further discussion about the onondaga nation's comments on the prap and rod for the onondaga lake...

7/31/2019 Further Discussion about the Onondaga Nation's Comments on the PRAP and ROD for the Onondaga Lake Bottom

1/14

Further Discussion about theOnondaga Nations Comments on the

Proposed Remedial Action Plan and

Record of Decision for the

Onondaga Lake Bottom Sub-site

Prepared for:

The Onondaga Nation

Nedrow, NY 13120

Prepared by:

Stratus Consulting Inc.

PO Box 4059

Boulder, CO 80306-4059(303) 381-8000

Report

umber 5-BD-***-

November 16, 2005SC10762

Stratus Consulting


2/14

Further Discussion about the

Onondaga Nations Comments on

the Proposed Remedial Action Plan

and Record of Decision for the

Onondaga Lake Bottom Sub-site

Prepared for:

The Onondaga Nation

Nedrow, NY 13120

Prepared by:

Stratus Consulting Inc.PO Box 4059

Boulder, CO 80306-4059

(303) 381-8000

November 16, 2005SC10762


3/14

1. Introduction

The New York State Department of Environmental Conservation (NYSDEC) and the

U.S. Environmental Protection Agency (EPA) (collectively, the agencies) have been workingtoward cleanup of Onondaga Lake, including its many surrounding sub-sites, for many years.

That work has included a lengthy and difficult interplay with Honeywell and its predecessors,

including complicated interactions within the judicial system. Therefore, it is not surprising that

the agencies wish to move to actual cleanup expeditiously, having finally reached a consensuswith each other and Honeywell, as well as approval by the court. However, many of the issues

raised by the Onondaga Nation (Nation) in their comments (Stratus Consulting, 2005) on the

Proposed Remedial Action Plan (PRAP; NYSDEC, 2004b) for the Onondaga Lake bottom sub-site could not have been weighed and addressed by the agencies before finalizing the Record of

Decision (ROD; NYSDEC and U.S. EPA, 2005b) a day later. This fact was apparentlyconfirmed in a subsequent meeting between the Nation and EPA, in which agency staff admittedthat the Nations comments were not read before the ROD was finalized and submitted to the

court for approval.

Since then, the agencies have responded to the Nations comments in writing (NYSDEC and

U.S. EPA, 2005c). It is clear that the agencies have now read and understood the comments, and

have devoted effort to defending their prior decisions. However, beyond the statutoryrequirements for consultation, we are concerned that the agencies responses indicate a

continuing lack of substantive consultation on the technical issues. Many of the agencies

responses are simply a reiteration of the positions presented previously in the PRAP, rather thana thoughtful exploration of the issues raised by the Nation.

The Nation should be accorded a higher level of consultation than the general public, bothbecause the statute requires it and because of the centuries-old connection between Onondaga

Lake and the Nation. Furthermore, more remediation may be required to properly address the

Nations special status, knowledge, and interests, and consultation is required to make thisdetermination. Therefore, consultation is not simply an academic or statutory exercise; it is

necessary to ensure an adequate level of protection for the environment and the public. We hope

that the agencies will reconsider their level of consultation with the Nation, and increase it.

We also note that there is a difference between the routine public involvement for Superfund

sites and the specific statutory requirement for consultation with affected tribes. The latter is in

addition to the former. However, the agencies have repeatedly described their meetings with theNation as outreach (e.g., p. 9 of ROD; NYSDEC and U.S. EPA, 2005b), and in the Nations

view, outreach is quite different from consultation and active participation in decision-making.

SC10762


4/14

Stratus Consulting (11/16/2005)

The request for consultation with the agencies does not reflect a lack of confidence in the

technical capabilities of agency experts. We recognize that the ROD is based on years ofcomplex technical analyses by many dedicated individuals. However, we believe it is essential

for the Nation to have a better understanding of these analyses and the opportunity to resolve anycurrent points of disagreement. We realize that the Nation is as anxious as the agencies to beginremediation of Onondaga Lake, and we present the following comments in the spirit of

promoting the Nations full cooperation in this process.

