#

SDMS Document

110765

INTERIM CLEANUP LEVELS INTERIM REPORT #2

RISK ASSESSMENT REYNOLDS METAL COMPANY

Prepared for

U.S. ENVIRONMENTAL PROTECTION AGENCY Emergency and Remedial Response Division

26 Federal Plaza New York, New York 10278

Work Assignment No.:

EPA Region:

EPA Site/Facility I.D. No.:

Contract No.:

Document No.:

Alliance Project No.:

Alliance Project Manager:

Telephone No.:

Subcontractor No.:

Subcontractor Project Manager:

Telephone No.:

EPA Work Assignment Manager:

Telephone No.:

Date Prepared:

C02082

n NYD002245964

68-W9-0003 (TES 6)

NY-082.PA1

1-635-236-0-2P4D

Naida Gavrelis

(508) 970-5600

N/A

N/A

N/A

Lisa Carson

(212) 264-6857

September 4, 1991

ATTTANCE TECHNOLOGIES CORPORATION 291 Broadway, Suite 1206

New York, NY 10007 / m i x 1Al\ ACMi

o o

O

RECYCLED PAPER A ALUANCE TecnnoO^es Corporaiion

• 1 ' ^ »

#

TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION 3

2.0 BACKGROUND 3

3.0 METHODOLOGY FOR ESTABUSHING CLEANUP LEVELS 4

4.0 RESULTS 7

5.0 DISCUSSION 13

6.0 COMPARISON WITH OTHER PCB CRITERIA . 16

REFERENCES 18

•

73

m

o o

o o en

m NY-082.PA1

RECYCLED PAPER A ALUAIMCE Tecnnoio^es Corporation

*!?'

m

m

1.0 INTRODUCTION

Alliance Technologies Corporation (Alliance) imder Work Assignment C02082 of

EPA Contract 68-W9-0003 (TES 6) was requested to derive human health risk-

based interim cleanup levels for PCB-contaminated sediments in the St. Lawrence

River adjacent to the Reynolds Metal Company (Reynolds) site in Massena, New

York. The method to derive risk based cleanup levels, the values derived, and

the uncertainties used are described below.

2.0 BACKGROUND

Target cleanup levels (preliminary remediation goals) are established to provide

levels of contaminants of concern in affected media that will be protective of

human health and the environment. They are calculated using the mediimi-

specific target risk range of 10" and 10"* established by the National Contingency

Plan. At the Reynolds site, PCBs (polychlorinated biphenyls) in sediments are the

contaminants of primary concern. PCBs were routinely used by Reynolds in their

production process and have been detected in sediments in the St. Lawrence

River adjacent to the Reynolds site at concentrations ranging from not detected

(ND) to 550,000 Mg/kg. Area residents may be exposed to sediments directly by

dermal contact or incidental ingestion. However, the greatest potential risk

resulting from human exposure to PCBs in the vicinity of the Reynolds site is

likely to be via the ingestion of PCB-contaminated fish. Total PCB concentrations

ranging from ND to 81,490 /ig/kg have been detected in fish collected in the St.

Lawrence and Raquette Rivers.

Two general groups, the Mohawk native population and recreational fishermen,

fish in the vicinity of the Reynolds site. The Mohawk Nation reservation is o

o C O .

NY-082.PA1 3 :

X)

-<

RECYCLED PAPER

JSk ALUAIMCE Tecnnoto^es Corooration

e

#

#

-<

o K)

OD

•

located on the St. Lawrence River 0.7 miles north of Reynolds on Cornwall Island

and 1.1 miles downstream at Raquette Point. Locally caught fish comprise a large

portion of the nearby Mohawk Nation population's diet Preferred species

include: northern pike, yellow perch, small mouth bass, bullhead, catfish,

sturgeon, and walleye pike (Jock, 1991). Recreational fishing in the lower reaches

of the St. Lawrence River (where Reynolds is located) is dominated by local

residents; 63 percent of the anglers in 1982 were from St. Lawrence County

(McCuUough, 1987). Canadian anglers were the largest group of non-New York

State anglers (comprising 10%) in this area of the St. Lawrence (McCullough,

1987). The preferred fish species among recreational anglers in both 1982 (in

American waters) and 1985 (in Canadian waters) were reported as: yellow perch,

northern pike and small mouth bass. Other preferred species included large

mouth bass and rock bass (McCullough, 1987 and Hart, 1986). The target

cleanup level analysis focused on fish species preferred by the Mohawk Nation

population because of its heavy consujnption of locally-caught fish. These fish

species are also the preferred species of recreational anglers.

