PUBLIC HEALTH ASSESSMENT
WASHINGTON NAVY YARD
WASHINGTON, DISTRICT OF COLUMBIA
Washington Navy Yard (WNY), an active military facility, encompasses 63.3 acres of land in southeastern Washington, D.C. It lies on the Anacostia River in a heavily urbanized area with industrial, commercial, residential, and vacant properties in the immediate vicinity. Since its inception in 1799, WNY has supported diverse functions, including shipbuilding (in the 1800s), ordnance research and production (mid-1800s to 1962), and administrative duties (1962 to present). WNY employed nearly 25,000 on-site workers at its peak operation during World War II. Currently, approximately 5,400 military and civilian personnel work at WNY.
WNY was proposed for listing on the U.S. Environmental Protection Agency (EPA) National Priorities List in 1998, primarily because of contamination detected in the adjacent Anacostia River, on-site sediment, and on-site soil (USAF 1998). Past activities at WNY have also impacted groundwater underlying the property and contributed to contamination found in fish from the Anacostia River. The primary contaminants of concern are metals (metals in groundwater and lead in surface soil), polychlorinated biphenyls (PCBs) (in sediment and fish), and dioxins (in sediment). These contaminants, as well as some petroleum hydrocarbons, pesticides, and other semi-volatile organic compounds, have been detected at levels above the Agency for Toxic Substances and Disease Registry's (ATSDR) health-based comparison values.
ATSDR conducted site visits in February and September of 1999. ATSDR learned that local community members had expressed concern about the environmental quality of the Anacostia River in the WNY vicinity, but did not identify any specific community health concerns attributed to WNY.
ATSDR reviewed and evaluated groundwater data. Metals were detected slightly above ATSDR comparison values for drinking water. There is, however, no known public exposure to groundwater contaminants. Washington, D.C., receives its drinking water from an area of the Potomac River, which is not impacted by the WNY sites, and is far upstream of the city. WNY is connected to the Washington, D.C., drinking water system. Because there is no known public exposure to groundwater underlying WNY, ATSDR concludes that it poses no apparent public health hazard.
To address community concerns about the environmental quality of the Anacostia River, ATSDR reviewed surface water and sediment quality data from both on- and off-site locations. Although some contaminants appear to originate from upstream, non-point sources, the WNY storm sewer system and outfalls have also contributed contaminants, primarily metals, to the river pollutant load. How much of the pollution originated from WNY operations is not known. Contaminants were detected primarily in sediments, both in the WNY storm sewer system and the Anacostia River. PCBs are the primary contaminant of concern, although polycyclic aromatic hydrocarbons, metals, pesticides, and dioxins were also detected above ATSDR comparison values. However, minimal, if any, public exposure occurs to the surface water and sediment of the Anacostia River because local residents do not swim or drink from WNY runoff, outfalls, or the Anacostia River. Any incidental exposures to the detected levels of contaminants in local surface water and sediment are not expected to pose a public health hazard. Therefore, ATSDR concludes that past, current, and future exposures to on- and off-site surface water and sediment pose no apparent public health hazards.
ATSDR also reviewed on-site soil data and evaluated potential public health exposure at 17 locations at WNY where past industrial operations resulted in contamination. Sixteen of the 17 sites are not associated with any known public health hazards because: 1) no site-related contaminants are present where exposure to the public could occur; 2) contaminant concentrations detected are too low to pose a health hazard; and/or 3) past and current exposures to the general public have been prevented. The other site, Admiral's Row (Site 10), contained lead concentrations in surface soil above the ATSDR comparison value for soil. Due to insufficient historical data on the extent of and exposure to this lead contamination, the exact health implications from past exposures cannot be assessed. Current and future exposures have been prevented by interim measures implemented by the Navy, including fencing, sign posting, land use restrictions, and public education efforts. ATSDR concludes that current and potential future exposures to on-site soil pose no apparent public health hazards. Past soil exposure to Admiral's Row surface soil is a completed exposure pathway with the potential for adverse health effects to children, but, due to the lack of historical data, the health implications from past exposure can not be assessed.