Therefore, we are providing comments on the agencies responses, not because we believe that

an after-the-fact reiteration of previous points is the most efficient technique to resolve these

important issues, but in hopes of clarifying the continuing concerns of the Nation. Our hope isthat this will facilitate discussions between the Nation and the agencies to resolve key issues for

a more protective remedy that more accurately accounts for the Nations concerns. We have

attempted to distinguish between agency responses that reiterated previous positions taken in the

PRAP (and ROD) but where we still believe that further consultation is needed to resolve theissue, issues that the agencies did not respond to, and new information provided by the agencies.

Most of the agencies responses fall into the first category, so many topics discussed here pointto the same issues that we raised in the original comments. We recommend that further

consultation take place via face-to-face meetings between the agencies technical experts and the

Nations technical experts.

2. Overview of Unresolved Technical Issues

The remainder of this document focuses on several technical issues addressed in the Nations

original comments and in the agencies responses to these comments. These issues are outlinedbelow and discussed in detail in the following sections in response to specific comments by theagencies.

Toxicity-based sediment cleanup goals. The level of protection achieved by remediation is

reduced by the agencies development of sediment cleanup goals based on measures of toxic

effects rather than no observed adverse effect levels (NOAELs) and the use of a range oftoxicity values to develop probable effects concentrations (PECs).

Risk averaging. By averaging risks among contaminants instead of evaluating the toxicity ofeach individual contaminant, the agencies analysis may have underestimated the importance of

individual risk drivers other than mercury.

Evaluation of bioaccumulation. Under the preferred alternative, the current bioaccumulation-

based sediment quality value (BSQV) for mercury would not be met in all areas of the lake.

Additionally, the level of protection estimated by the BSQV is also reduced by (1) the

Page 2SC10762


5/14


development of the mercury BSQV based on the lowest observed adverse effect level (LOAEL)

instead of the NOAEL, and (2) averaging of contaminant concentrations over all fish based onsize alone.

Limited consideration of chronic toxicity. Chronic toxicity is not explicitly addressed, and

therefore there may be areas of the lake where chronic toxicity is a problem even after

remediation.

Cap effectiveness. Cap effectiveness has been evaluated using a groundwater flow model and

capping model that depend on a number of assumptions with considerable uncertainty, and slopefailure is a concern within the in-lake waste deposit (ILWD).

Oxygenation. The plan for remediation of the profundal zone depends on the assumption that

oxygenation will be effective. However, oxygenation is an experimental remediation technology.

Risk analysis. Upon further review of the risk analysis,it is clear that there are substantial

differences in residual risk under the preferred alternative compared to the most protective

alternative (Alternative 7). We are not convinced that the cost of Alternative 7 outweighs theadditional risk reduction (Alternative 7 may be more cost-effective than the preferred

alternative).

3. Discussion of Unresolved Technical Issues

This section provides a detailed discussion of the unresolved technical issues. The intention of

this discussion is to clarify key issues of concern and discuss additional information related tothese issues.

3.1 Toxicity-Based Sediment Cleanup Goals

We disagree with the agencies position on their sediment toxicity analyses (Comments 4, 5, 7,

13, 14, 15, 27, and 28), and repeat our concerns that the agencies (1) have incorrectly applied the

methods used to develop sediment threshold concentrations, and (2) have not given sufficient

consideration to chronic toxicity and bioaccumulation in the development of PEC values.

We understand that the intent of the sediment effects concentration (SEC) process in the BaselineEcological Risk Assessment (BERA; TAMS, 2002a) was to develop a threshold that minimizes

both Type II (false positive) and Type I (false negative) errors. Based on this goal, one wouldexpect that a final value would fall centrally between concentrations below which adverse effects

are rarely observed (threshold effects concentrations) and concentrations above which adverse

Page 3SC10762


6/14


effects are frequently observed (PECs). However, the method used to develop the final PECs

included an adverse effects threshold (AET), above which adverse effects are always statisticallysignificant. AETs were not used in the development of PECs by MacDonald et al. (2000)

because they are not considered to be toxicity thresholds. AETs are much higher than probableeffects thresholds and are much more likely to result in a Type I (false negative) error. Thisapproach errs on the side of minimizing Type II errors (false positive), rather than achieving a

reasonable balance between threshold level effects and probable effects.

We realize that MacDonald et al. (2000) state that PEC quotients should be used to assess

sediments that contain complex mixtures of chemical contaminants. However, MacDonald et al.

