The Workplan for the Remedial
Investigation/Feasibility Study dated July 2001, Sampling and Analysis Plan,
and Quality Assurance Project Plan were received for review. Overall the
project is poorly described, lacking in detail and provides no clear goals.
Toxaphene, the principle contaminant found
in soils in the Terry/Dupree Creek drainages, is on EPA’s list of persistent
Bioaccumulative Toxic Pollutants (PBTs). Despite the fact that this chemical
is internationally recognized as one of the most environmentally dangerous
materials known, this work plan fails to provide any documentation of
testing or analytical methodology, ignores entirely subsurface soil
contamination, proposes qualitative techniques, and ignores important
The Terry Creek drainage is one of the
largest known reservoirs of toxaphene contamination. The studies described
in the RI/FS workplan, SAP and QAPP are inadequate to properly define the
borders of contamination and provide the scientific basis of a cleanup.
Comment 1a: Plan Lacks a
Methodology for Toxaphene Analytical Quality Assurance.
The Quality Assurance Plan is
intended to describe methods for obtaining and testing samples, however,
this plan omits all details of toxaphene analysis despite the assertion that
toxaphene drives both human and environmental risk assessments. Section 2.4
of the QAPP, Analysis and testing procedures, fails to provide any
references to toxaphene testing. Elsewhere in the work plan the Toxaphene
Task Force method is mentioned, however all references to toxaphene analysis
are omitted from the QAPP.
Comment 1b: Note that on
Page 7, Section 2.3.2, third paragraph of Sampling and Analysis Plan states
in part: “[there is] some reasonable indication of the presence of organic
species similar to some of those found in toxaphene, but there is not enough
proof to positively identify this compound as toxaphene in environmental
samples (Black and Veatch 1997).”
The SAP and QAPP omit all documentation of toxaphene testing methods. It
is essential that both the Sampling and Analysis Plan and Quality Assurance
Plan provide documentation of toxaphene methodology.
Comment 2: Page 20, section
2.4 of the QAPP states in the second paragraph: “…for some COPC’s (e.g.
toxaphene), it is known that the analytical detection limits typically
cannot meet the measurement quality objectives (i.e., higher than the EPA
Region IV screening levels).”
How far off are the measurements?
Why are alternative screening methods not provided?
How will the data meet data quality objectives for reproducibility if the
screening levels cannot be reliably met?
Does the scientific literature for toxaphene analysis fully support the
claim that detection limits cannot be met? Or is the detection limit problem
an artifact of Region 4 EPA methodology?
How will the volume estimates in the Feasibility Study be affected?
section on toxaphene analysis and confounders is required for the QAPP to be
Comment 3: In Section 1.4
pages 5 and 6 of the QAPP, the authors state that accuracy of results are
dependent on bias, precision, completeness, representativeness and
comparability. A section needs to be added to the QAPP showing how the
Toxaphene Task Force methodology (TTF )meets these criteria relative
to alternative methods, literature references to toxaphene analysis; other
regions within EPA and International goals for detecting and limiting
Comment 4: Note on page 7,
section 2.3.2 last paragraph: “…100% mortality of amphipods exposed to
sediment from Dupree Creek…” in a NOAA amphipod toxicity test. How are
the NOAA studies different from the ones planned for the Hercules RI/FS?
Amendments to the QAPP are needed, so that the SOP for toxicity tests can be
compared with the literature values.
Comment 5: Plan omits specific
information needed to evaluate quality assurance.