The consumption of locally-caught fish is another completed exposure pathway in the WNY vicinity. Fish in the lower Anacostia River near WNY have been impacted primarily by PCBs, although metals, pesticides, and dioxins were also detected in tissue samples. Detected concentrations of PCBs and the pesticide chlordane in local fish may pose a public health hazard if consumed in sufficient quantities. The Washington, D.C. Department of Public Health issued an initial fish consumption advisory in 1989 and an updated advisory in 1994 that urges the general public not to eat catfish, carp, or eel and limit consumption of largemouth bass, sunfish, and other fish. The advisory encourages the practice of catch-and-release. Despite this advise, some citizens continue to eat fish and eel caught from the lower Anacostia River near WNY. ATSDR concludes that a past, current, and future public health hazard could exist for anglers who routinely have consumed or continue to consume sufficient amounts of locally-caught fish; the fish consumption advisory for the Anacostia River should continue to be observed.
ATSDR concludes that groundwater, surface water, and sediment at WNY do not pose public health hazards. However, past exposure to on-site surface soil at Admiral's Row is a completed exposure pathway with the potential for adverse health effects to children. ATSDR also concludes that consumption of locally caught fish could pose a public health hazard in the WNY vicinity.
The Washington Navy Yard (WNY) is an active military facility located on 63.3 acres of urban land bordering the Anacostia River in southeastern Washington, D.C. (Figure 1). WNY began operations in 1799 as a shipbuilding facility (NFEC 1996). Today, it is the Navy's oldest shore station and the longest continuously operated federal facility in the United States (NGF no date).
WNY operations and its primary role have evolved over the past two centuries. Shipbuilding dominated yard activities in the early 1800s, giving way to canon and large gun manufacturing for ships in the mid-1800s (NFEC 2001). Until 1962, ordnance production was the principal WNY function (NGF no date). From 1962 to present, the primary activity of the WNY has been administrative (Navy 2001).
As WNY's function changed over the years, so did the yard's physical size. Historically, additional property was added by filling a shallow embayment of the Anacostia River and a tributary entering the Anacostia River from the north. During World War II, at its largest, the yard occupied approximately 127 acres. As WNY's role shifted from primarily manufacturing to administration, 63.5 acres of the facility were sold to the General Services Administration (GSA) for administrative purposes (NFEC 1996).
WNY has identified a number of potential waste sites that have resulted from historical and modern-day industrial operations. Most WNY contamination, however, occurs in limited access areas of the site. One of the key contaminants of concern found on site, however, is lead in surface soil from peeling lead-based paint that has flaked off of Admiral's Row buildings. Some other contaminants exist in sediment and surface water of the adjacent Anacostia River, though they are not necessarily associated with WNY operations. These off-site contaminants include metals (lead, arsenic, mercury, iron, beryllium), polychlorinated biphenyls (PCBs), polycyclic aromatic hydrocarbons (PAHs), volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs), and polychlorinated dibenzo-p-dioxins (PCDDs or "dioxins") (Navy 2001).
Investigations at WNY began in 1985, after WNY submitted a "Notification of Hazardous Waste Activity" to the United States Environmental Protection Agency (EPA) and identified itself as a generator of hazardous wastes (specifically PCBs). In 1988, the Naval Energy and Environmental Support Activity prepared a preliminary assessment (PA) report that indicated the presence of petroleum releases in soil and groundwater at WNY. As a result of these findings, numerous environmental investigations have been conducted, are ongoing, or have been planned to further determine the nature and extent of environmental contamination associated with WNY activities. In further investigating the site, the Navy and EPA signed a final Resource Conservation and Recovery Act (RCRA) Consent Order, effective on July 16, 1997, to conduct a two-phase RCRA facility investigation (RFI) and perform a corrective measures study (CMS). The RFI was intended to further investigate WNY sites, characterize contaminant sources, confirm contaminant releases, and assess environmental and human health impacts; the CMS also identifies and evaluates site-specific remediation options, if necessary.