(2000) are not advocating their use to establish protective concentrations. Rather, they indicatethat PECs and PEC quotients (PECQs) are used to identify sediments that are likely to be toxic

to sediment-dwelling organisms. MacDonald et al. (2000) note that PECQs do not consider the

potential for bioaccumulation in aquatic organisms nor the associated hazards to species that

consume aquatic organisms. Both MacDonald et al. (2000) and Ingersoll et al. (2000) point outthe importance of using additional tools, such as bioaccumulation assessments, in combination

with the PECQ method, to evaluate potential effects of sediment-associated contaminants.

In their comments, the agencies show that the Onondaga Lake consensus PEC for mercury of

2.2 mg/kg is similar to other probable effects levels, with similar being defined as within afactor of three as suggested by Smith et al. (1996) and MacDonald et al. (1996). The Onondaga

Lake PEC for mercury is twice the MacDonald et al. (2000) PEC of 1.1 mg/kg, and thus falls

within this range. However, the probable effect level (PEL; similar to a PEC) for mercury,derived by Smith et al. (1996), was 0.486 mg/kg, lower than the Onondaga Lake PEC of

2.2 mg/kg by a factor of 4.5, and thus not in a similar range. The Smith et al. (1996) threshold

was reviewed by MacDonald et al. (2000) and ultimately used in the development of theirconsensus-based threshold of 1.1 mg/kg.

In considering this issue further, we found indications from other studies that a mercury PEC of2.2 mg/kg may not be protective. For example, in the Remedial Investigation (RI; TAMS,

2002b), at the bottom of Figure 5-2 (mercury concentration map), there is a notation in NYSDEC(1999) that a mercury concentration of 1.3 mg/kg is considered to be a severe effect level. This is

close to half of the mercury PEC of 2.2 mg/kg for the Onondaga Lake site (TAMS, 2002a). We

also found that dredge sediments containing mercury at a concentration of over 1.6 mg/kg areclassified by NYSDEC (2004a) as class C sediments, which require capping with cleaner

material if reused.

We believe that NOAELs are more reasonable and more protective values than expected effects

levels such as PECQs. In fact, upon further review of the Feasibility Study (FS; Parsons, 2004),we noted the following statement that appears to support this view: According to NYSDEC

guidance, the magnitude of remaining risk is a component of the long-term effectiveness and

Page 4SC10762


7/14


permanence criterion, and can be expressed quantitatively, such as by cancer risk levels, or

margins of safety over NOAELs for noncarcinogenic effects, or by the volume orconcentration of contaminants in waste, media or treatment residuals remaining at the site

(emphasis added; from Section I.3.1.1. of Parsons, 2004).

3.2 Risk Averaging

The agencies comments reiterate their position on risk averaging (Comments 5, 7, 8, 9, 12, 13,and 39). After further consideration of the agencies position, we remain concerned that the use

of a single value as a threshold for remediation based on risk averaging may not be sufficiently

protective. We repeat our primary concerns that (1) averaging can underestimate risk andobscure strong risk drivers within a mixture, and (2) additivity of toxic contaminants is not

addressed by an average threshold quotient.

As suggested in the agencies comments, we have reviewed the contaminant distribution maps

accompanying Section 5 of the RI, and acknowledge that stations with elevated concentrations ofpolychlorinated biphenyls (PCBs) and polychlorinated dibenzo-p-dioxins/polychlorinated

dibenzofurans are generally located in areas of the lake targeted for remediation (Comment 19 in

NYSDEC and U.S. EPA, 2005c). However, we note that the FS also expressed concern that,There may be localized exceedences of individual SECs, such as the effects range low (ER-L),

in areas not addressed by remediation (p. 5-37 of FS; Parsons, 2004). Areas where at least one

chemical parameter of interest (CPOI) exceeds the individual ER-L for that CPOI are depicted inFigure 8 of the ROD (NYSDEC and U.S. EPA, 2005b), and constitute a larger area of the lake

than those targeted for remediation under the selected alternative.