Page 21 of the QAPP states “Samples for
toxaphene analysis will be subjected to sulfuric acid cleanup (EPA Method
3665A: EnChem SOP, Attachment 1A) to remove interferences.” However, a
thorough search of Attachment 1A failed to locate either the SOP or the EPA
Contents of Attachment 1A provided
Guidance for Assessing Chemical
Contaminant Data for use in Fish Advisories, Volume 1 EPA 823-B
Pesticides and PCBs (Semi-volatile
Extraction of Biological Samples; EnChem SVO-60
Extraction of Soil Samples; EnChem 3-SVO-10
of Organochlorine Pesticides by Gas Chromatography; EnChem SVO-51
of PCBs by Gas Chromatography; EnChem SVO-52
Extraction of Soil Samples for Analysis by GC/MS-SIM; EnChem SVO-67
Extraction of Biological Samples for PAHs for Methods 8310 and 8270; EnChem
of Polynuclear Aromatic Hydrocarbons by GC/MS-SIM; EnChem SVO-63
Volatile Organics; EnChem 3-VOA-9
Extraction of biota Samples for Base/Neutral/Acids; EnChem 3-SVO-70
of Semi-volatile (BNA) Compounds by GC/MS; SV)-73
Extraction of Soil Samples for BNA; 3-SVO-4
of BNA by GC/MS; 3-SVO-37
Acid Digestion of
Biota Samples; EnChem MET-59
Acid digestion of soil
samples for Silver, Antimony, and Mercury; EnChem Met-7
ICP Mass Spectroscopy;
Both Toxaphene analytical
methodology and sulfuric acid treatment are specifically omitted from this
plan. The QAPP should be modified to provide complete documentation of the
processing of toxaphene samples.
Comment 6: Plan provides
conflicting toxaphene analytical specification.
Under Attachment 1A SVO-51 we note
Peak retention times for multi-component
analytes are selected to three decimal places (retention time windows,
“The analyst will pick a minimum of three of the
largest peaks for Toxaphene…” based on minimal co-elution (Initial
Calibration, last paragraph).
There are no exceptions to SW-846 Method 8081A
(Exceptions to Methods section).
Comment 6a: How does the
Toxaphene Task Force methodology meet the requirements of peak window
retention time selection criteria stated above?
Comment 6b: Is the TTF
method an “exception” as disallowed above?
Comment 7: Plan fails to
provide information needed for safety of subsurface soils. Section 2.1
of the QAPP fails to provide a regimen for further testing of subsurface
soils. Section 4.2 of the Sampling and Analysis Plan fails to provide a
receptor for subsurface soil impact. Further, page 5, response to comment 7
in the RI/FS workplan states in part: “…subsurface soil (>3 feet) collected
from the Terry Creek Site area will not be considered, as direct exposure
pathways between these media and ecological receptors are lacking.” This
statement is unscientific. Burrowing invertebrates ranging from worms to
arthropods can utilize the marsh subsurface soils at these subsurface depths
and comprise a significant source of prey. Failure to test the subsurface
soils and analyze for effects on the ecosystem is a significant failure of
this plan. Either the plan must provide a testing regimen for the subsurface
soils, or provide scientific documentation that subsurface biota do not
Comment 8:QAPP omits information needed for evaluation of bird, reptile and
mammal investigations. Section 7.5.4 of
the SAP describes goals and locations for small mammals. Corresponding
documentation of the investigation are omitted from the QAPP. Both the SAP
and the QAPP appear to omit a discussion of birds and reptiles, although
they are discussed in the work plan as receptors for this site.
Comment 9: Page 24, Section
126.96.36.199 of the Sampling and Analysis Plan contains a discussion of
background that is extremely vague. Statements that “anthropogic, ubiquitous
chemicals” can be excluded from analysis, or chemicals may be excluded if
they are less than twice the “background” concentration needs to be fully
defined and explained. We could locate no corresponding sections in the
QAPP defining “anthropogic and ubiquitous chemicals.” A section needs to be
added to the QAPP for both anthropogic and ubiquitous chemicals, and COPC
“background” calculations should be defined and the appropriate EPA
Comment 10: Page 51,
Section 188.8.131.52. of the Sampling and Analysis Plan describes modification to
the bio-availability assumptions. The possible bio-availability
modifications are not just vague; they are actually completely lacking. The
authors make an unconvincing argument for less than 100% availability but
fail to cite literature resources or explain how they may calculate uptake.
