£ A \\mj UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

JAN 5

REGION VII726 MINNESOTA AVENUE

KANSAS CITY, KANSAS 66101

Mr. Marshall Sonksen Staff Environmental Engineer Aluminum Company of America P.0. BOX 3567 Davenport, Iowa 52808

Dear Mr. Sonksen:

137519

Superfund

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RE: Section VI-B of the Administrative Order on Consent,Docket No. 90-F-0027; Mississippi River Pool 15 Fish Sampling and Analysis Investigation and Study

This letter is to notify the Aluminum Company of America (Alcoa) that the U.S. Environmental Protection Agency (EPA) has completed its review of the September 29, 1993, document, Interim Fish Sampling Program Development, Mississippi River Pool 15.The document was reviewed to evaluate whether the statistical review of past data presented in the document justifies collection of only carp at Sites 2, 3 and 4 to meet current project objectives. The EPA does not agree with Alcoa's conclusion that the objective, as stated in Section VI-B of the 1990 Administrative Order on Consent, Docket No. 90-F-0027 (1990 AOC) , can be met by this reduced level of sampling.

While the statistical procedures utilized in the document are acceptable, it is necessary to evaluate previous fish studies from a practical viewpoint rather than just a statistical approach if the objectives of the 1990 AOC are to be satisfied. The intent of Mississippi River Pool 15 Fish Sampling and Analysis Investigation and Study was to conduct biennial fish studies to determine the need to continue or expand current advisories, to evaluate the risk to public health or welfare or the environment, and to determine if response actions for Pool 15 are necessary. After considering the objectives of the 1990 AOC, previous fish studies, Alcoa's Interim Fish Sampling Program Development for Mississippi River Pool 15, and the enclosed responses to Alcoa's Interim Fish Sampling Program Development for Mississippi River Pool 15 received from the Iowa Department of Natural Resources (IDNR), U.S. Fish and Wildlife Service (USFWS) , U.S. Food and Drug Administration (FDA), and Illinois Environmental Protection Agency (I11EPA) , EPA has determined that the 1994 Fish Study must include the following:

e Collection of common carp, river carpsucker, and channel catfish due to the existing fish consumption advisories for these three species.

RECYCLE^

• Maintain four sampling sites; sites 2, 3, and 4 on the Iowa side of the Mississippi River and a downstream location on the Illinois side, approximately at site 1 from the 1990 fish study.

• Collection of at least ten fish from each of the three species at each sampling site.

• Documented field observations (identification, location, and approximate size) of the other species listed in the 1990 AOC (flathead catfish, shovelnose sturgeon, smallmouth buffalo, and freshwater drum) that are encountered during the 1994 Fish Study.

The EPA also requests that documented field observations be made of the presence of the following host fishes for the Higgins' eye pearly mussel, Lamnsilis hiaginsi; largemouth bass, smallmouth bass, walleye, sauger, yellow perch, green sunfish, bluegill, and northern pike.

Also enclosed are EPA's technical review comments on the Interim Fish Sampling Program Development for Mississippi River Pool 15. Submittal of a revised Interim Fish Sampling Program Development for Mississippi River Pool 15 is not required, however any subsequent fish sampling plans and/or fish study reports must provide the appropriate clarification and/or address the inaccuracies cited in these comments.

As you are aware, the 1994 Fish Sampling Plan is due 30 days from Alcoa's receipt of this letter. If you have any questions, please contact me at (913) 551-7489.

Enclosures

cc: Dick Swanson, FDA (w/ comments)John Olsen, IDNR (w/ comments)Jody Millar, USFWS (w/ comments)Tom Long, Illinois DPH (w/ comments)Tom Homshaw, Illinois EPA (w/ comments) Marion Conover, IDNR Fisheries (w/ comments)

Sincerely,

James ColbertRemedial Enforcement SectionSuperfund BranchWaste Management Division

1

TECHNICAL REVIEW COMMENTS ON ALCOA DOCUMENT INTERIM FISH SAMPLING PROGRAM DEVELOPMENT

MISSISSIPPI RIVER POOL NO. 15 SEPTEMBER 29, 1993

Executive fliunmarv. page 1-1. The first paragraph states that

the data were collected during 1988, 1990, and 1992 in accordance

with the United States Environmental Protection Agency's (EPA)

stipulations in a 1990 Administrative Order on Consent, Docket No.

