M E M O R A N D U M DRAFTTO: Ed HanlonAJ.S^PA/SupcrfundyRegion V

COPIES: Laura Weyer/CH2M HILL/MICE

FROM: Jack Dingledine/CH2M HBLL/DAYMikeMischuk/CHlMHlLL^QCE 000006G

DATE: March 2, 1994

SUBJECT: Revised Problem Formulation for the Fields- Brook Ecological Assessment Workplan

PROJECT: GLE 65648.PD.PH

A summary of the revised "Problem Formulation" section of the Fields Brook EcologicalAssessment Workplan is provided for your review. Previously provided comments from EileenHcliDer, David Charters and Mark Sptcugw of U.S. ERA have been incorporated to the degreepossible, given the level of information currently available. Revisions to the "ProblemFormulation" section of the Wodqplan are based primarily on comments received during the 1/27/94conference call between CH2M HILL, U.S.EPA, Region V and U.SEPA, Edison. Specific detailsregarding proposed changes to site conceptual models have not been received* however.

As with the original effort, current guidance on workplan preparation was considered in developingthe "Problem Formulation" section of the document. EPA (1992, 1993) has identified five majorcomponents of problem formulation. Each of the components, as they relate to the Fields Brookinvestigation area identified below. A revised Workplan outline is attached for reference to moredetailed information to be provided in the final document The major components of the FieldsBrook problem formulation are:

Identification of the Ecosystem at Risk

The ecosystem at risk is comprised of the wetland and other communities within the 100-year floodplain of Fields Brook in Ashtabula, Ohio. The site consists of mixed deciduoustree, shrub, and emergent communities that support a variety of avian, mammalian, reptilian,and amphibian wildlife species. A variety of invertebrate species are also expected (Section2.2 of the Workplan will contain a more detailed description of the biotic and abioticconditions of the site). No state or federal threatened or endangered species are known tooccur cm the site. One potentially threatened, state listed plant species may occur. The siteextends from near its source at Cook Road to the confluence with the Ashtabula River. Thecurrent investigation is limited to floodplain communities along the Brook and do notinclude the stream channel itself.

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Identification of Stressor Characteristics

Chemical stressors are the major stressors of concern within the Fields Brook site.Chemicals contaminants include volatile organic compounds, semivolatile organiccompounds, pesticides, PCB's and metals (These have been identified in the draft workplan. Table 2-4). Some contaminants exhibited high concentrations such as chloroform,1,1,2,2-tetrachloroethanc, 1,2-dichloroethyleuc, chlorobenzcne, tetrachloroethylene,trichloroethylene, hexachloroethane, hexacblorobutadiene, phthalates, PAHs, heptachlor,hexachlorobeazene, PCBs, arsenic, barium, beryllium, cadmium, chromium, mercury,selenium, vanadium, and zinc. Whifc others such as 1,2-dichlorocthyleoe,tetrachloroethylene, trichloroethylene, hexachlorobutadine, several PAHs,hexachlorobcnzenc> PCB's, aluminum, arsenic, barium, beryllium, cadmium, cobalt,mercury, silver, vanadium, and zinc were prevalent at most of the sampling locations. Manyof the contaminant* of concern have been present in the floodplain for some time andcontinue to be persistent Control of potential sources is currently in progress, butcontaminants in the floodplain pose a continuous source to the environment Many of thethese contaminants have remained persistent and as such represent a potential threat to localflora and fauna biological cycles.

The distlibution of contaminants are widespread within the watershed, but several reacheshave higher concentrations, these include Reach 5 (Fields Brook floodplain, downstream ofState Road), Reach 6 (Fields Brook floodplain, downstream of old Detrex tributary to StateRoad), Reach 11 (DS tributary floodplain), and Reach 12 (Detrex tributary floodplain).A screening evaluation of Fields Brook contaminants has been conducted to identifyContaminants of Ecological Concern (COECs) for the investigation. This screening wasbased on a comparison of environmental concentrations of the contaminants with known orcalculated No Observable Adverse Effect Level (NOAEL) infonnadon from publishedsources. A description of die screening process is provided in the attachment Details onthe screening process will be provided in Section 2.4.2 of the final woikplan.

Description of Potential Ecological Effects

Information on toxicity and ecological effects were evaluated in the initial screening ofContaminants of Ecological Concern (COEC) for the site. Contaminant effects and toxicityinformation for the Fields Brook COECs are summarized in Appendix in of die Workplaa,This information is based on published literature sources or reports and do sot reflect sitespecific evidence of contaminant effects. At this time, results of field investigations thatmay document contaminant effects are not available.