In April 1998, the Navy, Department of Justice, and the Earthjustice Legal Defense Fund (formerly the Sierra Club Legal Defense Fund) negotiated an agreement on cleanup of the site, known as the Earthjustice Consent Decree, after Earthjustice expressed concern about potential Anacostia River hazards and about the timeliness of Navy cleanup activities. Later that same year, EPA placed WNY on its National Priorities List (NPL) (on August 27, 1998), part of EPA's Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as "Superfund." As a Superfund site, the RCRA Consent Order activities have been integrated into the Navy's CERCLA remediation obligations. On June 30, 1999, EPA and Navy officials and the D.C. Mayor's office signed a Federal Facilities Agreement (FFA). The FFA was signed to ensure that environmental impacts from past operations were thoroughly investigated and appropriate remedial actions are undertaken to protect people and the environment. Future cleanup activities at WNY will continue under the requirements of CERCLA and the Department of Defense Installation Restoration Program.
Through various environmental investigations, the Navy evaluated conditions at 17 sites at WNY including basewide groundwater. Among the sites investigated are facilities that were once used for automotive maintenance operations, foundry operations, gun assembly, or laundry services. Following preliminary investigations, eight of the sites have been recommended for no further action (sites 1, 2, 3, 5, 8, 9, 14 and 17). Further investigations are underway at seven sites requiring additional study (4, 6, 7, 10, 11, 13, 15), including RCRA actions at Sites 4 and 6. Remedial investigation (RI) activities have been completed at Site 16. The Navy is also continuing its investigation of the groundwater beneath the site to further characterize the extent and magnitude of contamination.
To reduce and control the spread of contamination, the Navy conducted removal of contaminated soil and sediment at several sites. Removal of sediment from the storm sewer system has been completed as well as the rehabilitation of the storm sewer lines. At Site 16, one cubic foot (5 gallons) of subsurface soil containing free-phase mercury was removed from beneath a parking lot. At site 13, PCB contaminated soil near building 290 was removed. Although the removal of lead-contaminated soil from Admiral's Row, Site 10 (NFEC 2001, Navy 2001) is proposed, soil is currently being managed in-place until a risk assessment can be completed. The Navy has also conducted site removal evaluations at Sites 7 and 11. The results of the evaluations indicate that no removal activities were warranted at these locations.
To characterize the population and identify the presence of sensitive subpopulations, such as young children, in the vicinity of WNY, the Agency for Toxic Substances and Disease Registry (ATSDR) examines the demographics of the nearby communities. This information also provides details on residential history in a particular area that helps ATSDR assess time frames of potential human exposure to contaminants. The demographic and housing data for WNY and the surrounding areas, historically and at present, are outlined in this section. Current demographics are based on U.S. Census data from 1990 (Figure 2). Based on the 1990 data, there are approximately 50,528 people residing within one mile of WNY.
WNY lies in an urban setting and adjacent land use varies considerably. Within less than a one mile radius of the facility there are industrial, commercial, residential, and vacant properties. WNY is bordered on the north by commercial and vacant commercial properties along M Street, on the east by an abandoned industrial area along 11th Street, on the west by the Southeast Federal Center owned by GSA, and on the south by the Anacostia River (Figures 1 and 2).
The WNY facility itself consists of administrative, supply, and storage buildings; residences; and training facilities (Figure 3). Approximately 9 acres of WNY has been listed on the National Register of Historic Districts. The district includes a Naval museum that was opened to the public in 1993 (WNY 2001). Almost 95% of the WNY is covered by buildings, asphalt, and other impervious surfaces (CH2MHILL 1999). Two combined and one separate storm sewer pipes owned by Washington, D.C., underlie WNY and flow into the Anacostia River. Another separate storm sewer pipe owned by the city that runs beneath 11th Street had accepted storm water from WNY in the past. Since storm sewer renovations, WNY connections to city owned lines have been removed and rerouted to other separate storm sewers operated by the Navy. Many of the former industrial and storage buildings have been converted to office buildings. Additional renovations are currently underway at several more buildings to create more office space for future employees.