3.0 METHODOLOGY FOR ESTABLISHING CLEANUP LEVELS

Data on PCB concentrations in fish tissue were obtained firom a study conducted

by the New York State Department of Environmental Conservation (NYSDEC)

and the St. Regis Mohawk Tribe Environmental Programs (Sloan and Jock, 1990).

These data were collected as part of a health risk assessment for the nearby GM

Foundry site. Data on PCB concentrations in sediments were obtained from the

Additional River Sampling Report (Woodward-ayde, 1991). This report presents

^ the findings of the investigation of the extent of contamination in the sediment

and surface water in the St. Lawrence and Raquette Rivers in the vicinity of the

o Reynolds site.

^ NY-082.PA1

RECYCLED PAPER

ALLIANCE TecnnoBgies Coooranon

#

m

Fish and sediment samples were analyzed for several different Aroclor mixtures.

PCB concentrations in fish were reported by NYSDEC as Aroclor 1221, 1016, and

1254, but Ukely include other Aroclor such as 1248 and 1260. PCB concentrations

in sediment were reported as Aroclor 1016, 1221, 1232, 1242, 1248, 1254, and

1260. Reported mixture-specific PCB concentrations were summed to produce

separate total PCB values for fish and sediment, which were used throughout this

analysis. The technique of summing reported PCB values should result in

comparable total PCB concentrations, exclusive of differences in the mixtures

reported by laboratory analysis.

In order to derive a risk-based sediment cleanup level it was first necessary to

estimate the PCB concentration in fish tissue which would produce a carcinogenic

risk within the NCP target range (10^ to 10"*). Consistent with EPA risk

assessment guidance (1989 and 1991) and available site-specific information, the

following equation and exposure peirameters were used to back-calculate from

target risk levels to PCB concentration in fish:

(1) PCB Concentration = Risk x BW x AT x CF in Fish Tissue (/ig/kg) CSF x IR x H x EF x ED

where: BW = Body weight = 70 kg AT = Averaging time = 25550 days CF = Conversion factor = 1 x lO' Mg/nig CSF = Cancer slope factor for PCBs = 7.7 (mg/kg/day)-^ IR = Ingestion rate = 0.132 kg/day FI = Fraction ingested from contaminated source =

1 (unitless) EF = Exposure frequency = 350 days/yr ED = Ejqwsure duration = 70 years

In order to relate these PCB concentrations in fish tissue to concentrations in

sediment, it was necessary to derive sediment-based bioaccumulation factors (fish

NY-082J'A1

X) m -<

o o

RECYCLED PAPER O CO

ALLIANCE ^ Tecnnotogies Corporaton A

f

to sediment concentration ratios). Bioaccumulation factors (BAFs) were derived

using the following equation:

(2) BAF = £f

A Reynolds site-specific BAF was calculated using:

(a) Cf = The maximimi total PCB concentration in fish (carp) caught

immediately adjacent to Reynolds site outfalls, and

Cj = Arithmetic mean total PCB concentration in area 3B (area adjacent

to Reynolds site outfall)

In an effort to provide a context for the above BAF and utilize a larger data set,

two area-wide BAFs were also calculated using:

(b) Cf = Arithmetic mean total PCB concentration in aU preferred fish species caught throughout the St. Lawrence River System, and

Cj = Arithmetic mean total PCB concentration in all sediment samples collected near the Reynolds site.

and

(c) Cf = Maximum total PCB concentration in preferred fish species, excluding fish caught in the area in front of GM (another source of PCBs along the St. Lawrence River). The maximum PCB concentration was reported in channel catfish caught at the mouth of the Grass River, approximately 0.9 mile upstream of Reynolds.

Cj = Arithmetic mean total PCB concentration in ail sediment samples collected near the Reynolds site.

NY-082J»A1

RECYCLED PAPER

^ ^ ^ 002 0849

A A ALLIANCE

#

The rationale for these three BAF scenarios is presented in the discussion section

below (Section 5.0).