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Twelve compounds have been identified to be of ecological concern at Fields Brook basedon toxicity information and the results of preliminary soil/sediment sampling. Theirpotential effects include:

VQCs:

Tetrachloroethyfcne: Tetrachloroethyicnc is a common solvent and industrial chemicalwhich is known to rapidly volatilize from surface water. The No Observable AdverseEffect Level (NOAEL) in labocatory mice exposed to drinking water is 14 mg/kg/day forliver effects. Tetrachloroethylene has a reported bioconcenttation factor of 9.5 to 143.

1,2, Dichloroethykne: 1,2, Dichloroethylene occurs in w and treats isomeric forms. It ismobile in soils and groundwater and is expected to volatilize rapidly from surface soils.Bioconcentration factors of O.S (traits) and 0.8 (cis) are low, limiting the potential forsignificant accumulation by biological organisms* Toxicity data indicates a LowestObservable Adverse Effect Level (LOEAL) of SCO mg/L in water for the Laboratory rat, anda NOAEL of 17 mg/Kg bw/day for mouse. Significant routes of exposure may potentiallyinclude inhalation and ingcstion through drinking water.

SVOCs:

Hexachloroethane: Limited information on me environmental characteristics and toxicityof hexachloroethane is currently available. A 1 mg/kg/day is the estimated NOAEL basedon a chronic (16 wks) evaluation with laboratory rats.

HexadJorobutadiene: Hexachlorobutadiene (HCBD) is a chemical solvent which isexpected to rapidly evaporate when released to surface soils. In surface water HCBD has

0^ an estimated half-life of 3 to 30 days. Previous studies with trout indicate a high^ bioconccntration factor, which may range from 5,800 to 17,000. Environmental studies of

HCBD found elevated levels in eggs or organs of seabixds, seals, and shrews, A NOAELof 0.2 mg/kg/day has been established for the rat

Total FCBs: Polychlorinate biphenyls are a group of many synthetic halogenated aromatichydrocarbons which bond tightly to paniculate matter including soils and sediments. As aresult, PCBs are known to be persistent In the environment Reported toxicity values in theliterature for wildlife species exposed to Aroclor include LD50 values greater than

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2,000 mg/kg for Mallards. An LD50 value of 841 mg/kg was established foe albino ratsexposed orally to Aroclor in corn oil for 6 days. At a treatment level of 10 ppm, one deathin six male rats at 29 days of exposure was observed. Results of these investigations yielda total intake of 500 to 2,000 mg/kg Aroclor as the lethal level for dietary exposure of 1 to7 weeks in rats. Chronic toxicity of PCBs has been reported a levels as low as 2 ppra inthe diet of mink, one of die most sensitive species tested. Reproductive failure and death ofoffspring has occurred as a result of exposure. Chronic level NOAELs for ingestion ofPCBs in rats have been reported at 0.005 mg/Kg bw/day

PCBs are known to bioaccumulate and biomagnify through the food chain. Reported BCFsin freshwater fish and invertebrates for PCBs range from 47,000 to 60-

Metals;

Arsenic: Arsenic is a common dement in die environment. Increased levels of arsenicexposure, however, can produce carcinogenic and teratogenic effects. Hie maximumchronic tolerated level of arsenic in grazing animal diet is 50 mg/kg. Reported oral LD50toxicity values in the literature include: 43 mg/kg bw (arsenic trioxide-mouse), 143 mg/kgbw (arsenic ttioxide-rat), 8 mg/kg bw (arsenic pentoxide-rat), 14 mg/kg bw (potassiumarsenlte-rat), 794 mg/kg bw (calcium arsenatc-raouse). Other reported oral toxicity valuesfor arsenic exposure to laboratory animals include: 30 mg/kg bw (mild toxicity to arsenictrioxide-gutoea pig), 15 mg/kg bw (mild toxicity to arsenic ttioxide-rabbit),and 50 mg/kgbw (LD100 for arsenic trioxidc-dog).

Toxic effects of arsenic are different with various animal species and even in strains of thesame species. It was found that solutions of arsenic trioxide are many times more toxicthan the dry powder, and that the high purity compound was less of an irritant to the gastro-

-- intestinal tract than die crude sample, possibly due to the presence of impurities such as(~ 'i antimony .A review of literature utilizing laboratory animal toxicity studies yielded a

NOAJEL of 1.2 mg As/kg bw/day for mouse and dogs and a LOAEL value of 6.4 for dogs.