Throughout its history, WNY has provided thousands of jobs for D.C. area residents. At the turn-of-the-century, WNY employed approximately 2,000 individuals. When the facility was operating at its peak, during World War II, nearly 25,000 people worked at WNY. Today, WNY employs an average of 5,400 military and civilian personnel. WNY is headquarters for the Naval Sea Systems Command, with a population of 10,500 (Brief History Fact Sheet no date; ATSDR 1999a, Navy 2001).
Admiral's Row (Site 10) along Warrington Avenue consists of an on-site residential area and Leutze Park. In the past, the area supported 20 residential quarters and 3 buildings (some residential) (CH2MHILL 1998). The quarters and buildings were multi-storied and painted with lead paint. Leutze Park is an unfenced recreational area that is used for public access and as a parade ground for official change of command and retirement ceremonies. Luetze Park is the only substantial on-site vegetated area. (NFEC 1996). Historically, the quarters and buildings housed several hundred Naval officers and their family members. (It is unknown how many children or what age children lived in these residences in the past.) Today, only the quarters are used to house the 15 to 20 families that currently reside at WNY (Navy 2001). No new housing construction is planned for WNY (Navy 2001).
Access to the entire site is restricted by a perimeter wall. Security guards are stationed at gate entrances. Individuals with direct access to the site include on-site employees, on-site residents, and on-site workers under contract with the Navy to conduct various building and lawn maintenance activities. Adult and child visitors and recreational users may also pass through security clearance. Bus tours are conducted on site and the Navy Museum (Building 76) receives visitors daily (except holidays). (As of January 2000, the Navy Museum building was closed for renovations. During renovations, visitors could view the exhibits at the Navy Museum Annex [Building 70] and at the Navy Art Gallery [Building 67]). Willard Park, across from the Navy Museum on the banks of the Anacostia River, is visited by the public. The park displays naval ordnance used in battle from the Civil War to the Vietnam era (WNY 2001).
WNY lies on the banks of the Anacostia River in a historically natural wetlands area that has been filled to accommodate urban development expansions. Prior to 1800, approximately one-third of WNY property was covered by a shallow embayment, but wetlands no longer exist in the WNY vicinity. Upstream from WNY and outside of Washington, D.C., agricultural and forested areas remain and drain into the large Anacostia River watershed. Less than two miles downstream from WNY, the Anacostia River merges with the Potomac River and flows into the Chesapeake Bay.
Washington, D.C., receives its drinking water from an area of the Potomac River, which is not impacted by the WNY sites, and is far upstream of the city. WNY is connected to the Washington, D.C., drinking water system. There are no private wells in the vicinity (Miller 1999).
Many groups have been formed to protect the natural resources of the Anacostia River and other water bodies in the area. In 1999, the Anacostia Watershed Toxics Alliance was formed to review existing research data and evaluate the entire watershed.
In July 1998, ATSDR published a Health Consultation for the Anacostia River Initiative, Washington, D.C. (ATSDR 1998). This Health Consultation did not specifically address environmental contamination issues related to WNY, but evaluated the safety of consuming fish caught in the Anacostia and Potomac Rivers. ATSDR concluded that the reported concentrations of chemical residues in fish from the Anacostia and Potomac Rivers could pose a public health hazard for sport anglers.
In February 1999, ATSDR conducted a site visit at WNY. ATSDR viewed on-base sites and remediation efforts, as well as off-base residential areas, the GSA property, and both sides of the Anacostia River. ATSDR met with representatives from the Naval District Washington, the Naval Facilities Engineering Command, the Naval Research Laboratory, EPA Region III, and the Washington, D.C., Department of Public Health. ATSDR did not identify any specific community health concerns attributed to WNY, but learned that local community members had expressed concern about the environmental quality of the Anacostia River in the WNY vicinity (ATSDR 1999a).