Sediment cleanup levels were derived based on calculated BAFs using the

following equation:

(3)

where

Cf

BAF =

Q = £f BAF

concentration of PCBs in sediment producing an increased carcinogenic risk of 10" and 10"* to hmnans based on consumption of fish which may have fed in areas with contaminated sediment

concentration of PCBs in fish tissue producing an increased carcinogenic risk of 10"* and 10"* to humans consuming fish.

Bioaccumulation factor as previously described.

4.0 RESULTS

Table 1 presents the spreadsheet used to calculate PCB concentrations in fish

tissue that would result in a 10^ and 10"* carcinogenic risk.

Mean total PCB concentrations calculated for fish and sediments are presented in

Table 2. Calculated mean PCB concentrations in fish tissue range from 1,780 to

46,845 Mg/kg. Calculated mean PCB concentrations in sediment were 93,184 and

184,418 /ig/kg.

•

The calculated BAFs (Table 3) range from 0.02, when PCB concentrations in

preferred fish species and aU sediments are used, to 0.5, when the maximtmi PCB ^ -<

NY-082J>A1

RECYCLED PAPER

w^^w^

O o

O 00 01

ALUANCE ^ Tecrmoio^es Cofoofanon

t

concentration in fish and all sediments are used. When fish and sediment near

Reynolds are used, the BAF is 03.

At the 10"* risk level, sediment cleanup levels (Table 4) range from 0.2 MgA&

using maximum PCB concentration in fish and all data for PCB concentration in

sediment, to 4 jug/kg, using PCB concentration in all preferred species and all

data for PCB concentration in sediments. When PCB concentrations in carp and

sediments collected near Reynolds are used to calculate BAFs, calculated

sediment cleanup levels are 03. At the 10^ risk level, these cleanup levels

increase to 20, 400, and 30 Mg/kg, respectively.

#

NY-^mJAl

RECYCLED PAPER

8 REY 002 0 8 5 1

ALLIANCE Tecrmoio^es CoroofaJon

#

TABLE 1. PCB CONCENTRATIONS IN FISH TISSUE BACK-CALCULATED FROM INCREASED CANCER RISKS.

Exposure Scenario

Local Resident

Contaminant of Concern

PCBs

Increrased Cancer

FBsk

1.00E-06

1.00E-04

Concentratton ihRsh {ugfl«g}

0.072

7.182

NY-082J'A1

RECYCLED PAPER

o o

o CD Cn

jSbi ALLIANCE Tacnndo^es Cofooranon

TABLE 2. MEAN PCB CONCENTRATIONS IN FISH AND SEDIMENTS NEAR REYNOLDS

#

#

#

RSHr Maximum PCB Concentrations in Carp Caught in Area 3B (Upstream of Reynolds);

AR-1248 AR-1254

, AR-1260

TOTAL

Mean PCB Concentrations in Preferred Species:

AR-1016 AR-1221 AR-1254

TOTAL

liiiliiiiiiiilii _ . ^ . , „ . - . . . . . . . . • _

19000.00 ug/kg 25000.00 ug/kg

4400.00 ug/kg

48400.00 ug/kg

573.096 ug/kg 30.88 ug/kg

1176.10 ug/kg

1780.07 ug/kg

Maximum PCB Concentrations in Channel Catfish Caught Near the Mouth of the Grass River (Upstream of Reynolds):

AR-1016 AR-1221 AR-1254

TOTAL SEDIMENTS:.

Mean PCB Concentrations in Sediments from Area 3B:

AR-1242 AR-1221 AR-1016 AR-1248 AR-1254 AR-1260

TOTAL

Mean PCB Concentrations in Sediments from All Areas:

AR-1260 AR-1248 AR-1242 Afl-1232 AR-1254 AR-1221 AR-1016

TOTAL

2030.00 ug/kg 25.00 ug/kg

44790.00 ug/kg

46845.00 ug/kg

iBiliiiiiiiiiiii

48916.23 ug/kg 19685.00 ug/kg 19280.79 ug/kg 19532.37 ug/kg 38551.05 ug/kg 38452.28 ug/kg

184417.72 ug/kg

19549.63 ug/kg 9960.69 ug/kg

24148.89 ug/kg 70.00 ug/kg

19606.50 ug/kg 10033.77 ug/kg 9814.59 ug/kg

93184.07 ug/kg

i l i i i l p i -- - •

lllpii

rn -<

o o

O CO

NY-082.PA1

RECYCLED PAPER

10 CO

ALLIANCE Tecnnoioses Corporaton

#

TABLE 3. BIOACCUMULATION FACTOR CALCULATIONS

m

RshType

Carp from Area 3B:

Preferred Species:

Channel Catfish:

PCB Cone. (Cf}

(ugflcg>* 48400.00

1780.07

46840.00

Sediment Area

Area 3B:

All Areas:

All Areas:

PCB Cone. <Cs>

184417.72

93184.07

93184.07

| | | | | | B | | | | | i | :

0.019

0.503

see Table 2.