Arsenic is known to bloconcentrate in organisms, but is not considered a biomagnifier in thefood chain.

Barium: Barium is an element which may be common in many areas. Median lethal dosesin mg/kg bw for ingested barium chloride were reported as 7 to 29 in mice, 90 in dogs, 170la rabbits, 300 to 500 in rats, and 800 to 1,200 in horses. For the less soluble bariumcarbonate, the median lethal doses derived in the literature wete 35 to 56 for cats, 104 to139 in guinea pigs, 200 in mice, 418 to 557 in rabbits, 623 to 800 in chickens, and 1,480 to

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1400 in rats. Rats and mice to 5 mg/1 barium in drinking water for a life-time(approximately 0.25 mg/kgAiay for rats and 0.825 mg/kg/day for mice). No adverse effectswere observed.

Reported LD50 values for various laboratory animals exposed orally to barium include:54 mg/kg bw (barium chloride-mouse), 150 mg/kg bw (barium chloride-rat), 630 mg/kgbw (calcium carbonate-rat), 175 mg/kg bw (barium sOicofluoride-rat). Other toxidtyvalues for laboratory animals exposed orally to barium salts include; LD100 of 350 mg/kgbw for guinea pigs exposed to barium fluoride, LD100 of 121 mg/kg bw for guinea pigsexposed to barium carbonate, LD100 range of 236 to 815 mg/kg bw for rabbits exposed tobarium acetate, and an LD100 of 90 mg/kg bw for dogs exposed to barium chloride. Achronic level NOAEL of 0.85 rag/Kg bw/day has been reported for mouse.

Barium is known to bioaccumukte in aquatic invertebrates and macrophytes, but is notknown to biomagnify.

Beryllium: Limited information on beryllium and its potential terrestrial toxicity arcavailable at this time. A NOAEL of 0,54 mg/kg bw/day for chronic/oral exposure to rats,and a LOAEL of 0.85 mg/kg bw/day (chronic, oral exposure to rats) has beeo reported inthe literature.

Chromium: Although considered an essential dement, elevated exposures to chromiummay produce adverse effects such as tertratogenicity. Chromium toxidty is generallyconsidered to be dependant on a variety of biotic and abiotic factors. In a study conductedin the laboratory a NOAEL of 0.046 mg/kg bw/day was established for rats chronicallyexposed to chromium in the diet

^ Chromium is not considered to biomagnify in the food chain but is known to bioaccumukte^ j in lower trophic level organisms.

Cadmium: Cadmium, a relatively rare heavy metal, is a known teratogen and carcinogen.The maximum chronic tolerated fevei of cadmium in grazing animal diet is 0.05 mg/kg.The degree of cadmium toxicity to mammals varies widely and is influenced by externalfactors. Cadmium exposure can cause derangement in carbohydrate and mineralmetabolism, in renal hepatic, testicular and prostate functions and disturbs the integrity ofthe central nervous system. Mammals are comparatively resistant to cadmium. The lowestoral dose, in mg/kg bw of cadmium (as fluoroborate) producing death, was 250 in rats and150 (as ™\dF"pni fluoride) in guinea pigs.

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Chronic feeding of cadmium at low levels to rats, rabbits, lambs, pigs calves, and poultrycauses diminished growth and feed consumption. Rats tolerate 10 ppm cadmium (ascadmium chloride) in their drinking water, and show no visible symptoms of toxkity, buttheir longevity is reduced.

Various toxicicy values reported for laboratory animals exposed orally to cadmium saltsinclude; LD50 88 nag/kg bw (cadmium chloride-rat), LD50 of ISO m^cg bw (cadmiumfluoride-guinea pig), LD50 660 mg/kg bw (cadmium succinate - rat), LD100 70 mg/kg bw(cadmium chlorides-rabbit), and an LD100 of 27 mg/kg bw (cadmium sulfate-dog).

A review of the literature involving toxicity studies with laboratory animals yielded aNOAEL of 0.004 mg As/kg bw/day and ft LQAEL of 0.014 mg As/kg bw/day.

Freshwater and marine aquatic organisms are known to accumulate cadmium from water at) relatively low levels. Evidence of cadmium transfer through the food chain in aquatic

systems suggests bfonaagnification may occur at the lower trophic levels.

