. I would like to point out, **:* I/ v however, that i f we are to do more than the barest dioxin work, we w ill need some sign ifican t help from you in the way of extramural contract d ollars. *>wL, - I f you want to discuss the resource question some more, please call R iiC ti V E L 7 APR 2 91983 /- 7 c '0r' - ' In t h e ^ ie n m T ^ H ^ a r ^ ^ ^ i^ ^ n ly pleased to be able to provide a limited amount o fvdioxin/furan analytical support at Bay St. Louis and B e ltsv ille for emergehcysitnatTorTs'; P^ase-'give me a call on 557-7090 i f you think more discussion is needed. . /) /] Edwin L. Johnson, Director Office of Pesticide Programs (TS-768-C) LABORATORY ISSUES ISSUE #1: The Agency has undergone a major sh ift to Contract laboratory usage. This procedure has resulted in less Federal staff positions being assigned to the Central Regional Laboratory (CRL). In addition, the threat of laboratory consolidation has reduced sta ff morale. The net result of all of the problems has been a loss of some key laboratory expertise. This expertise was unique in that the staff involved were of a high technical capability and in most cases they had several years of experience with the II.S. Environmental Protection Agency (EPA) in the laboratory. The loss of these crucial sta ff has decreased the CRL technical capability to be costeffective in producing high quality data on routine as well as non-routine samples... we can s t i l l produce high quality data but much less and on fewer samples. Finally, on some d iffic u lt and non-routine samples types. We can no longer produce any data due to lack of expertise to address the analytical prohlems. RECOMMENDATION: All identified "Core" positions that become vacant must he fille d via Nationwide recruitment. It is c rit ic a lly necessary to maintain the proper mix of expertise to address analysis quality and quantity and to maintain the capability to handle complex sample analyses. Finally, the balance between contracting out and in-house analyses favors contracting out to the extent that the cost-effectiveness of in-house laboratories is being threatened. The alarm here might not he ju stifie d , were it not for the fact that data quality continues to suffer more as the rate of contracting increases. Contracting out is so extensive that we are starting to notice conflicts of interest hetween the Contract laboratories and industries involved; in addition to contracting out the routine analyses, we1are now starting to contract out the non-routine analyses; and we are contracting out highly visib le enforcement samples (these last two items are inheritly not contractable according to the Congressional A-76 document). There is a need to consider shifting some of these non-routine analyses and highly visib le enforcement work hack into in-house along with the necessary support resources. This shift would assist in re-establishing the balance in in-house laboratory resources along with maintaining the expertise challenge to draw and maintain highly capahle technical staff. ISSUE #2: The Region has an immediate need to commence a Region V/Michigan Dioxins/ Furans and other toxicants studies. Due to the CRL location, like of a positive commitment to use other capable EPA laboratories, and like of an existing contract nr a known capable Contract laboratory, Region V does not have an available laboratory for the pending Dinxins/Furans study. In addition to like of laboratory support, no specific support resources have been identified for FY '83 or FY '84. Finally, further frustration is added to this issue in that Headquarters is now talking about taking two years to start the National Dioxin study. In fact, ORD staff are s t i l l debating which method and how much quality control should he required. -2- RECOMMENDATION: Due to the urgency of the matter, the following alternatives in order of priority are listed: 1. Submit another request to Headquarters requesting the use of the Pesticides Bay St. Louis, M ississippi and RTP laboratories for the entire Region V study. (CRL to coordinate the analytical effort.) 2. Consider having Argonne National Laboratory do the Region V study via the existing Region V/Argonne IAG. 3. Consider expanding the existing partial containment laboratory concept to a full containment laboratory concept at Argonne, purchase equipment, recruit staff and have U.S. EPA staff run the Region V study at Argonne. (This alternative would require interim assistance from an outside laboratory such as Argonne.) 4. Request Headquarters to purchase equipment and staff-up the NEIC and Las Vegas laboratories to do the Region V study as well as the National study. 5. If an adequate laboratory(ies) can be found, use Contractor laboratory resources via the existing VIAR Contract to run the Region V study. SPECIAL NOTE: . Region V potentially has a significant pervasive Dioxins/Furans problem. The immediate problem in Michigan is estimated to only be the "tip of the ice berg". Accordingly, in the short term we need the RTP and M ississippi laboratories for the expediency of the matter. In the long term (1-2 years), Region V needs to seriously consider purchasing the equipment ($500,000-51 ,000,000) and hiring 4-5 technical staff to perform in-house analyses. -3- ISSUE #3: Program staff are currently planning extensive environmental surve\' without any formal planning process (in many cases), CRL input is being omitted or refused, and no input from the Quality Assurance Office (QAO) is being u t i1ized. Planning of sophisticated environr'Mta^ surveys relies on proper objectives setting, proper station se le c ti',n* proper parameter selection, sta tistic a lly valid quality control aud`^s > sample preservations, s p lit samples, proper custody and sample hani!ln9 procedures, analytical support, and data analysis/reporting. The and the QAO (more times than not) are the only Regional entities w i^ the expertise capability to properly design the OC and select the appropriate parameters and attendant analytical methods. When this input is omitted, our experience in the past indicates that entire expensive time consuming surveys can be lost due to incompleteness 'F the data or the CRL must spend exorbitant time trying to bail out t),e defective projects. Often times the bail out time exceeds the time that would have been spent in the f ir s t place. RECOMMENDATION: The Region needs to establish policy, that the Environmental Services Division (ESD) has specific technical responsibility in the design df environmental studies. The QAO has