Due to changes in technical staff, ATSDR conducted a follow-up site visit in September 1999. No additional public health issues or community concerns were identified by ATSDR during the site visit. In June 2000, ATSDR met with the Washington Navy Yard Restoration Advisory Board (RAB) and presented an overview of ATSDR and the public health assessment process. Prior to the RAB, we met with representatives of the DC Department of Health and others agencies to let them know of our activities. Navy representatives gave ATSDR an off-site tour of areas surrounding WNY.
ATSDR held public availability sessions on September 26 and 27, 2000, to obtain community concerns. The sessions were held at the Van Ness Elementary School and the Anacostia Park Pavilion. Although the general public did not attend these sessions, ATSDR spoke with representatives of the National Park Service and The Student Conservation Association, Inc. and fishermen fishing in Anacostia Park. No public comments were received during the public comment period for this assessment, September 28 through October 31, 2001. However, ATSDR received comments from the Navy (Navy 2001) and DC Department of Health (DC Department of Health 2001b) and made revisions, which are included in this final Public Health Assessment.
In preparing this public health assessment, ATSDR reviewed and evaluated information provided in the referenced documents. Documents prepared for the CERCLA program must meet specific standards for adequate quality assurance and control measures for chain-of-custody procedures, laboratory procedures, and data reporting. The environmental data presented in this public health assessment are from Navy remedial site investigations, Anacostia River monitoring data; municipal drinking water reports; and other information provided primarily by Navy, EPA, and Washington, D.C. Department of Public Health reports. Based on our evaluation, ATSDR determined that the quality of environmental data available in most site-related documents for WNY is adequate to make public health decisions.
In this section, exposure pathways are evaluated to determine whether people accessing or living near WNY could have been (past scenario), are (current scenario), or will be (future scenario) exposed to site-related contaminants. In evaluating exposure pathways, ATSDR determines whether exposure to contaminated media has occurred, is occurring, or will occur through ingestion, dermal (skin) contact, or inhalation of contaminants. If the contamination is located in an area where exposure is not likely, no public health hazard will be expected to occur (for instance, where contaminated soil is located in an area that is fenced and access is restricted). Exposure to contaminants does not necessarily result in adverse health effects. For a health hazard to be possible, the contaminants must be present in large enough amounts to cause harm, and the exposure must be for a long enough time for the effect to be possible. To determine whether completed pathways pose a potential health hazard, ATSDR compares contaminant concentrations to health-based comparison values.
Comparison values are calculated from available scientific literature on exposure and health effects. These values, which are defined for each of the different media, reflect the estimated maximum contaminant concentration for a given chemical that is not expected to cause adverse health effects, given a standard daily ingestion rate and standard body weight. If contaminant concentrations are above comparison values or background concentrations, ATSDR further analyzes exposure variables (for example, duration and frequency) and the toxicology of the contaminant. This exposure evaluation process is summarized in Figure 4.
ATSDR evaluated available information on underlying groundwater, local surface water, the WNY investigation sites (Figure 3), and locally-caught fish to determine if they pose any past, current, or potential future public health hazards. After fully evaluating potential human exposure pathways at WNY, ATSDR concluded that public exposures (past, current, and future) to groundwater, surface water, sediment, and most soil are not expected to result in adverse human health effects. No adverse health effects are anticipated because contamination in these media is below levels of health concern or there is no public exposure. ATSDR identified past exposure to on-site Admiral's Row surface soils and the consumption of locally-caught fish as completed exposure pathways. Information on the various contaminated media, exposure pathways, and exposure doses is summarized in Table 1, Appendix A, Appendix B, Appendix C, and the following text. Appendix D provides a glossary to explain related key words and terms.
The following discussion evaluates community concerns about potential human exposure via contaminated groundwater, surface water, sediment, soil, and locally-caught fish. ATSDR's conclusions regarding the past, current, and potential future exposures to the various environmental media on and in the vicinity of WNY are based on an evaluation of information gathered from site investigations, groundwater monitoring data, surface water investigations, and observations compiled during site visits.
Could contaminants in groundwater result in adverse human health effects for local employees, residents, or visitors?