90-F-0027 (1990 AOC) between Alcoa and EPA. The 1988 fish study

was conducted before the 1990 AOC was drafted. Therefore, it is

incorrect to state that data from 1988 were collected in accordance

with the AOC.

2. Executive summaryf page 1-2. The first bullet on this page

states that the upper 95 percent confidence intervals (95 UCI) of

the mean for channel catfish and freshwater drum were below 2 mg/kg

at all sites during each of the three years. This statement is not

true. For example, at Site 3 in 1990, according to the data in

Appendix A, seven drum were collected with a mean total PCB

concentration of 2.63 mg/kg. This mean concentration was

calculated by summing detected concentrations for Aroclors 1248,

1254, and 1260 (or the detection limit) plus half the detection

limit for Aroclors 1016, 1221, 1232, and 1242.

Fish Sample No. Total PCBs Mean PCBs for Sample

3-FWD-01-101690 12.32 13.49

3-FWD-01-101690(rep) 14.66

1

3-FWD-02-101690 1.84 1.84

3—FWD-03-101690 .50 .50

3—FWD-04-101690 .90 .90

3-FWD-05-101690 .65 .60

3-FWD-05-101690(rep) .54

3—FWD-06-101690 .59 .59

3-FWD-07-101690 .50 .50

3-FWD-07-101690(rep) .50

The second bullet on this page states that the 95 percent UCI of

the mean for freshwater drum was below 1.0 mg/kg during each of the

three years. It is not clear if this is the mean of all drum from

all sites or the individual means from drum at each site. The

statement must be clarified. Also, as stated above, the mean

total PCB concentration for drum was greater than 2.0 mg/kg at some

sites.

The third bullet on this page states that common carp had

statistically higher tissue PCB concentrations than all other

species at Sites 2 and 3 and for Sites 2, 3, and 4 combined. If

these comparisons were only performed for species with more than

ten individuals at a given site, this must be stated. The

statement must be reworded so that it is clear which data were used

in each calculation.

2

3. Section 2.0 Introduction, page 2-1. See Comment No. 1

concerning the 1990 AOC.

4. Section 3.0 Description of Data, page 3-1. The third

paragraph states that total PCB concentrations were calculated as

the sum of individual Aroclors in the 1988 study. A review of the

1988 final report, An Assessment of PCB Concentration in Fish,

shows that only Aroclor 1248 data were used to calculate total

PCBs, and this total PCB concentration was used in calculating mean

and 95 percent UCIs. Total PCB concentrations should be

recalculated for all three study years using the same formula. The

total PCB concentration should be calculated by summing detected

concentrations for Aroclors 1248, 1254, and 1260 (or the detection

limit) plus half the detection limit for Aroclors 1016, 1221, 1232,

and 1242.

5. Section 3.0. Description of Data, page 3-1. The fourth

paragraph on this page states that during 1992, Sites 2, 3, 4 and

5 remained the same as in 1990. However, in an attempt to collect

all target species, these sites were extended further into the

river for the 1992 fish study. Hoop nets were set further from the

shore in deeper, faster water. In addition to collecting some

additional target species, some members of species that were

previously collected near the shore, were collected further into

the channel. A comparison of PCB concentrations of fish collected

near the shore with fish collected further from the shore indicated

3

that the location where fish were collected may impact the total

PCB concentration. A review of data from the 1992 sampling event

indicates that PCB concentrations in bottom feeders that were

collected further from the shore were lower than PCB concentrations

in fish collected near the shore. In order to more conservatively

estimate the PCB concentrations in fish, future fish sampling

programs should concentrate on collecting fish near the shore using

electrofish techniques rather than collecting fish further from the

shore with hoop nets, gill nets, and trammel nets. In addition,

Alcoa's costs associated with the 1994 fish study should be reduced

if the required number of individual fish (10) for the three

species (common carp, river carpsucker, channel catfish) can be

collected using only electrofishing techniques. The discussion of

differences between the 1988, 1990, and 1992 sampling events must

also include the different sampling strategies used during the

1988, 1990, and 1992 studies and the potential or known impact

these differences have had on the data collected.

In the description of data, it must also be noted that sampling

events were conducted at different times of the year. This

discussion should include the potential impact on total PCB

concentrations of collecting fish in July versus November or

October. The impact of time of year should also be discussed in

terms of species collected and number of individuals of a species

collected.