NY-082J'A1

RECYCLED PAPER

11

7) m

o o

o OD 0 1

JSk ALLIANCE Tecnnolo^es CorDoraoon

TABLE 4. SEDIMENT CLEAN-UP LEVELS

•

Sediment Clean-Up Levels for Area 38 Based on Carp BAF in Area 3B: increased

Cancer Risk

1.OOE-06

1.00E-04 •

; Backcalculated BAF** Fish Cone,

(ugflcg)-0.084 0.262

8.379 0.262

i Sediment Clean-Up

Level (ug/kg) 0.3

30 Sediment Clean-Up Levels for All Areas Based on Preferred Species BAF in All Areas:

Increased Cancer

Risk

1 .OOE-06

1.00E-04

Backcafculated BAF-* Rsh Cone,

(ug/kg)-0.084 0.019

8.379 0.019

Sediment Cfean-Up

Level (ug/kg) 4

400 Sediment Clean-Up Levels for All Areas Based on Channel Catfish BAF in All Areas:

Increased 1 Cancer

Risk 1.OOE-06

1.00E-04

Backcalculated BAF** Rsh Cone,

(ugfl^g)* 0.084 0.503

8.379 0.503

Sediment Clean-Up

Level (ug/kg)

0.1

10

9 * see Table 1. * * see Table 3.

73 m <

o o

O CO

#

NY-082.PA1

RECYCLED PAPER

12

ALLIANCE Tecnnotoges Cotpof anon

•

5.0 DISCUSSION

Site-specific BAFs were estimated using available data on PCB concentrations in

both fish and sediment collected near the Reynolds site. Models exist that

estimate contaminant concentrations in the water colmnn based on concentrations

in sediment or that estimate contaminant concentrations in fish based on

concentrations in the water column (e.g., EXAMS/WASP4, and SGETS).

However, for this analysis a site-specific BAF was calculated because it is believed

that this method would produce a more realistic site-specific estimate of PCBs in

sediments. This decision was made based on consultation with the EPA WAM

and an evaluation of the benefits and limitations of existing models.

Since the BAFs derived for the purpose of calculating cleanup levels are the

driving force in the final calculation, a more detailed discussion on the rationale

behind the selection of the equation parameters is warranted. Equation 2a uses

the maximum total PCB concentration measured in carp caught immediately

adjacent to Reynolds and sediments in area 3b (the Reynolds outfall) to calculate

a Reynolds-specific BAF. The maximvun total PCB concentration was used

because of the limited number (two) of samples available. While carp is not a

preferred species for local consumption, it may provide a conservative

approximation of PCB concentrations in preferred fish species exposed to PCB-

contaminated sediments resulting from the Reynolds site. Carp have a limited

home range (Sloan and Jock, 1990). Therefore, carp collected adjacent to

Reynolds outfalls are likely to have been exposed to contaminants arising fi-om

these outfalls, although they are unlikely to have fed exclusively on these

sediments. Carp also have a relatively high fat content and since there is a

positive association between fat content and PCB concentration (Sloan and Jock,

1990), PCB concentrations in carp may be at the high end of the range found in

NY-082.PA1 13

RECYCLED PAPER

73 m <

o o ro

A ALLIANCE Tecnnocgies Corpocaipon

o CD

0^

•

73

-<

all fish. However, whether the PCB concentrations found in the carp sampled are

representative of PCB concentrations foimd in all fish exposed to Reynolds- -

contaminated sediments is imcertain because of the small number (n = 2) of fish

sampled. Small samples do not necessarily provide an accurate estimate of

patterns in the entire population, j - r ; - - : ,5 - :: . n:; ::\.uy.

