Comments on UCD Bioaccumulation Studies

G. Fred Lee, PhD, DEE
G. Fred Lee & Associates
27298 E. El Macero Dr.
El Macero, California 95618-1005

Via em: [email protected]

July 2, 1997

Brian Oatman
Associate Environmental Engineer
University of California
Environmental Health and Safety
Davis, CA 95616

Dear Brian:

Following up on the last UCD - DOE LEHR national Superfund site RPM meeting and my FAX to you bringing to your attention Robert Brodberg, the person who I believe would be a key person to contact concerning California Department of Health Services' approaches for issuing a fish consumption advisory for Putah Creek based on the ATSDR data, as I mentioned, recently I have been involved in helping to establish a bioaccumulation monitoring program for fish in the Sacramento River watershed. This is part of the Central Valley Regional Water Quality Control Board's Watershed Initiative. A panel of several of us have been responsible for developing an overall study program for bioaccumulation on the Sacramento River system. The initial focus is on the main stem of the river and its major tributaries; it does not include smaller tributaries such as Putah Creek. Mr. Brodberg is part of this group.

While as I mentioned at the RPM meeting I doubt that, based on correspondence in connection with our e-mail network on bioaccumulation issues, DHS would support formally listing Putah Creek near the UCD campus wastewater discharges with a fish consumption health advisory based on only the ATSDR data, this does not mean that UCD should not post this area warning people that the fish in Putah Creek near the campus wastewater discharge at Old Davis Road have been found to contain excessive concentrations of mercury and lead. While some within the UCD L. Vanderhoef administration are trying to minimize the significance of this situation and confuse the public and others about its importance, the facts are that if anything, the concentrations of higher trophic level fish in that area will be even higher than the average concentrations that were found in the ATSDR's studies since typically higher trophic level fish tend to bioaccumulate more.

This posting should be done independent of the concentrations at other locations. For the UCD L. Vanderhoef administration to ignore the ATSDR's recommendations on this could put this administration and members of it in a significant liability situation. Should someone who has been or continues to consume fish from this area assert that they have been damaged because of consuming fish under conditions where the University administration knew that this situation existed and that there is considerable evidence that it is related to UCD's wastewater dischargers/stormwater runoff.

With respect to the comments made by UCD staff at the RPM meeting about a UCD researcher providing advice on mercury studies, if this researcher is Slotton, he is part of the group with whom I am working on Sacramento River watershed issues. It is important that UCD's future work include proper evaluation of the potential critical concentrations of mercury in accord with the latest work. Some of the previous UCD work in this area has failed to recognize and report on the concentrations of mercury that are now considered by the US EPA to be adverse to human health. These are on the order of about 0.1 mg/kg for individuals who consume one meal of fish per week. Further, UCD should get individuals involved who understand aquatic chemistry of mercury and how to do forensic studies to trace mercury back to its sources. Based on the ATSDR data, there is little question that at least part, and possibly a substantial part, of the mercury that is bioaccumulating in fish is from UCD's wastewater sources.

It is also important for UCD to not ignore the possibility of chlorinated hydrocarbons arising from UCD's wastewater discharges and stormwater runoff being present in Putah Creek fish at excessive concentrations. As I have previously pointed out, the ATSDR studies did not properly measure some of the chlorinated hydrocarbons that are of concern at sufficiently low concentrations to determine if excessive concentrations are present in fish tissue.

If you have any questions about these comments, please contact me.

Sincerely yours,


G. Fred Lee, PhD, DEE
Copy to: J. Roth

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