4

6. Section 4.0 Data Analyses, page 4-1. The first paragraph

states that data are summarized in Appendix A. In order to compare

PCB concentrations across sampling events PCB concentrations must

be calculated in a consistent manner. There are other confounding

factors influencing the ability to compare the sampling events, so

every effort should be made to increase the comparability of data.

Total PCB concentrations should be calculated by summing detected

concentrations for Aroclors 1248, 1254, and 1260 (or the detection

limit) plus half the detection limit for Aroclors 1016, 1221, 1232,

and 1242. It also appears that some data were mistranscribed from

the 1988 report into Appendix A. For example, the data for Sample

No. 256 in Appendix A indicate concentrations for Aroclors 1016,

1221, 1232, 1242, 1254, and 1260 of less than 0.1 mg/kg. The data

in the 1988 fish report show the concentration of these Aroclors

are less than 1.0 mg/kg, not 0.1 mg/kg. The data in Appendix A

must be verified and total PCB concentrations recalculated.

7. Section 4.0 Data Analyses, page 4-1. The first and second

bullets state that freshwater drum PCB concentrations were below 2

and/or 1 mg/kg for all three sample events. As stated in Comment

No. 2, at some sites mean PCB concentrations in drum were greater

than 2.0 mg/kg. These statements must corrected to reflect the

data accurately.

Bullet No. 3 concludes that there appears to be a general decrease

in tissue PCB concentrations in common carp at Site 3 from 1988 to

5

1992. Since total PCB concentrations were calculated by different

methods in the three reports, this conclusion must be re-evaluated

after recalculating the data by the method stated in Comment No. 6.

Bullet No. 4 states that insufficient river carpsucker were

collected for analysis (EPA assumes Alcoa means statistical

analysis) during 1988. Even though 10 river carpsucker were not

collected at an individual Site, nine carpsucker were collected at

Site 2 in 1988 and this data must be considered when assessing PCB

contamination in MRP15. The mean total PCB concentration of eight

of these fish (the data for the ninth fish could not be located in

the 1988 report) is 23.6 mg/kg. This bullet further states that

PCB concentrations were lower in 1992 than in 1990 for river

carpsucker. When making this comparison it should be noted that 72

out of a total of 74 river carpsucker sampled in 1990 were

collected by electrofishing, near the shore, and 22 out of a total

of 55 river carpsucker sampled in 1992 were collected further from

the shore, in hoop nets. The confounding factor of different

collection locations (near shore vs. channel) may invalidate

comparison of data between 1990 and 1992, and at the very least

must be noted.

8. Section 4,0 Data Analyses, page 4-1. The second paragraph

states that results are graphed for visual examination on

Figures 1,2,3, and 4. Criteria are not described for including

data on the graphs. For example, there are data for nine catfish

6

at Site 2 in 1988 in Appendix A, and these data are shown on

Figure 2. There are also data for nine river carpsucker at Site 2

from the 1988 fish study that are not listed in Appendix A nor

shown on Figure 4. The rationale for including, or not including,

available data in the report must be provided.

It would be useful for the reader if the range of total PCB

concentrations was also provided in Table 2, along with the number

of fish collected of each species at each site.

9. Section 4.2.1 Results of 1992 Statistical Analyses, page 4-3.

The 1992 Fish Report states that 10 data sets were normally

distributed and seven were lognormally distributed. This document

does not indicate why a lognormal transformation was used on all

data sets. The first paragraph states that the results of the

W-Test are provided in Appendix B. These results of the W-Test

could not be located in Appendix B.

10. Section 4.2 Statistical Approach, page 4-2. The level of

significance specified for the statistical tests applied to the

data should be presented.

There is no discussion in this section on the other sources of

variability in the experimental groups. If a statistical

comparison of the data sets is used to evaluate whether the data

sets represent the same population, it is assumed that the source

7

of variability being compared in the statistical comparison is

either the species of fish or the site where the fish were

collected. A discussion should be included in this section to

justify this assumption. The other sources of variability in data

sets, such as collection technique, should be addressed.