Mercury: Inorganic mercury and its chemical compounds are relatively biologically inertHowever, the addition of an organic group to elemental Hg to form methylmercury (CHSHgor MeHg) markedly increased the lipid solubility and rates of transfer of Hg acrossbiological membranes. It is the organic Hg compounds that pose the greatest threat toanimal health.

In a study on the effect of methyl mercury on adult male river otters, methylmcrcurichydroxide was added to food at levels of 2,4, and 8 jig/g methyl mercury in the diet of theexperimental animals that provided an exposure of 9.3, 17, and 37 mg Hg/kg bw/day. Themean survival time in the experimental groups was 184, 117 and 54 days, respectively.

Mercury transfer to plants occurs almost totally as elemental vapor. Concentrations of 1 to2 ppm Hg in soil are considered toxic to plants.

Reported oral LD50 toxicity values for laboratory animals include; 22 mg/kg bw (mercuricoxide-mouse), 18 mg/kg bw (mercuric oxide-rat), 37 mg/kg bw (mercuric chloride-rat),80 mg/kg bw (mercuric iodide-mouse), 40 mg/kg bw (mercuric sulfate-mouse), 62 mg/kgbw (mercuric acetate-mouse), 110 mg/kg bw (roercuious iodide-mouse), 110 mg/kg bw(mercun>u$ iodide-rat), 297 mg/kg bw (mcrcurous nitrate-rat), 388 mg/kg bw (mercurousnitrate-mouse), 30 mg/kg bw (ethyl mercuric chloride-rat), 60 mg/kg bw (phenyl mercuricchloride) 26 mg/kg bw (phenyl mercuric acetate-mouse) 50 mg/kg bw and (phenyl mercuricacetate-mouse). Other established oral toxicity values from the literature include; 15 mg/kg

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bw (LD100 for dogs exposed to mercuric chloride).

A review of the literature utilizing laboratory animals revealed a NOAEL of 0.003 mg/kgbw/day and a LOAEL of 0.1S mg/fcg bw/day.

Vanadium: Information on vanadium and its toxicity to terrestrial organisms is limited.Review of the literature involving laboratory animals revealed a NOAEL value of 07 rag/kgbw/day and a LOAEL of 2.8 mgAcg bw/day for rats chronically exposed to vanadium.

Endpotot Selection

Information on Fields Brook ecosystem characteristics! chemical stiessois, and potentialeffects information provides a basis for the selection of project endpoints. An endpoint is acharacteristic of an ecological component dial may be effected by a stressor Generally two itypes of endpoints are identified in an assessment These include assessment endpoints andmeasurement endpoints. Measurement endpoints are measurable responses to a stressor thatrelate to the characteristics chosen as assessment endpoints (EPA, 1993).

Based on ousting information currently available for the Fields Brook Floodplain, thefollowing endpoints arc proposed:

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Assessment Endpoint

Reductions in wetland ecosystem diversity

Measurement Endpoint

Decreases in lower trophic level speckspopulations assessed through contaminantanalysis and direct survey

Direct measures of soil/sediment toxicity andbioaccumulation through bioassay

Observations of contaminant impacts onterrestrial plant species

Population decline of higher trophic levelorganisms

Decreases in prey populations

Contaminant concentrations in dietary items

The relationship between the proposed assessment and measurement endpoints is described in theconceptual model for the site. Additional details regarding project endpoints and Die relationship ofendpoints to stzessors and ecological receptors will be provided in Sections 2.5 and 2.6 of the finalworkplan. A conceptual model for the Fields Brook site is provided below.

Conceptual Model Development

The conceptual model hi an ecological assessment involves the development and expression of aseries of working hypotheses on how the identified stressors may effect ecological components ofthe site. Conceptual models can be expressed hi narrative or diagrammatic form. A preliminaryconceptual model for the Fields Brook site, based on current information, is described below. Adiagrammatic representation of the site conceptual model will be developed for the final workplan.A complete conceptual model will integrate information on contaminant fate and transport,potential routes of exposure and potential contaminant effects on receptors.

A modd of potential fate and transport of COECs within the Fields Brook project area has been

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described in Figure 2-5 of the Draft Worfcplan. Contaminants of concern have been transportedfrom primary sources such as industrial processes to secondary sources through previous spills,direct discharge into the stream, and through airborne deposition. Secondary sources ofcontamination which now include surface waters, sediments/soils, and biological organismsthemselves lead to additional exposure through secondary mechanisms that are expected to includeresuspension of sediments* leaching, erosion, infiltration, and ingestion by higher trophic levelorganisms.