- Past activities at WNY affected groundwater underlying military property. Metals are the main contaminants of concern.
- On-site residents, employees, and visitors are not exposed to contaminated groundwater; drinking water is supplied and monitored by a municipal source that meets Washington, D.C., and federal and state drinking water standards. There is no known public exposure to groundwater contaminants.
Although groundwater underlying Washington, D.C., generally occurs in unconfined conditions, the fill and underlying clay at WNY result in semi-confined conditions (CH2MHILL 1999). On a small scale, the heterogeneous nature of the fill material likely influences the direction of groundwater flow beneath WNY. Due to WNY topography, the underlying watertable level varies, from approximately 55 feet above sea level in the northeast corner to slightly above sea level along the waterfront (NFEC 1996). The Anacostia River is believed to be the ultimate discharge point for shallow groundwater (CH2MHILL 1999).
The surrounding community obtains drinking water from the Washington, D.C., municipal drinking water system, a routinely-monitored municipal source that meets Washington, D.C., and federal and state drinking water standards (e.g., EPA's maximum contaminant levels [MCLs]). There are no private wells in the vicinity (Miller 1999). Current and future exposures to contaminated groundwater are unlikely because there are no known users of groundwater as a drinking water supply in the vicinity of WNY. There are no future plans to place potable wells in the area (ATSDR 1999a). WNY and the surrounding community will continue to receive water from the Washington, D.C., municipal drinking water system (ATSDR 1999a).
Past activities at WNY affected groundwater underlying military property. VOCs, SVOCs, and metals were detected in groundwater underlying WNY, most at concentrations below ATSDR comparison values for drinking water. Methylene chloride (detected up to 17 parts per billion [ppb]) and chloroform (up to 12 ppb), were the only VOCs exceeding their respective ATSDR comparison values for drinking water (5 ppb and 6 ppb, respectively) (NFEC 1996, NFEC 1999). Methylene chloride also exceeded EPA's MCL of 5 ppb. Both methylene chloride and chloroform are believed to be laboratory contaminants and not site-specific contaminants (Navy 2001). Acetone, 1,2-dichloroethene (total), acenaphthene, fluorene, butylbenzylphthalate, bis(2-ethylhexyl)phthalate, and di-n-octylphthalate were frequently detected at concentrations at or below ATSDR comparison values. Seventeen metals were detected in the groundwater. Metals detected at levels above ATSDR comparison values included aluminum, arsenic, barium, beryllium, iron, lead, manganese, and vanadium. Lead in groundwater underlying WNY exceeded the federal action level of 15 ppb at the following sites: 2, 4, 5, 6, 7, 17, and the Navy Yard monitoring wells (NFEC 1996). Petroleum-impacted groundwater at Site 16 is being remediated (Navy 2000).
Appendix A summarizes sampling results for each site. Groundwater samples were collected from Sites 2, 3, 4, 5, 6, 7, 9, 14, 16, 17, and the Navy Yard monitoring wells. No groundwater samples were collected from Sites 1, 8, 10, 11, 12, or 13.
Evaluation of Potential Public Health Hazards
Even though groundwater contamination has been detected, there is no known public exposure to groundwater underlying or in the vicinity of WNY. Private wells are not located in the WNY vicinity (Miller 1999) and local residents receive water from the Washington, D.C., municipal drinking water system. Because there is no known exposure, ATSDR concludes that groundwater poses no apparent public health hazard.
Could exposure to surface water and sediment contaminants in the WNY vicinity result in adverse health effects for local employees, residents, or visitors?
- PCBs, PAHs, metals, and pesticides contributed from different sources have been detected in surface water and/or sediment of the adjacent Anacostia River, some at levels above ATSDR's health-based comparison values.
- People do not swim or drink from WNY runoff, outfalls, or the Anacostia River. Therefore, any exposure to contaminants in surface water and sediment is minimal, limited to infrequent dermal contact that may occur while boating, fishing, or other recreational activities. This type of exposure is not expected to lead to adverse health effects.