Theoretically it appears valid to compare the data sets by

assessing homogeneity of variance and parametric and nonparametric

analyses of variance; however, the examination of the data indicate

that there are probably multiple factors impacting data set

variability. For example, at Site 3 in 1992 from data from

Appendix A, the mean PCB concentration in carp was 3.25 mg/kg and

the sample standard deviation was 2.62 mg/kg. The large standard

deviation relative to the mean is an indication of the variability

of data within each species at each site. The practical

significance of comparing the sample population from different

sites and between species must be considered in addition to the

statistical significance of doing this. Statistically the total

PCB concentrations in common carp from Sites 3 and 4 may not be

different, however, practically these differences in total PCB

concentrations appear to be significant.

11. Section 5.0 Interim gampHnq strategy, page 5-1.

The term "satisfactory database for tissue PCB analysis" in the

first bullet should be defined. In addition, it should be noted

that 24 smallmouth buffalo were captured during the 1992 sampling

event. The increase in capture of the species may be due to the

8

time of year that sampling was conducted or the alternative

sampling techniques that were utilized during this event. The

conclusion that adequate smallmouth buffalo cannot be captured is

not justified.

See Comment No. 2 concerning the second and third bullets. The

first two bullets on page 5-2 address the statistical significance

of PCB comparisons. The level of significance must be included.

See Comment No. 10 concerning justification of planning future

sampling events based solely on statistical significance and not

considering practical aspects.

12. Section 5.0 Interim sampUng strategy, page 5-1. The first

recommendation, to collect a single target species, is not

acceptable. An evaluation of data collected during the three

sampling events and the alternate fish collection methods utilized

indicates that sampling strategies and varying boundaries of fish

collection sites have impacted mean PCB concentrations for species

at various locations. If river carpsuckers were only collected

from near the shore during the 1992 sampling event, the mean

concentration of total PCBs resulting may have been higher.

Comparison of river carpsucker PCB concentrations from fish

collected near the shore versus fish collected further from the

shore indicates this factor impacted PCB concentrations. In order

to conservatively estimate fish PCB concentrations, the impact of

9

collecting fish only from near the shore must be evaluated when

planning future fish sampling events.

Since fishing advisories have been issued for carp, river

carpsuckers, and channel catfish, the impact of not collecting the

river carpsuckers and channel catfish on the ability of the State

of Iowa to issue a fishing advisory must be evaluated when planning

fish sampling events.

The second bullet indicates that fish would be collected as a

single sample from Sites 2, 3 and 4 since the sample populations

from these sites were not "statistically" different. However, it

is recommended that the existing site boundaries remain constant

from past sampling events to increase comparability of data over

time.

13. Figures. A map depicting the sampling locations (sites)

should be included for the benefit of the reader.

14. Appendix A. It is not clear if the values provided for 1992

for Aroclors 1016, 1221, 1232, and 1242 are detected concentrations

or detection limits. If these values are detection limits, this

should be clearly presented.

10

RECEIVED

oec :2 m

SPFD BRANCH

TERRY E. BRANSTAD. governor DEPARTMENT OF NATURAL RESOURCESLARRY J. WILSON, DIRECTOR

December 16, 1993

James ColbertSuperfund Branch, Waste Management Division U.S. Environmental Protection Agency Kansas City, KS 66101

Dear Mr. Colbert:

As requested in your letter of November 23, 1993, DNR staff have reviewed the report Interim Fish Sampling Development. Mississippi River Pool 15 prepared by Woodward-Clyde Consultants. The report suggests that a single indicator species (carp) be used to assess levels of PCBs in fish of Pool 15 near the ALCOA facility.

DNR appreciates the difficulty of collecting several of the target species, especially flathead catfish and shovelnose sturgeon. DNR does not, however, believe that the proposal to use carp as a single indicator species is consistent with the objective of the fish sampling requirement in the CERCLA Consent Order (Docket No. 90-F-0027):

To determine the need to continue or expand current advisories, to evaluate the risk to human health or the environment, and to determine if response actions for Pool 15 are necessary.

