Davis South Campus Superfund Oversight Committee
Rt.2 Box 2879
Davis, CA 95616
email [email protected]

Regent of the University of California
300 Lakeside Drive, 22^nd Floor
Oakland, CA 94612-3559

Dear Regents,

Enclosed please find a copy of the Agency for Toxic Substance and Disease Registry's (ATSDR) fish hazardous chemical study report for Putah Creek. This report was prepared as part of ATSDR's public health assessment for the LEHR Superfund site on the University of California, Davis campus. ATSDR is conducting public health assessments of all sites listed or proposed for listing on the National Priorities List (NPL or Superfund list). The LEHR site was listed in May of 1994.

I wrote a letter to the Regents on March 17, 1997 advising you of ATSDR's soon to be released report and asked for the Regents to delay their certification of UCD's EIR for its replacement Wastewater Treatment Plant and to delay amending UCD's long range development plan until the Regents and others had an opportunity to review ATSDR's report. It is my understanding that the Regents certified UCD's EIR and amended the LRDP at their meeting March 20^th before reviewing the ATSDR report which was released April 4, 1997.

ATSDR's report confirms the need for UCD to begin to adequately and reliably monitor and investigate all of its wastewater and stormwater discharges to Putah Creek which are causing excessive bioaccumulation of hazardous constituents in Putah Creek aquatic life which represent a public health and/or environmental hazard. The ATSDR report recommends posting Putah Creek to warn the public of a general fish advisory for areas of Putah Creek near the former LEHR site for elevated concentrations of mercury and lead. The recommended follow-up investigation must include more then the LEHR Superfund site discharges as UCD has other wastewater and stormwater discharges to Putah Creek at the location of the LEHR site study where excessive bioaccumulation of hazardous chemicals was found. It is important to note that excessive concentrations of hazardous chemicals were not found in fish tissue either upstream or downstream of the area where UCD's wastewater treatment plant discharges its partially treated wastewaters to the Creek. The ATSDR report confirms what the public has been stating for years that "UCD's wastewater and stormwater discharges are putting the public health and the environment at risk."

One of the reasons that I requested the Regents delay their certification of UCD's EIR is that Dr. G. Fred Lee, an internationally recognized expert on water quality issues, found in his review ("Review of the Technical Deficiencies in the University of California, Davis Draft Environmental Impact Report for the Wastewater Treatment Plant Replacement Project dated October 1996, Comments submitted by G. Fred Lee, PhD, DEE, December 1996) of UCD's campus wastewater treatment plant proposed replacement facility's EIR that the proposed replacement facility will be inadequate and will most likely not be effective in treating some of the waste in the wastewater which will be discharged to Putah Creek. Dr. Lee presented his comments before the ATSDR report was made available to him and the public. Now ATSDR's report confirms that the public should be even more concerned that the UCD replacement plant will allow UCD's wastewater discharges to continue to place public health and the environment at risk.

DSCSOC requested UCD to prepare a credible LEHR storm and surface water runoff monitoring plan before the first storm event of the 1996-1997 season as part of the LEHR site investigation. To date, UCD has not presented a plan and another season of storm events has passed. There is a need for those in authority at the University of California to request that UCD immediately, adequately and reliably investigate and monitor its wastewater and stormwater discharges and there is a need for the Regents to reconsider UCD's EIR for the Replacement Wastewater Treatment Plant in order to protect the public and the environment from the risks associated with UCD's wastewater and stormwater discharges.

I have enclosed a copy of Dr. Lee's review of the ATSDR report which he provided to me.

If any of the Regents have questions about Dr. Lee's comments, please contact him. If you have questions about this letter or DSCSOC, please contact me.

Sincerely,

Julie Roth, Ex. Dir.

cc: Governor Pete Wilson
Dr. G. Fred Lee
Dr. William H. Taylor
James Strock
Chancellor Larry Vanderhoef
Yolo County Environmental Health
Solano County Environmental Heath

Health Consultation
Fish Sampling in Putah Creek, 1996
Laboratory for Energy-Related Health Research
Davis, California

CERCLIS NO. CA2890190000

April 4, 1997

Prepared by
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Federal Facilities Assessment Branch
Energy Section

BACKGROUND

The Agency for Toxic Substances and Disease Registry (ATSDR) is mandated by Congress under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to conduct public health assessments at all sites listed or proposed for listing on the National Priorities List (NPL, or Superfund list). The Laboratory for Energy-Related Health Research (LEHR) in Davis, California, was listed on the NPL in May 1994.