Surface Water Hydrology and Sediment Characteristics
The Anacostia River is the major surface water body that flows near WNY. Upstream from WNY and outside of Washington, D.C., agricultural and forested areas remain and drain into the large Anacostia River watershed. Around WNY, surface water runoff from urbanized areas and groundwater that flows beneath the WNY empty into river (CH2MHILL 1999). Less than two miles downstream from WNY, the Anacostia River converges with the Potomac River and flows into the Chesapeake Bay. Because of increasing local urbanization, and the resulting loss of wetland, the lower Anacostia River in the vicinity of the WNY is experiencing growing problems with erosion, sedimentation, and the delivery of excess nutrients. The effects of these problems have diminished the river's natural capacity to filter contaminants and increased chemical contaminant transport via sediment movement.
Much of the WNY property bordering the Anacostia River is filled land. Because of the fill's flat topography, water tends to flow slowly, especially at the mouth of the Anacostia River. This sluggish movement, coupled with the fact that the river in the WNY area is tidally influenced (from the Chesapeake Bay), creates an environment in which pollutants linger instead of being washed out by quickly moving water. On average, it takes materials in the lower Anacostia River 20 to 40 days (and over 100 days in times of drought) to reach the Chesapeake Bay (Interstate Commission 1996, USACE 1990). This flow pattern appears to deposit and concentrate significant amounts of upstream contaminants and sediments in the WNY vicinity (EPA and Chesapeake Bay Program Office 1999).
About 450 storm sewer outfalls owned by the Washington, D.C., Water and Sewer Authority discharge stormwater runoff directly into the area's local surface waters. Of these, 136 stormwater outfalls discharge into the Anacostia watershed. During large rain storms, 15 combined sewer overflow (CSO) outfalls discharge raw sewage and stormwater directly to the D.C. portion of the tidal Anacostia River. One hundred and ten storm sewer outfalls discharge into the tidal Anacostia River. Four outfalls--two CSO and two storm sewer outfalls--underlie WNY property and have discharged to the River. Washington, D.C., has not yet tested or monitored its municipal outfalls, but the Navy conducted some preliminary sampling.
Surface Water Use
No one drinks surface water from the Anacostia River in the WNY vicinity. Local anglers and boaters use the Anacostia River for recreational purposes. There is a small boat yard and two yacht clubs immediately upstream from WNY. Across the river is a public park accessed by anglers. Park visitors and local residents do not normally swim in the Anacostia River in the WNY vicinity, but swimming in this area is not prohibited.
Surface Water and Sediment Quality
The Anacostia River's health has been impacted by numerous interrelated forces. Because of a number of possible pollutant sources along the river, the extent to which WNY has contributed to the Anacostia River contamination remains unknown (Washington, D.C. RA 1996). However, shallow groundwater from WNY does discharge to the Anacostia River. Few industries or other point sources today continue to discharge effluent to the lower Anacostia River. Most existing river contamination stems from continued releases from past discharges, off-site non-point sources, and/or releases from storm and combined sewers.
Recent surveys of the sediments in the Anacostia River (Velinsky et al. 1994, Wade et al. 1994) reveal significant concentrations of PCBs, PAHs, metals, and the pesticide chlordane (Velinsky et al. 1992). The highest concentrations of many contaminants have been located in the sediments at the lower reaches of the Anacostia River near the confluence with the Potomac River. Most of the major contaminants in the river adhere to particles and traveled to WNY area via sediment transport.