The agencies reported that they considered summing PECQs, but that using the sum of PECQs

could result in a situation in which all CPOIs have PECQs of less than 1, but the sum of PECQs

would be much greater than 1. An additional concern discussed by the agencies was the unequalweighting of compounds under an additive PECQ model. We recognize the complications that an

additive model presents; however, these could be addressed by reconsidering the critical

threshold for an aggregated PECQ, and appropriately weighting compounds. Alternatively, as werecommended previously (Stratus Consulting, 2005), an evaluation of each chemical class

PECQ-sum could be used independently to evaluate risk, pre- and post-remedy. This type of

analysis would ensure that the risk of each chemical is evaluated, rather than potentially masking

high-risk chemical concentrations via risk averaging.

Page 5SC10762


8/14


3.3 Bioaccumulation

We have carefully considered the agencies responses to our comments about the analysis of

bioaccumulation (Comments 17, 19-26). We continue to have two major concerns about thebioaccumulation analysis: (1) that the BSQV was developed using a LOAEL rather than a

NOAEL, and (2) that contaminant concentrations were averaged over all fish based on size

alone. We also remain concerned that the selected remedy is not protective of bioaccumulation

effects based on a comparison of the mercury BSQV with expected concentrations in sediment.

First, the agencies have still not addressed our concern that the mercury BSQV was developedusing the LOAEL and not the NOAEL (Stratus Consulting, 2005). We request that this concern

be considered and addressed.

The agencies have also not addressed our concern that averaging contaminant concentrations

over all fish based on size alone obscures the influence of highly significant factors that affectcontaminant 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 (Section 3.4.1 in Stratus Consulting, 2005). The Nation notes that size offish does not necessarily correlate with trophic status, as stated in the agencies Comment #22

(NYSDEC and U.S. EPA, 2005c).

We also reaffirm our position that it is imprudent to derive single numbers for mercury target

concentrations in fish tissue without more information on this subject. We have consideredadditional information on this topic that supports this view. For example, Barr (1986) found that

reproductive impairment in loons is associated with the consumption of fish containing as little

as 0.0003 mg/kg of mercury, well below the lake-wide fish tissue targets for mercury under thepreferred remedy of 0.14 mg/kg for ecological receptors and 0.3 mg/kg for humans.

Upon further review of the residual risk evaluation in Appendix I of the FS (Parsons, 2004), wealso note that not all wildlife that consume fish are protected by the preferred alternative. In fact,

the residual risk analysis indicates that the lakewide surface-weighted average concentration

(SWAC) for mercury under the preferred alternative (0.96 mg/kg) is greater than the BSQV of0.8 mg/kg (Appendix I of Parsons, 2004).

Under the preferred alternative, the predicted SWAC in the profundal zone would be 1.19 mg/kg(Appendix I of Parsons, 2004). According to the ROD, the sediment mercury concentration goal

of a 0.8 mg/kg BSQV would only be met in all of the profundal sediments under Alternative 7,which is based on the ER-L threshold (p. 65 of ROD; NYSDEC and U.S. EPA, 2005b).

Page 6SC10762


9/14


3.4 Chronic Toxicity

The agencies have provided more explanation about why chronic toxicity information was not

used to drive remedy selection (Comments 3, 6, and 37). However, we continue to maintain thatthe agencies have not demonstrated that such information cannot be reliably used, and we

believe that its proper use would add legitimate justification for a more protective remedy.

The agencies argue that measures of chronic toxicity were considered in the SEC selection

process and that significant reductions in chronic toxicity would be expected under the selected

remedy (NYSDEC and U.S. EPA, 2005a). However, the response to Technical Comment #7 inthe ROD (NYSDEC and U.S. EPA, 2005a) clearly states that chronic toxicity is not explicitly

addressed by the mean PECQ methodology, and it is possible that, following remediation, areaswill remain in the lake where chronic toxicity to benthic organisms could occur (NYSDEC and

U.S. EPA, 2005a).

We argue that the chronic toxicity test results represent an important source of site-specific

information that should have been used in the development of SECs. The ER-L, threshold effect

level, and PEL sediment effect concentrations from the site-specific chronic toxicity tests are thesame or slightly higher than the effect concentrations from the site-specific acute toxicity tests.

However, the effects range-median (ER-M) threshold (based on amphipod reproduction;

0.7 mg/kg) and the AET (based on amphipod survival/chironomid biomass; 9.6 mg/kg) from thesite-specific chronic toxicity tests are lower than the selected ER-M (2.8 mg/kg) and AET

(13 mg/kg) from the acute tests. Thus, the selected ER-M and AET used to develop the SEC may

not be protective of benthic organisms.