formal review and sign-off respdn" s ib ilit y on all environmental data gathering studies. Due to the technical specificity of custody sample handling, parameter selectidn> and the analytical methodology involved, the CRL needs to participafe in the survey planning process. Furthermore, there most like ly is rf resource discrepancy in th is process... the programs in sistin g on performing services that should be done by the CRL and QAO probably should he allocating resources to the ESD to do this work. Accordingly an appropriate resource reallocation should also he considered with this recommendation. *^ /I Howard Zar Environmental- Scie ntist Donald Sanning, Program Manager Uncontrolled Hazardous Waste Sites, SHWRD-Merl Thru: .David Stringham, Deputy Director Waste Management D ivision Enclosed find a procurement and a Description of the Task Force "Support to Region V Dioxin Study" for implementation under the TMS-3 contract, 68-03-3113. Questions in this matter should be referred to me at .886-1491. cc: G. Amendola, 5SED0 S. Bch, 5W H. Zar, 5WQ P. Redmon, WQP Attachments H. Zar/ww 3/7/84: 6-1491 Fenner Description of Task In implementing EPA's National Dioxin Strategy, Region V w ill undertake a series of investigations, data collection a c tivitie s and analyses to determine the sources and levels of dioxin contamination, and the extent of exposure to the public and w ild life . The National! Strategy envisions a seven tiered approach to the dioxin problem, [focusing on 2, 3, 7, 8 - tetrachlorodibenzo-p-dioxin (2, 3, 7, 8 TCDD), the most toxic of dioxin isomers. Integral to th is strategy are the collection of information on various industrial site s and management of the data received. Data management efforts for the proposed effort are focused primarily in tg ie rs 3 and 6 of the National Strategy, these being: Tier 3 - Sites (and associated disposal site s) where 2, 4, 5, - TCP arid it s derivatives were formulated into pesticide products. r I Tier 6 - Certain organic chemical and pesticide manufacturing f a c ilit ie s where improper quality control may result in the formation of 2, 3, 7, 8 - TCDD. These data management/analyses a c tiv itie s are important pre liminary steps, forming the basis for Regional decisions on site inspections and sampling a c tiv itie s. However, ongoing regional a c tivitie s and investigations severely lim it the resources available for th is important undertaking. Region V is therefore requesting that contractor assistance be made available under the Research and Development Contract on Remedial Measures for Uncontrolled Hazardous Waste Sites. It is essential that persons a ssistin g in th is effort work closely with Region V sta ff and be capable of performing quick response tasks., Specific a c tiv itie s to be undertaken by the contractor include: Meeting,with Region V sta ff to c la rify and confirm the scope of specific tasks Contacting other EPA sta ff to benefit from the ir experience in sim ilar data collection effort - 0 Preparing mailings of the information requests to Identified f a c ilit ie s assembling data resulting from such requests j Developing a data management scheme se nsitive to the ready interpretation of data received Undertaking necessary survey follow-up a c tiv itie s Analyzing and summarizing the data base under Regional Director, providing the necessary documentation for meetings 4 knowledge gained' in both the technical and lo g istic a l aspects of th is effort wi l l be shared with other interested EPA regions We anticipate that Regional activitie s in support of the National Dioxin Strategy wil l continue through FY '8 5 . ; To be successful in th is effort it is essential that adequate personnel are available at the outset, laying a so lid technical foundation for future EPA a c tiv itie s in Meeting with Region V staff to c la rify and confirm the scope of th is highly sensitive area. i i A c tiv itie s will; be specified in writing by the task manager. Outputs w ill be in the form of file s, mailings, data summaries & documentation specified by the task manager. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION V DATE: MAY 3 1 1983 s u b j e c t : Region V Dioxin Research Needs f r o m : Valdas V. Adarrkus Regional Administrator T0: Courtney Riordan Assistant Administrator for Research and Development (W913) As you know, Region V is planning to conduct a major survey for dioxins and other toxic substances as part of a national study during FY'84 and FY185- The regional effort includes analyses of native fish across the region and in the Great Lakes, and an intensive site study at the Dow Chemical-Midland Plant and surrounding areas in Midland, Michigan- This study will be conducted with the Michigan Department of Natural Resources. In order to draw meaningful conclusions from th is work, i t is apparent that additional information and data beyond the scope of these studies must be made available in the near term. S p e c ific a lly , the Agency needs to address the potential for widespread low-level release of PCDDs, PCDFs, and other toxic substances from a range of industrial, u t ilit y , and municipal operations. We are aware that a sign ific a n t amount of work has been initiated in this area (e.g., sampling of coal-fired u t ilit ie s , municipal incinerators, etc.). However, there does not appear to be any .mechanism in place to assemble results from all of those studies, along `with results from additional studies that may be necessary to adequately characterize such releases. We are requesting that th is question be addressed as a national research project. Isomer-specific analyses of PCDDs should be included in ongoing and future studies to the maximum extent possible. We believe the Agency should also fu lly evaluate Dow Chemical's hypothesis that dioxins are formed in virtu ally all combustion processes. This could be accomplished with several straightforward experiments that would include combustion of various materials under controlled conditions such that the feed materials, combustion gases, and residues could be V I roperly analyzed. Again, isomer-specific analyses would be necessary. Fin ally, aside from limited data for native fish, there is v irtu a lly no information regarding the distribution of dioxins within fish , i. e . , concentration in fatty tissue or whole fish vs concentration in standard edible portions. Such information would be helpful in assessing the public health risks of consuming fish from waters with dioxin contamination EPA FORM 1320-6 IREV3-76J **. >