The nature, distribution, and concentration of COEC such as VOCs, SVOCs, Heavy Metals, andPCBs, suggests potential exposure to wildlife within the Fields Brook fioodplain may occur throughvarious routes. These may include ingestion of contaminated surface waters, soils/sediments, andplant and animal tissue containing accumulation contaminants; inhalation of volatilizingcontaminants presence in surface and subsurface soils; and direct contact by borrowing and othersmall mammals with soil/sediment contamination* ^

Measures or approaches to assessing contaminant effects at Fields Brook are ultimately dependanton various factors including, the physical and biochemical properties of die contaminant theexpression of contaminant toxicity (Le. reproductive impairment), and the presence and distributionof ecological communities within the areas of documented contamination. The presence of elevatedlevels of PCBs and Mercury, both persistent compounds which are known to biomagnify throughthe food chain, represent potential hazards to higher level organisms. Species such as mink and thegreat blue heron may be at risk from localized population declines as a result of reduced levels ofreproductive success or direct mortality of adults, Elevated levels of PCBs and mercury in dietaryitems for species such as the mink and heron will provided an indication of whether thesecontaminants arc increasing in concentration in the food chain to levels known to be toxic, basedon previous investigations.

In the case of contaminants which arc less persistent and which do not have a tendency to »biomagnify, exposure to lower or mid-trophic level species including species such as small ^mammals and herbivores may effect species number and abundance and reduce wetland diversity.Elevated metals such as cadmium may accumulate in terrestrial and wetland plant tissue leading toexposure to deer, muskrat, and cottontails. Other small mammals such as the shrew may ingestmetals directly or in association with food items such as earthworms. These exposures may lead tovarious effects that ultimately effect survival and fitness.

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Revised Problem Formulation Outline

The revised "Problem Formulation" for the Fields Brook Wockplan is outlined below. Each of themajor project components identified above have been incorporated into die Fields Brook Workplan.

2.0 Problem Formulation

2.1 Site History2.1.1 Initial RI/FS Investigation2.12 SQDI Phase I Investigation2.1.3 Purpose of the SQDI Phase n Investigation

2.2 Current Site Conditions2.2.1 Physical Conditions

2.2.1.1 Physiography2.2.1.2 Geology and Soils2.2.1.3 Hydrogeology2.2.1.4 Land Use2.2.1.5 Climatology

2.2.2 Ecological Communities and Potential Receptors2.2.2.1 Major Terrestrial and Wetland Community Types2.2.2.2 Mqjor Aquatic Communicy Types2.2.2.3 Rare, Threatened, and Endangered Species

2.2.3 Nature and Extent of Contamination2.2.3.1 Results of die SQDI Phase I Investigation2.2.3.2 Results of SQDI Phase H Sampling

2.3 Potential Exposure Pathways23.1 Preliminary Conceptual Site Model

2.3.1.1 Surface Water Exposure Route2.3.1.2 Son/Sediment Exposure Route2.3.1.3 Aquatic and Terrestrial Biota Exposure Route

2.4 Ecological Receptors and Contaminants of Concern2.4.1 Ecological Receptors of Concern (ROCs)

2.4,1.1, Criteria for the Selection of ROCs2.4.1.2 Selected ROCs

2.4.2 Contaminants of Ecological Concern (COECs)14.2.1 Criteria for the Selection of COECs

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2.42.1.1 Development of NOAEL Data2.42.2 Selected CQECs

2.5 Selection of Project Endpointe2.5.1 Assessment Endpoints2.52 Measurwneot Endpoints

2.6 Final Conceptual Site Model2.7 Project Objectives and Data Needs

2.7.1 Soil and Sediment Data Requirements2.7.2 Surface Water Data Requirements2.7.3 Biological Tissue Data Requirements

2.8 Project ARARs

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NOAEL Development

The following attachment describes the procedure used to assess which contaminants of concernshould be retained as COECs. This process included the development of NOAELs and appropriateuncertainty factors.