Thus, DNR recommends that, at a minimum, ALCOA be required to continue monitoring PCB concentrations in carp, carpsucker, and channel catfish and that samples of at least 10 individuals of each species be collected from Sites 2, 3, 4, and 5 of Pool 15 of the Upper Mississippi River. This recommendation is based on the following:

• Information on levels of PCBs in carp and carpsucker is necessary to determine whether the existing fish consumption advisory needs to be revised;

• Channel catfish is a very important commercial and sport fish. Monitoring of channel catfish is necessary to determine whether the existing fish consumption advisory should be extended to cover this species. Although average levels of PCBs in channel catfish have remained below 2.0 ppm at all sites in 1990 and 1992, levels of PCBs have exceeded 2.0 ppm in at least one channel catfish from Sites 2 and 3 in those years;

WALLACE STATE OFFICE BUILDING / DES MOINES, IOWA 50319 / 515-281-5145 / TDD 515-242-5967 / FAX 515-281-8895

James Colbert December 16, 1993 Page 2.

• DNR needs site-specific information on levels of PCBs to determine the appropriate coverage for the fish consumption advisory. Although between-site differences in levels of PCBS did not exist for carp at Sites 2, 3, and 4 in 1992, Figure 1 of the report suggests that between-site differences have occurred in the past.

• DNR needs information on levels of PCBs in fish from Site 5 to insure that the coverage of the existing fish consumption advisory is appropriate. The occurrence of significantly lower levels of PCBs in fish collected from Site 5 is not only an interesting phenomenon but is important to both Iowa and Illinois for the design of the fish consumption advisory issued by DNR for the Iowa side of Pool 15. In addition, levels of PCBs in fish from site 5 occasionally exceed 2.0 ppm of total PCBS. For example, two smallmouth buffalo collected in 1992 (sample 5-SMB-l (2.80 ppm) and sample 5-SMB-4 (2.21 ppm)) exceeded the 2.0 ppm level of concern.

While a relatively minor point, DNR is surprised that all carpsuckers collected at sampling sites in Pool 15 during 1990 and 1992 have been river carpsuckers (Caroiodes carpio). The quillback (C. cvprinus) is a closely-related species that is also a common inhabitant of the Upper Mississippi River. The highfin carpsucker (C. velifer) occurs in the river but is less common than either the river carpsucker or quillback. If the possibility exists that other species of carpsucker were included in samples labelled as "river carpsucker," future reports should refer to the carpsucker genus (Caroiodes) rather than to the river carpsucker.

Thank you for the opportunity to comment on the proposed changes in sampling design. If you have questions regarding DNR comments, please call me at 515/281-8905.

Sincerely,

(^John R. OlsonWater Resources Section

cc: Darrell McAllister, DNR Water Quality BureauJohn Vedder, DNR Hazardous Waste Section Marion Conover, DNR Fisheries Bureau Tom Boland, DNR Fisheries Bureau

State of Illinois

ENVIRONMENTAL PROTECTION AGENCY

Mr. James Colbert Remedial Project Manager Remedial Enforcement Section Superfund Branch Waste Management Division IISEPA, Region VII 726 Minnesota Avenue Kansas City, Kansas 66101

Dear Mr. Colbert:

I have reviewed the Interim Fish Sampling Development, Mississippi River Pool 15 as requested in your November 23, 1993 letter. After discussing the conclusions of this document with Tom Long of the Illinois Department of Public Health, it is our conclusion that limiting the 1994 sampling effort to just carp is not acceptable. First, we note that the mean PCB concentration for river carpsuckers at Site 2 in 1992 was just slightly less than the 2 ppm Action Level, with the 95% UCL well above the Action Level. Second, the mean at Site 3 in 1990 was over 8 ppm with the 95% UCL at 17.3 ppm. Third, these two UCL values are actually greater than the corresponding carp sample UCLs. For these reasons, we do not believe that carp should be the only indicator species for this project. We recommend that river carpsucker be a second indicator species.

We also note that the sampling efforts will be limited to Sites 2, 3, and 4, with no samples collected from Site 5 on the Illinois side of Pool 15. While we agree that the past analytical data for Site 5 shows no PCB results of concern, we would suggest that it may be appropriate to collect carp and river carpsucker samples in an area of Pool 15 more downstream of the Alcoa outfall (the current sampling area is almost directly across the river from the outfall). This would sample fish populations which would theoretically be more at risk of exposure to sediments contaminated from the outfall.

Finally, we must point out that the flooding experienced this summer along the Mississippi may have resulted in a major redistribution of sediments in this area. This further argues for sampling efforts on the Illinois side of the River, and for sampling more than just carp. We suggest that it may be prudent to collect the other species sampled in the past (channel catfish, drum, etc.) and hold these samples in a freezer. If the data for the indicator species shows that there is evidence that the PCB problem has been affected by the floodwaters, these other samples can then be sent for analysis, saving the expense of going out for a second sampling expedition.