ATSDR staff first visited the LEHR site in July 1995. As a result of that visit and after reviewing documents pertaining to the site, we issued a site summary report in December 1995. In that report, we recommended that the fish in Putah Creek, adjacent to the LEHR site, be sampled to ensure that people who eat the fish from the creek are not being exposed to unsafe levels of contamination. As a followup to this recommendation, ATSDR asked the Environmental Protection Agency's (EPA's) National Air and Radiation Environmental Laboratory (NAREL) to assist us by collecting and analyzing fish from Putah Creek near the LEHR site. NAREL completed the fish screening survey in September 1996, and this report contains a summary of the results of that study.

EPA NAREL staff asked EPA Region IX scientists to help with this fish survey. EPA Region IX scientists collected a total of 141 fish and crayfish from four locations along Putah Creek in a two week period during August and September 1996. They also collected water and sediment samples from the creek at the same four locations. They packaged the samples and sent them to the NAREL in Montgomery, Alabama, for analysis. NAREL scientists filleted the fish and removed the crayfish tails and, in some cases, combined them to have enough sample for analysis [1].

We have attached the data from the laboratory analyses of fish, water, and sediment collected from Putah Creek to the end of this report. ATSDR scientists and NAREL scientists reviewed the NAREL data [2]. ATSDR offers the following conclusions and recommendations:

CONCLUSIONS

1. Mercury and lead concentrations in some fish collected from Putah Creek pose a public health hazard.

2. Based on the samples that EPA Region IX collected in August and September 1996, neither the water nor the sediment in Putah Creek directly poses a public health hazard.

3. Radionuclides, organic pesticides, polychlorinated biphenyls (PCBs), and metals other than mercury and lead were not present in the fish, water, or sediment collected from Putah Creek in concentrations that pose a public health hazard.

RECOMMENDATIONS

1. Conduct an additional fish study to define the concentration of mercury and lead in different fish species within selected length ranges.

2. Until further data are available, post a general fish advisory for areas of Putah Creek near the former LEHR site; elevated concentrations of mercury and lead in the collected fish justify the advisory.

DISCUSSION

Mercury and lead in fish and crayfish collected from Putah Creek were present at levels that pose a public health hazard. The fish and crayfish that contain elevated levels of mercury or lead were collected at the location (Site #1) nearest the LEHR site. The high concentrations of mercury (0.69 milligrams of mercury per kilogram of wet fish [mg Hg/kg-wet fish]) and lead (1.06 milligrams lead per kilogram of wet fish [mg Pb/kg-wet fish]) were measured in two separate composites of fish fillets (or fish fillets and crayfish tails); each composite was made up of three different species of fish (six species in all). Composite 1 at Site #1 had approximately four times the mercury concentration of Composite 2, and Composite 2 had approximately four times the lead concentration of Composite 1. These data suggest that the bioconcentration of mercury and lead may vary by species of fish. In addition, because these samples are composites, these data reflect average concentrations. This means that one or two fish species may have much higher levels of mercury or lead than the maximum levels reported, and other species may have little or no mercury or lead.

ATSDR scientists note that the highest concentrations of mercury and lead reported by NAREL in these samples are higher than concentrations that may be considered toxic to people who would eat these fish frequently. The actual hazard to people depends on how often the people eat the contaminated fish and how much of the fish they eat. Because we do not know how much fish people actually eat from Putah Creek, we based our evaluation on estimated average fish consumption rates for the general U.S. population [3, 4].

Our conclusions and recommendations are based on a limited amount of data because we combined many fish into composite samples to have sufficient sample sizes to perform all the analyses we had planned.

We found that contamination is not at levels that pose a health hazard in the water or sediment. However, lead was in all the sediment samples, and mercury was in those sediment samples from Site #1--the same location where the fish with the highest concentration of mercury were collected.