Further, as concluded in the BERA, . . . the results of the 2000 42-day chronic (long term)sediment toxicity tests . . . and the results of the 1992 10-day acute (short term) tests . . .confirmed that both sub-lethal (impaired growth and reproduction) and lethal impacts (survival)

are occurring in the sediments of Onondaga Lake (Section 9.2.1.3 of TAMS, 2002a). These data

support the argument that chronic toxicity should be considered in the development of SECs.

3.5 Capping

We have several comments on the additional information on capping provided in the agencies

comments (Comments 10, 11, 16, 17, 29, 30, 34, 35, and 38).

First, we are concerned with the uncertainties associated with the effectiveness of the planned

groundwater barrier wall and collection system (NYSDEC and U.S. EPA, 2005a). As noted by

the agencies in their Responsiveness Summary, Honeywells groundwater flow model has notbeen calibrated or validated by comparing predicted upwelling rates to measured values in lake

Page 7SC10762


10/14


sediments (NYSDEC and U.S. EPA, 2005a). The agencies have addressed this issue by using

what they consider a conservative upwelling rate to develop cap threshold values (CTVs) forcontaminant concentrations below the cap. However, it is unclear exactly what upwelling rate

was used in the cap modeling. The rate is given as 6 cm/yr in Comment #10 in response to theNations comments (NYSDEC and U.S. EPA, 2005c) and as 9 cm/yr in response to TechnicalComment # 7 in the Responsiveness Summary (NYSDEC and U.S. EPA, 2005a). While this may

simply be a typographical error, we would like to know which rate was actually used, since

NYSDEC has argued that the rate of 9 cm is the most appropriate value to assume given thatCTVs decrease significantly as upwelling velocities increase up to about 9 cm/yr for an isolation

layer of the thickness assumed for Onondaga Lake remediation (NYSDEC and U.S. EPA,

2005a). Regardless of which upwelling rate is modeled, there remains uncertainty about what the

actual reductions in upwelling rates will be and what CTVs will be necessary to avoid capfailure.

We also note with concern the comments of technical experts and the agencies about thepossibility of slope failures within the ILWD in sediment management unit 1 (SMU 1; U.S. EPA,

2005; NYSDEC and U.S. EPA, 2005a). The agencies have noted that the possibility of slopefailures and the soft nature of the sediments within this area represent a significant engineering

concern (p. 1 of U.S. EPA, 2005). The agencies also observe that, In the event of failure, the

impacts would be expected to be greatest under those alternatives that involve capping of the

greatest mass/highest concentrations of contaminants (p. 2 of U.S. EPA, 2005). This may be animportant reason for further consideration of the potential advantages of Alternative 7, which

involves full removal throughout SMU 1, compared to the preferred alternative, which includes

capping in SMU 1 except in hot spot areas targeted for dredging. This may also influencedecisions about the relative cost-effectiveness of the two alternatives.

The agencies are taking steps to address these issues with ongoing monitoring and periodic re-

evaluation. It will be important for the Nation to have an opportunity for consultation with theagencies about monitoring results and any additional remedial actions that are proposed.

3.6 Oxygenation of the Profundal Zone

The agencies have repeated their assertion that aeration (oxygenation) is a proven technology

(Comments 30 and 33). However, we continue to disagree with this assertion, and are concerned

about the dependence of the remediation of the profundal zone on this technology. Here we

provide some additional comments to support our position.

Even though oxygenation has been used in other contexts, it has not been well tested for

remediation purposes. As noted in the PRAP, Aeration (oxygenation) has been performed in

other lakes and reservoirs, but rarely to specifically control methylmercury production (p. 54 of

Page 8SC10762


11/14


PRAP; NYSDEC, 2004b). This is a significant concern. If aeration is not effective or is

suspended during the summer months, the oxygen demand of the profundal sediments wouldrapidly cause the loss of oxygen in the hypolimnion and result in the resumption of mercury

methylation in the hypolimnion (p. 69 of PRAP; NYSDEC, 2004b). Even if pilot testing showsaeration to be an effective technology, NYSDEC has acknowledged that aeration would need tobe actively maintained (NYSDEC, 2004b).