Mary A. Gade, Director

217/785-0830

2200 Churchill Road, Springfield, IL 62794-9276

RECEiVtJ

December 15, 1993

DEC 2 i 133-3SPFD BRANCH

Mat* m tacfcl* Aptr

RECElVt-J

FISH AND WILDLIFE SERVICE Rock Island Field Office (ES)

4469 - 48th Avenue Court Rock Island, Illinois 61201IN REPLY REFER TO:

309/793-5800

December 30, 1993

Mr. James Colbert Remedial Project Manager U.S. Environmental Protection Agency Remedial Enforcement Section Superfund Branch Region VII 726 Minnesota Avenue Kansas City, Kansas 66101

Dear Mr. Colbert:

This is in response to your request for comments on the Interim Fish Sampling Program Development, Mississippi River Pool 15, September 29, 1993, prepared by Woodward Clyde Consultants for the Aluminum Company of America (ALCOA) Riverdale, Iowa plant.We understand that ALCOA intends to incorporate comments received on this document into their 1994 Fish Sampling Plan for Pool 15 of the Upper Mississippi River.

Our concerns with the ALCOA site include the potential for adverse effects to the federally endangered Higgins' eye pearly mussel. Lampsilis higginsi. from polychlorinated biphenyl (PCB) contaminated bed sediments. Direct impacts may result from mussels ingesting contaminated material. Indirect impacts may result from impacts to fish hosts. Because the fish hosts for freshwater mussels represent a critical stage in development and survival, preservation and management efforts to protect endangered mussel species must necessarily include preservation of the fish hosts.

Therefore, we recommend that documented field observations be made of the presence of host fishes for L. higginsi during any scheduled fish sampling, and that this activity be specifically included in AlCOA's 1994 Fish Sampling Plan, in order to more completely evaluate the adverse effects of PCB-contaminated sediments on L. higginsi. The host fishes, as determined by

laboratory studies1 and field observations2, for L. hiaainsi are listed as follows:

largemouth bass (Micropterus salmoides) smallmouth bass (Micropterus dolmieuil walleye (Stizostedion vitreum vitriumi

sauger (Stizostedion canadense) yellow perch (Perea flavescensi

green sunfish (Lepomis cyanellus) bluegill (Lepomis machrochirus) northern pike (Esox lucius) freshwater drum (APPlodinotus arunniens).

We also recommend that collections based on the original list of fish species, as described in the 1990 consent order, be continued. This would include the collection of freshwater drum, a potential Higgins' eye host fish. ALCOA's proposal to collect only common carp, which would represent an indicator species to be used for assessing PCB concentrations in the general fish population, is not acceptable. No one species of fish can serve to indicate for a community of species all the potential adverse effects of contaminants confined primarily to the benthic environment. This is particularly critical when that one species does not always interact with the benthic environment, as do bottom dwelling fishes such as catfishes and suckers, and benthic invertebrates such as freshwater mussels.

In reviewing ALCOA's analytical data for fish collections adjacent to the facility made in 1990, we are aware that PCBs in fish tissues have been found as high as 920 ppm in rivercarpsucker, 40 ppm in freshwater drum, and 29 ppm in common carp (Woodward-Clyde Consultants 1991)3. In light of such data, pre-selecting the common carp as an indicator species may grossly misrepresent the adverse effects of such contaminants to the environment.

‘Waller, D. L. and L. E. Hoiland-Bartels. 1988. Fish hosts for glochidia of the endangered freshwater mussel Lampsilis hiaainsi Lea (Bivalvia: Unionidae). Malacological Review 21: 119-122.

2Hoggarth, M. A. 1992. An examination of the glochidia- host relationships reported in the literature for North American species of Unionaceae (Mollusca: Bivalvia). Malacology Data Net 3(1-4):1-30.

Woodward-Clyde Consultants. 1991. An assessment of PCB concentrations in fish of Pool 15 of the Mississippi River, prepared for Aluminum Company of America, Davenport, Iowa, November, 1991.