We could locate no corresponding section in the QAPP discussing algorithms
for modifying bio-availability. A section in the QAPP needs to be added
for modifications to the 100% factor for bio-availability, especially for
toxaphene, including all relevant scientific citations and appropriate EPA
Comment 11: Page 61,
Section 6.1, last paragraph: The authors state that values that cannot be
quantified will be reported as “unlikely,” “possible,” or “probable,” but do
not explain how these semi-quantitative reporting qualifiers will be
determined. This is unscientific and unacceptable. There are no
“pass-fail” parameters in risk estimation. A section needs to be added to
the QAPP defining these parameters, citing relevant EPA guidelines, and
explaining the relationship of each of the qualitative factors affect on
Comment 12: Section 7.4 of
the Sampling and Analysis Plan, inclusive. It is not clear if there are
sufficient test samples since a rationale for choosing sites is not
included. Merely stating that non-dredged areas will be used is
unscientific. Appropriate sampling formulation must be used, referenced
and described in the SAP and QAPP. 100-foot grids are too coarse.
Page 71, Section 7.4.3 of the Sampling and
Analysis Plan. This section on qualitative sediment deposition studies
describes a scientifically unmeritorious set of experiments. Of what
value are “qualitatively evaluated” transport mechanisms? Where is the
description of the proposed laboratory studies on fate? How will the data be
plotted and analyzed? We agree with EPA’s
assertion that these studies are needed. We disagree with the authors
proposed plans as stated. This entire section needs to be revised and
resubmitted as a bona fide quantitatively modeled fate and transport
study. The SAP describes an investigation
of toxaphene transport in Section 7.4.3. This section lists a “qualitative”
evaluation in line 2 last paragraph. However, the QAPP lacks any discussion
of qualitative evaluation, objectives or data treatment. Clearly the plan is
deficient in this regard. In
Section 7.5 of the RI/FS Workplan, the Sediment Deposition studies are
defined as either empirical or qualitative. “Potential” deposition sites are
identified, but not tested. Inferential data for undefined “natural
attenuation indicator parameters” are mentioned but not defined. The
QAPP requires modification to list the techniques to be used and expected
Comment 14: On page 7 of
the RI/FS Workplan in response to Comment 5, the authors state that
toxaphene exposure during dredging is a significant health threat: “It [a
draft Public Health Assessment] mentions that only during periods of
toxaphene production and remedial activities (e.g., dredging) would
exposures to toxaphene occur through the air. We agree with this
conclusion.” [Emphasis added]. The workplan and QAPP need to be
modified to include testing on toxaphene release from dredged soils in order
to evaluate feasibility options for short-term effectiveness.
Comment 15: Page 91 of the
RI/FS discusses the lack of abundance of oysters in Terry/Dupree Creeks. The
authors blame the lack of abundance on “little hard substrate on which to
set.” However, prolific oyster beds are known to occur on similar areas and
the region was historically known for oyster production. Toxaphene
effects cannot be ruled out and should be noted or the paragraph struck from
Comment 16: Page 24 of the
RI/FS Workplan, Section 5.2.2, defines monitored natural attenuation (MNA)
as a potential remedial alternative. How can MNA be considered when the
workplan provides only for a qualitative sediment transport study and
complete omission of the subsurface soils impact? How can MNA meet
standards for short-term and long-term effectiveness when all data collected
is only inferential?
Comment 17: Page 26,
section 5.3.1 of the RI/FS Workplan indicates remedial alternatives included
for the Main Dredge spoil areas are No action, Institutional Controls and
MNA. Why are these considered three different options when they are all
the exact same level of technology? How do these meet the EPA requirements
of treating toxaphene contamination under international considerations as a
Without a description of toxaphene
analysis, without a subsurface investigation, with only a qualitative
sediment transport study, with appropriate environmental receptors
disregarded, and with no rationale for sampling locations given these work
plans fail nearly every test for completeness. No meaningful quantitative
data can be obtained from the studies described in the Work plan, Sampling
and Analysis plan and Quality Assurance Plan.
R. Kevin Pegg, Ph. D.
Mary Starnes Saunders, Ph.D.
"This project has been
funded wholly or partly by the U.S. Environmental Protection Agency under
Assistance Agreement Number
to The Glynn
Environmental Coalition, Inc. The contents of this document do not
necessarily reflect the views and policies of the U.S. Environmental
Protection agency, nor does mention of trade names or commercial products
constitute endorsement or recommendation for use."