Further, the anoxic sediments, which extend to a depth of approximately 3 feet in the profundal

zone (NYSDEC and U.S. EPA, 2005b), represent a source for potential (and substantial)

methylated mercury production regardless of the oxygen status of the overlying waters. This

adds a very large degree of uncertainty to the assertion that oxygenation of the hypolimnetic areawill reduce a substantial portion of mercury methylation. Gas bubbles, presumed to be

methane, are found in the profundal sediments (NYSDEC and U.S. EPA, 2005b). In the FS, the

assertion is made that hypolimnetic oxygenation is expected to reduce the production of methane

gas bubbles that may transport methylated mercury from the underlying anoxic sediments to thewater column (p. 3-38 of Parsons, 2004). The same section asserts that the oxygenation is not

expected to penetrate more than a few inches, at most, into the anoxic zone of the sediments. Inlight of this, it is counterintuitive to assume that water column oxygenation could substantially

affect the production of gases from the sediments.

3.7 Residual Risks

The agencies provided information on their residual risk analysis (Comments 10, 19, 20, 21, 25,

31, 32, and 40) that requires further comment.

First, we acknowledge that the values presented in Table 4.2 of Stratus Consulting (2005) are not

residual concentrations, as indicated in the first column of the table. We regret this confusion.

In Comment 10, the agencies point out that Appendix I of the FS (Parsons, 2004) provides a

detailed discussion of the risk analysis. However, we note that because the preferred alternativewas developed after the FS was completed, a risk analysis for the preferred alternative is not

provided in this document. However, the agencies indicate that Alternatives F1-H in Appendix I

of the FS are comparable to the preferred remedy (NYSDEC, 2004b), and therefore we examined

the potential residual risks for the preferred remedy using estimates of residual risk for thesealternatives as a surrogate.

We focused our review on the residual risk estimates for the preferred alternative compared to

Alternative 7 (which is based on the ER-L and is the most protective alternative). Table 1

presents the SWACs for the two alternatives.

Page 9SC10762


12/14


Table 1. Estimated SWACs (in mg/kg dry wt) for the preferred alternative compared to

Alternative 7

Area considered Contaminant Preferred alternative Alternative 7Littoral zone Barium 107 102

Chromium 30 14

Mercury 0.48 0.23

Zinc 54 49

Total PAHsa

2.23 0.4

PCBs

0.027 0.025

Lakewide Mercury 0.96 0.34

PCBs 0.027 0.025

Profundal zone Mercury 1.19 Not given

a. PAHs = polycyclic aromatic hydrocarbons.

Source: Parsons, 2004 (Tables I.26 and I.30, and Appendix I text).

Based on the SWACs in Table 1, under the preferred alternative the estimated residual

concentrations of mercury both in the littoral zone and lakewide would be more than double that

of Alternative 7. The estimated residual concentration of total PAHs in the littoral zone would beover 5 times greater under the preferred alternative.

In addition to these considerably greater residual concentrations estimated for the preferred

alternative, we are concerned about some of the assumptions used for the risk analysis.

According to Comment 19, the estimated percent reductions in the lakewide SWACs for mercury

and total PCBs under the preferred alternative will result in a similar reduction in concentrationsof these contaminants in fish tissue (NYSDEC and U.S. EPA, 2005c). The support for this

assumption is unclear.

Finally, we note that maps in the PRAP (NYSDEC, 2004b) show that surface sedimentsthroughout the site exceed the ER-L for one or more CPOIs, while large areas of the littoral zone

are not targeted for remediation based on the PEC criteria used for the preferred remedy.

Likewise, there are substantial areas in the profundal zone that are not targeted for remediation

under the preferred remedy, even though they contain CPOIs exceeding the ER-L.

Page 10SC10762


13/14


4. Conclusions

In this document, we have focused on the unresolved technical issues related to the OnondagaLake bottom sub-site risk assessment and remediation plan. The Nation has a unique and

important stake in the outcome of the cleanup of Onondaga Lake, and consultation with the

Nation is necessary to ensure an adequate level of protection for the environment and the public.Face-to-face meetings between technical experts for the agencies and the Nation are essential to

help resolve outstanding technical issues. Ongoing consultation with the Nation will also be

important during remedial design and remedial action for the Onondaga Lake site, as well as RI,

risk assessment, FS, remedial design, and remedial action at the various other sub-sites thataffect Onondaga Lake.