Two area wide BAFs were calculated in an effort to provide a context for the

Reynolds-specific BAF calculated. The first set of area wide Cj and C values

(Equation 2b) was used to approximate an average BAF for commonly consumed

fish species in the St. Lawrence River System that could have potentially

consumed sediments contaminated by PCBs from Reynolds. Selecting only

preferred fish species reflects likely exposure to local populations. Fish collected

at all locations were included here because fish are mobile and even those caught

8 miles upstream or downstream fi-om the Reynolds site could have consxmaed

site-related contaminants via sediments or biota. The mean total PCB

concentration for preferred fish species was used to represent a river-wide average

condition. While it is recognized that fish vary in typical mobility patterns (Sloan

and Jock, 1990), mobility patterns for a given fish species can change with season

and habitat (Sloan, 1991); Therefore elimination of data from fish typically having

a "restricted home range" seemed unwarranted, especially when balanced against

the disadvantage of decreasing already small sample sizes. Likewise, use of data

for all available sediment samples collected near the Reynolds site fi-om WCC

(1991), rather than those for only highly contaminated sediments was assumed to

better represent the conditions to which fish in the St. Lawrence River System are

actually exposed.

rn I The second set of area wide Cf and C values (Equation 2c) was used to calculate

a BAF based on the highest level of contamination (total PCBs) reported for fish o o

O NY-082.PA1 14 CD i j \

^ RECYCLED PAPER

0 A AUIANCE Techneogies Corcioration

#

#

•

tiiat could have potentially consumed sediments contaminated by PCBs from the

Reynolds site and that were collected outside the immediate vicinity of the GM

plant. A maximmn was selected to represent a potential worst case. Once again,

all available sediment data from WCC (1991) were used in deriving Cj.

The cleanup levels presented in this report are, of necessity, based on limited data

sets and a number of underlying assimiptions regarding these data. While PCB

concentrations in carp and sediment collected adjacent to the Reynolds site

represent the most site-specific data available, uncertainty in the cleanup level

estimate results from: (1) the small number of carp sampled; (2) the possibility

that fish collected near Reynolds are feeding on sediments (and biota) from a

variety of areas within the St. Lawrence River System, including uncontaminated

areas and areas contaminated with PCBs from other sources (e.g., GM and

Alcoa); (3) the unknown relative contribution of the Reynolds site to PCBs

throughout the area of the St. Lawrence River System from which fish were

collected; (4) the possibility that the relative concentrations of PCBs in fish and

sediment have changed over time, as fish and sediment samples were not

collected concurrentiy; and (5) the possibility that contaminant concentrations in

carp do not accurately reflect contaminant concentrations in commonly consimaed

fish species due to differences among species in lipid content, mobility, and

feeding habits.

Many of the same limitations apply to data used to calculate cleanup levels based

on area-wide BAFs. Contaminant concentrations in sediments are highly

heterogeneous within the home range of any given fish species. This

heterogeneity limits direct linkage between contaminant concentrations in

sediments in a given area and contaminant concentration in fish tissues. Caging

fish and their prey in an area of known sediment contaminant concentrations may 73

NY-082.PA1 15 g

RECYCLED PAPER O

A ALUANCE § M ^ m k Tecnnonges Corporation w

VK-

#

be the one way to obtain direct correspondence between these two data types. A

further consideration is the trophic level of the fish involved. Since PCB

concentrations would tend to increase in fish at higher trophic levels, the trophic

level of the species used as a model is likely to impact the BAFs calculated.

6.0 COMPARISON WITH OTHER PCB CRITERIA

As a basis of comparison, interim sediment criteria developed by U.S. EPA and

New York State are presented below . The U.S. EPA (1988) has developed an

interim sediment criterion for PCBs based on Aroclor 1242. Since the capacity

for sediments to retain PCBs increases with increasing organic carbon content of

the sediment, the sediment criteria are calculated based on the organic carbon

content of the sediment. The 95% confidence interval of criteria designed to be

protective for the consumption of aquatic biota ranges from 38.7 to 999 Mg/kg

(with a mean of 195 Mg/kg) for sediment with an organic carbon content of 1%

and 387 to 9990 Mg/kg (with a mean of 1950 Mg/kg) for sediment with an organic

carbon content of 10%. Sediments in the SL Lawrence River are likely to have

an organic carbon content between 0 and 10 percent based on experience at other

sites and professional judgment. Confidence intervals are given to emphasize the

uncertainty in the calculation of these values. This criterion was calculated using

the equilibrium-partitioning approach and a Food and Drug Administration

(FDA) action level of 5000 Mg/kg. Since its development, the FDA action level

has been lowered to 2000 Mg/kg. Furthermore, bioaccumulation within the food

chain is not accounted for in the calculation of BAFs used in the development of

this criterion. It is estimated that bioaccumulation in the food chain may result in

— BAFs ten times greater than laboratory measured BAFs (EPA 1988). Also,

^ different PCB congeners vary in their toxicity, accumulation, and metabolism, -<

adding additional imcertainty to these values (EPA 1990).