Mercury and lead are especially toxic to fetuses, infants, and children. Both mercury and lead affect the central nervous system; both methylmercury (the most prevalent form of mercury found in fish) and lead are able to cross the placental and blood-brain barriers in children and cause permanent brain damage. Early signs of mercury poisoning are often nonspecific, e.g., malaise, blurred vision, or hearing loss; higher blood levels of mercury will cause kidney damage. Effects of lead poisoning in children are similar to those of mercury poisoning: impaired neurological development, lower IQ scores, and hearing loss. At significantly elevated blood levels, lead can interfere with normal cell metabolism and induce anemia [5, 6].

We recommend additional fish sampling to differentiate mercury and lead contamination across different species and sizes of fish in Putah Creek. Fish size or length is a surrogate for fish age. Since the fish can bioconcentrate the contaminants (mercury and lead), we expect the older fish will have the highest concentrations of contaminants. Additional fish sampling can clarify whether people who catch fish in Putah Creek should limit their consumption of those fish to certain species and size. Unlike the initial screening survey, which investigated many different contaminants and required large sample weights for the large number of different analytes, the next fishing survey should have to address mercury and lead contamination only. The laboratory analyses for mercury and lead require only small amounts (50 grams wet weight, total) of fish.

For questions or comments, please contact Dr. William H. Taylor, Health Assessor, Agency for Toxic Substances and Disease Registry, Mailstop E-56, Atlanta, Georgia 30333, 404-639-6035.

ATSDR is performing a public health assessment on the LEHR Site. The ATSDR public health assessment is scheduled for release in 1998.

PREPARERS OF REPORT

William H. Taylor, PhD
Health Assessor
Federal Facilities Assessment Branch
ATSDR

Clinton Cox, PhD, CIH, PE
NAREL

REVIEWERS OF REPORT

Burt J. Cooper
Chief, Energy Section
Federal Facilities Assessment Branch
ATSDR

Sandra G. Isaacs
Chief, Federal Facilities Assessment Branch
ATSDR

J. Scott Telofski, PE
NAREL

Vicki D. Lloyd
NAREL

WRITER-EDITOR

Ronald E. Hatcher
Program Evaluation, Records and Information Services Branch
ATSDR

REFERENCES

1. Environmental Protection Agency, National Air and Radiation Environmental Laboratory. Sampling and analysis guidelines for fish, sediment, and water samples from the Putah Creek adjacent to the former Laboratory for Energy-Related Health Research, Davis, CA. 1997 Aug 24.

2. Environmental Protection Agency, National Air and Radiation Environmental Laboratory. Concentrations of selected radionuclides and chemicals in fish, sediment, and water collected from the Putah Creek near the former Laboratory for Energy-Related Health Research, Davis, CA. 1997 Mar 31.

3. Environmental Protection Agency. Guidance for assessing chemical contamination data for use in fish advisories, volume 1, fish sampling and analysis, second edition; 1995 Sep. Report No.:EPA 823-R-95-007,

4. U.S. Department of Agriculture. Food and nutrient intakes by individuals in the United States, 1 day, 1987-1988, nationwide food consumption survey; 1993 Sep. Report No.: 87-I-1.

5. Agency for Toxic Substances and Disease Registry. Toxicological profile for mercury (update). Atlanta: US Department of Health and Human Services, Public Health Service, 1994.

6. Agency for Toxic Substances and Disease Registry. Toxicological profile for lead (update). Atlanta: US Department of Health and Human Services, Public Health Service, 1993.

DATA TABLES FROM ATSDR / EPA NAREL FISH SAMPLING SURVEY, PUTAH CREEK, DAVIS CALIFORNIA, AUGUST-SEPTEMBER 1996

Table 1. Sampling Locations in Putah Creek Adjacent to the LEHR Site, Aug 27-Sep 12, 1996

"Figure" 1. Putah Creek Sampling Locations

Table 2. Fish Collected from Putah Creek near the Former LEHR Facility, Aug 27-Sep 12, 1996

Table 3. Radiological Results for Water Collected from Putah Creek near the Former LEHR Facility

(y) -- measured by gamma spectrometry with a corresponding radiochemical analysis. ND -- not detected.
NA -- not analyzed. X -- designates a replicate analysis.
* Replicate analysis: Sr-89, 7.47±4.96 pCi/L; Sr-90, -0.750±0.740 pCi/L.
"Less than value" is equal to the Minimum Detectable Concentration (MDC).

Table 4. Inorganic Results For Water Collected From Putah Creek Near The Former LEHR Facility