Literature CitedBarr, J.F. 1986. Population dynamics of the common loon (Gavia immer) associated withmercury-contaminated water in northwestern Ontario. Occasional Paper No. 56, Canadian

Wildlife Service.

Ingersoll, C.G., D.D. MacDonald, N. Wang, J.L. Crane, L.J. Field, P.S. Haverland, N.E. Kemble,

R.A. Linsdkoog, C. Severn, and D.E. Smorong. 2000. Prediction of Sediment Toxicity UsingConsensus-Based Freshwater Sediment Quality Guidelines. EPA 905/R-00/007.

U.S. Environmental Protection Agency, Washington, DC.

MacDonald, D.D., C.G. Ingersoll, and T.A. Berger. 2000. Development and evaluation ofconsensus-based sediment quality guidelines for freshwater ecosystems.Archives ofEnvironmental Contamination and Toxicology 39:20-31.

MacDonald, D.D., R.S. Carr, F.D. Calder, E.R. Long, and C.G. Ingersoll. 1996. Developmentand evaluation of sediment quality guidelines for Florida coastal waters.Ecotoxicology 5:253-

278.

NYSDEC. 1999. Technical Guidance for Screening Contaminated Sediments. New York State

Department of Environmental Conservation, Division of Fish, Wildlife, and Marine Resources,

Albany, NY. As cited in TAMS, 2002b.

NYSDEC. 2004a. In-Water and Riparian Management of Sediment and Dredged Material. NewYork State Department of Environmental Conservation, Division of Water, Technical andOperational Guidance Series 5.1.9, Albany. November.

Page 11SC10762


14/14


NYSDEC. 2004b. Proposed Plan: Onondaga Lake Bottom Subsite of the Onondaga Lake

Superfund Site, Syracuse, New York. New York State Department of EnvironmentalConservation, Albany. November.

NYSDEC and U.S. EPA. 2005a. Onondaga Lake Bottom Subsite of the Onondaga Lake

Superfund Site, Syracuse, New York. Responsiveness Summary (Record of Decision Appendix

VI). July.

NYSDEC and U.S. EPA. 2005b. Record of Decision, Onondaga Lake Bottom Subsite of the

Onondaga Lake Superfund Site, Towns of Geddes and Salina, Villages of Solvay and Liverpool,and City of Syracuse, Onondaga County, New York. July.

NYSDEC and U.S. EPA. 2005c. Responses to Technical Analysis of Baseline Ecological Risk

Assessment and Proposed Remedial Action Plan for Mercury in Onondaga Lake. September.

Parsons. 2004. Draft Final Onondaga Lake Feasibility Study Report, Onondaga County, New

York. Prepared for Honeywell, Morristown, NJ. November.

Smith, S.L., D.D. MacDonald, K.A. Keenleyside, C.G. Ingersoll, and L.J. Field. 1996. A

preliminary evaluation of sediment quality assessment values for freshwater ecosystems. Journal

of Great Lakes Research 22(3):624-638.

Stratus Consulting. 2005. Technical Analysis of Baseline Ecological Risk Assessment andProposed Remedial Action Plan for Mercury in Onondaga Lake. Prepared June 28, 2005 for The

Onondaga Nation, Nedrow, NY, by Stratus Consulting Inc., Boulder, CO.

TAMS. 2002a. Onondaga Lake Baseline Ecological Risk Assessment. Original documentprepared by Exponent, Bellevue, WA, for Honeywell, Syracuse, NY. Revision prepared byTAMS Consultants, Inc., New York, for the New York State Department of Environmental

Conservation, Albany. December.

TAMS. 2002b. 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 EnvironmentalConservation, Albany. December.

U.S. EPA. 2005. National Remedy Review Board Recommendations for the Lake Bottom Sub-

Site of the Onondaga Lake Superfund Site. March 25, 2005 memorandum from William J.McCabe, Acting Division Director, Emergency and Remedial Response Division, EPA Region 2

to Jo Ann Griffith, Chair of the National Remedy Review Board.

Page 12SC10762

further discussion about the onondaga nation's comments on the prap and rod for the onondaga lake...

Documents