•

o o

O NY^2J'A1 16 03 cn vO RECYCLED PAPER

ALLIANCE TechrK*3S«s Corporation

#

•

•

New York State has developed ±eir own guidance sediment criteria (NYSDEC,

1989), using both an equilibrium-partitioning approach and a bioaccumulation

approach. When an equilibrium-partitioning approach was used (based on a

proposed ambient water quality standard of 6 x 10^ Mg/1), tiie sediment criteria

assuming 1% organic carbon is 0.08 Mg/kg and assuming 3% organic carbon is

0.24 Mg/kg. This criterion is based on a lO"* cancer risk from fish consiunption.

The NYS criterion is lower than the EPA value derived by the same method

because:. (1) the water quality criterion used by EPA was derived from a BAF

lower than beUeved to be reaUstic by NYS, and (2) the fish flesh criterion used by

EPA for wildlife is lower than beUeved prudent by NYS (NYS 1989). NYS used

a second approach, the bioaccumulation approach, to calculate a criterion for

PCBs. Using this approach and assuming an edible fillet with 3% lipid and

sediment with 3% organic carbon, the sediment criterion range calculated for

PCBs is 0.6 to 0.06 Mg/kg. These values were calculated assuming a 10" cancer

risk, 0.5 pound per week fish consumption, and sediment to fish accumulation

factors ranging from 1 to 10.

The sediment cleanup values presented in this report fall within the range of

criteria developed by the U.S. EPA and NYS; however this is a very broad range

spanning five orders of magnitude, depending on the method used and initial

assumptions.

73 m -<

o o

o CO

NY-082.PA1 17 °

RECYCLED PAPER

ALLIANCE Tecrvx»g«es Cor poraton

c

#

0:

•

•

REFERENCES

Hart, M.L. 1986. St. Lawrence River Summer Creel Census, 1986. Ontario Ministry of Natural Resources.

Jock, K, 1991. St. Regis Mohawk Tribe Environmental Programs. Personal communication with Naida Gavrehs, Alliance Technologies Corporation.

McCullough, R.D. 1987. The Summer Boat Fishery of the St. Lawrence River, 1982. NYS DEC, 1987 St. Lawrence River Subconunittee Report, Great Lakes Fishery Commission.

NYSDEC. 1989. Sediment Criteria. Bureau of Environmental Protection, Division of Fish and Wildlife.

Sloan, RJ. 1991. NYS Department of Environmental Conservation. Personal communication with Dolores Savignano, Alliance Technologies Corporation.

Sloan, R J . and K. Jock. 1990. Chemical Contaminants in Fish from the St. Lawrence River Drainage on Lands of the Mohawk Nation at Akwesasne and Near the General Motors Corporation Central Foundry Division Massena, New York Plant. NYSDEC Technical Report 90-1 (BEP) Division of Fish and Wildlife, 96 pp.

U.S. EPA, 1989. Risk Assessment Guidance for Superfund, Volume I and IL Office of Emergency and Remedial Response.

U.S. EPA, 1991. Risk Assessment Guidance for Superfund, Volume I, Supplemental Guidance: Standard Default Exposure Factors, Interim Final Office of Emergency and Remedial Response.

U.S. EPA- 1990. Guidance on Remedial Actions for Superfund Sites with PCB Contamination. Office of Emergency and Remedial Response, EPA/540/G-90/007.

U.S. EPA. 1988. Interim Sediment Criteria Values for Nonpolar Hydrophobic Organic Contaminants. Office of Water Regulations and Standards, Criteria and Standards Division.

Woodward-Clyde Consultants. 1991. Draft Additional River Sampling Report: St. Lawrence River System, prepared for Reynold Metals Company, Massena, NY.

NY-082.PA1 18

RECYCLED PAPER

X! m -<

o o

o CD

A ALLIANCE Tecnnotoges Corporaiion