2

Regarding sampling sites, we believe it is extremely important to include a downstream Illinois site. This site may be most appropriately located where organic sediments collect like above the Iowa-Illinois hydropower plant on Sylvan Slough. Adult mayflies collected at Dam 15 by Service personnel indicated the presence of PCB's in their body burdens. We would consider some consolidation of sites 2, 3, and 4, and the possible elimination of site 5.

We would be pleased to discuss these comments with you further.If you have any questions, contact Melanie Young or Jody Millar of this office.

Sincerely

cc: Marshal Sonksen, P.E., ALCOA

MY:sjg

3

JAN 2 5 W*

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QtSierc____________ ,<5 •/

Mr. Marshall Sonksen Staff Environmental Engineer Aluminum Company of America P.0. Box 3567 Davenport, Iowa 52808

Dear Mr. Sonksen:

RE: Section VI-B of the Administrative Order on Consent,Docket No. 90-F-0027; Mississippi River Pool 15 Fish Sampling and Analysis Investigation and Study

This letter is to notify the Aluminum Company of America (Alcoa) that the U.S. Environmental Protection Agency (EPA) has completed its review of the September 29, 1993, document, Interim Fish Sampling Program Development, Mississippi River Pool 15.The document was reviewed to evaluate whether the statistical review of past data presented in the document justifies collection of only carp at Sites 2, 3 and 4 to meet current project objectives. The EPA does not agree with Alcoa's conclusion that the objective, as stated in Section VI-B of the 1990 Administrative Order on Consent, Docket No. 90-F-0027 (1990 AOC), can be met by this reduced level of sampling.

While the statistical procedures utilized in the document are acceptable, it is necessary to evaluate previous fish studies from a practical viewpoint rather than just a statistical approach if the objectives of the 1990 AOC are to be satisfied.The intent of Mississippi River Pool 15 Fish Sampling and Analysis Investigation and Study was to conduct biennial fish studies to determine the need to continue or expand current advisories, to evaluate the risk to public health or welfare or the environment, and to determine if response actions for Pool 15 are necessary. After considering the objectives of the 1990 AOC, previous fish studies, Alcoa's Interim Fish Sampling Program Development for Mississippi River Pool 15, and the enclosed responses to Alcoa's Interim Fish Sampling Program Development for Mississippi River Pool 15 received from the Iowa Department of Natural Resources (IDNR), U.S. Fish and Wildlife Service (USFWS), U.S. Food and Drug Administration (FDA), and Illinois Environmental Protection Agency (I11EPA), EPA has determined that the 1994 Fish Study must include the following:

• Collection of common carp, river carpsucker, and channel catfish due to the existing fish consumption advisories for these three species.

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• Maintain four sampling sites; sites 2, 3, and 4 on the Iowa side of the Mississippi River and a downstream location on the Illinois side, approximately at site 1 from the 1990 fish study.

• Collection of at least ten fish from each of the three species at each sampling site.

• Documented field observations (identification, location, and approximate size) of the other species listed in the 1990 AOC (flathead catfish, shovelnose sturgeon, smallmouth buffalo, and freshwater drum) that are encountered during the 1994 Fish Study.

The EPA also requests that documented field observations be made of the presence of the following host fishes for the Higgins' eye pearly mussel, Lampsilis higcrinsi: largemouth bass, smallmouth bass, walleye, sauger, yellow perch, green sunfish, bluegill, and northern pike.

Also enclosed are EPA's technical review comments on the Interim Fish Sampling Program Development for Mississippi River Pool 15. Submittal of a revised Interim Fish Sampling Program Development for Mississippi River Pool 15 is not required, however any subsequent fish sampling plans and/or fish study reports must provide the appropriate clarification and/or address the inaccuracies cited in these comments.

As you are aware, the 1994 Fish Sampling Plan is due 30 days from Alcoa's receipt of this letter. If you have any questions, please contact me at (913) 551-7489.

Sincerely,

James ColbertRemedial Enforcement SectionSuperfund BranchWaste Management Division

Enclosures

cc: Dick Swanson, FDA (w/ comments)John Olsen, IDNR (w/ comments)Jody Millar, USFWS (w/ comments)Tom Long, Illinois DPH (w/ comments)Tom Hornshaw, Illinois EPA (w/ comments)Marion Conover, IDNR Fisheries (w/ comments)

bcc: Scott Pemberton, CNSLJan Lydigsen, Jacobs (w/ comments)