2,4,2,1 Criteria for the Selection of Contaminants of Ecological Concern (COECs)

Initial screening criteria for selection of COEC's was based on existing soil/sediment cleanupcriteria (Beyer, 1990 and CCME, 1991) which are presented in Table 2-7. The Netherlands havedeveloped criteria for use in evaluating soils (Beyers, 1990). These criteria are intended to provideguidance during decision making in relationship to soil issues ranging from backgroundconcentrations (detection limits) to threshold values that require immediate cleanup. The InterimCanadian Environmental Quality Criteria for Contaminated Sites (CCME, 1991) includes two typesof benchmarks for soil: assessment criteria and remediation criteria. The assessment criteria areapproximate background concentrations or analytical detection limits. Remediation criteria areconsidered generally protective of human and environmental health for specified uses of soil.Comparisons of maximum soil/sediment concentrations to the above criteria were made as an initialscreen of soil/sediment quality in the Fields Brook floodplain (Table 2-7). Chemical contaminantsthat were not excluded under these criteria were further reviewed using toxicologically basedinformation.

The lexicological selection guidelines for selection of final COECs were based upon thecomparison of the maximum observed concentration of each of the contaminants in surfacesoil/sediment to an oral incidental soil ingestion dose derived from a no observable adverse effectlevel (NOAEL), The NOAEL values arc literature derived toxicity values based upon lexicologicalinvestigations using laboratory or wild species. Data related to chronic oral exposure studies(gavage, diet) were used in preference to data derived from intraperitoneal or intramuscularexposure studies. Inhalation data were not included in the toxicity assessments. For similar reasons,the potential for dermal exposure was not addressed in this screen. Where NOAEL information wasnot available* lowest observable adverse effect level (LOAEL) or lethal dose that would effect 50% of the population (LD^) was used The values that were deemed appropriate for this assessmentare presented in Table 2-8.

In the final COEC sciten, the maTimifm observed COECs were compared to develop criteria forchemical concentrations based on incidental ingestion doses of surface soil that could result in no

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adverse effect. Small mammal incidental ingestion rates were used since they provided a moredirect measure of potential contaminant response without use of a complicated food web model.Likewise small mammals ingest soil during feeding, grooming, and burrowing activities and wouldlikely come in direct contact with contaminated soil/sediment most often. Soil dose levels wexedeveloped to the extent that appropriate data were available, A soil ingestion dose was derived bymultiplying the oral ingestion rale (of the applicable test species) to the maximum observed soilconcentration of a COEC (in mg/kg soil). The resulting value was compared to an adjustedliterature derived NOAEL with an applied uncertainty factor. These toxicity values were divided byappropriate uncertainty factors to adjust the level for interspecific differences and safety marginsinvolved with these data comparisons. In all cases an appropriate uncertainty factor was applied(Table 2-9). If the derived soil dose of an COEC exceeded the adjusted literature NOAEL value(NOAEL/appIicable uncertainty factor), it was retained as a final COEC. If die derived incidentalsoil dose of a COEC fell below the adjusted NOAEL value, it was not considered a final COEC forsurface soil (Table 2-10). Tins screening step allows the environmental assessment to focus oncompounds that are most likely to contribute to exposure levels that may cause adverse effects.

Although this is only a screening assessment several assumptions were made. The contaminants ofconcern were 100% bioavaliable, the anomals were exposed to the contaminants 100% of the time,tht 100% of the contaminant was absoibded by the receptor of concern, and that these were theonly known contaminants from the site.

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ChronicChronicChrabcChfoaic

AcuteAcuteAcuteAcuteAcuteAcuteAorteAcute

OiiomcChronicAcoleAcuteAcnieAcmeAcmeAcute

ChromicCtaonkcChronkChroiuc

RcfefCDCd

{NOAEL/ LOAEJL ADM)MactaBicetil.* 1981NALanbeliU 1987Lambctat.t 1987Madceuleetal.,1981Lamb eta]., 1987

Vcnctocrea, 1983Vaxcbocftn. 1983Yendwcna, 1983Vencbuoai, 1983Vendnam, 1983Vendwcrau 1983Vencbueraiv 1983VeradMKiau 1983Baler, 1990EUld, 1990Vendiuevcn* 1983Vf^*»riiiigMMM| 1Q8̂

VendraeicOv 1983Vendraereo, 1983Vencbnerea, 1983

Ofant.1983GfBBt,1983Gfa»t,1983OoAim

K!M

rr

c

f*p >•* ̂ -*Hgese

•Vaf

HIh

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2-9. Uncenaimty Facton Used in Establishing Adjusted NOAEL Values for Soti/Seffimcat Dene Comparisons.

H»aUh Effects

NOABLChronic LOAELSobchfooic LOAELAcute LOAEL. LD50

Factor* Used toConrtrt Effects to*

NOAEL

10100

Factor Appikdfor Intenpactflc

Varlatioo

10101010

TotalDncertainitf

Factor

10101001000

Source: EPA, 1992

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