During the Navy's Site Investigation, six sediment samples were collected from the Anacostia River adjacent to WNY and one sediment sample was collected upstream to serve as a background sediment sample. Methylene chloride (up to 3 parts per million [ppm]), acetone (up to 100 ppm), and toluene (trace amounts) were the only VOCs detected in the seven sediment samples, all at concentrations below ATSDR comparison values for soil (no comparison values exist for sediments). A total of 24 SVOCs were detected in the sediment samples collected from the Anacostia River, all at concentrations below ATSDR comparison values for soil (NFEC 1996). In general, the SVOC concentrations appear to be increasing downstream. Metals detected in the sediment samples included copper (up to 260 ppm), lead (up to 234 ppm), nickel (up to 40.7 ppm), and zinc (up to 415 ppm). Pesticides were not detected in the seven sediment samples. However, PCBs (Aroclor 1260) were detected in all the sediment samples with the exception of the background sediment sample. The concentrations of PCBs ranged from 0.085 ppm to 12 ppm and appear to be increasing downstream (NFEC 1996). ATSDR does not have a comparison value for Aroclor 1260, so the maximum detected concentration was screened against the most conservative Aroclor compound comparison value for soil, which is Aroclor 1254. Detected PCB levels slightly exceeded the Aroclor 1245 comparison value of 10 ppm for an adult and 1 ppm for a child. The highest PCB concentrations in sediment were measured adjacent to and downstream from WNY.
During another investigation, concentrations of PAHs in Anacostia River sediment in the WNY vicinity ranged from 5.6 to 28.3 ppm (Wade et al. 1994). These concentrations exceed upstream Anacostia River and typical urban background concentrations, both reported in the range of ppb rather than ppm (ATSDR 1995). The elevated PAH concentrations in the lower Anacostia River likely result from sediment transport and deposition in the WNY vicinity rather than from WNY activities (Wade et al. 1994; Coffin et al. 1998; ATSDR 1999a).
During a 1996 sediment removal action from two stormwater sewer lines (outfall 5 and outfall 10 [Figure 3]), the Navy found that the stormwater line sediments contained high levels of metals (arsenic [up to 52.6 ppm], lead [up to 567 ppm], mercury [up to 1.2 ppm]) and PCBs (Aroclor 1260 [up to 38 ppm]). Elevated levels of PAHs were also detected in the sediment (see Appendix A for details). Sediment samples collected at the WNY waterfront in 1996 contained lower contaminant concentrations. The contamination in the outfalls may have originated from Sites 4 and 6 or from the off-site Southeast Federal Center (SEFC), which formerly was part of WNY during its industrial period. Surface water samples were then collected at Sites 6 and 14, both of which contained metals (arsenic [up to 65.4 ppb], cadmium [up to 7.2 ppb], iron [up to 42,000 ppb], and lead [up to 305 ppb]) and PCBs (Aroclor 1260 [up to 2.2 ppb]) (NFEC 1996). Even though the maximum detected contaminant concentrations occurred in proximity to WNY, the portion attributable to WNY activities is unknown. Contaminant deposition is concentrated in the WNY area due to the natural flow, tidal, current, and mixing patterns of the river (Coffin et al. 1998).
In July 1998, the Navy issued an addendum to the Final Interim Measures Work Plan to address dioxin concerns. One sediment sample was collected for each of the storm sewers leading to outfalls 1 and 5 which release into the Anacostia River. Sediment from two storm sewers lines, at outfalls 1 and 5, contained dioxin. The toxicity equivalency factors for dioxin were detected above EPA's residential screening level. Again, the sediment from the storm sewer lines has been removed and the storm sewer system has been repaired (Navy 2001).
Evaluation of Potential Public Health Hazards
No one is exposed to contaminants in on-site surface water or sediment at the WNY. The storm water outfalls underlying WNY are buried underground and discharge into the Anacostia River at locations where there is no public access. Nor is anyone who uses the Anacostia River expected to come in contact with harmful levels of contaminants. Most importantly, people do not swim or drink from the Anacostia River. Exposure, if any, to contaminated surface water and sediment is minimal and limited to infrequent dermal contact that might occur during fishing, boating, or other recreational activities. Furthermore, skin contact with the contaminants detected above CVs is not expected to cause health problems since the contaminants do not easily absorb into or pass through the skin. ATSDR concludes that such infrequent, short-duration exposure to chemical contaminants in surface water and sediment near WNY does not pose any apparent public health hazards.
Could exposure to surface soil at WNY result in adverse health effects for local employees, residents, or visitors?
- Lead is the primary contaminant of concern in WNY surface soils. Admiral's Row (Site 10) surface soils contained lead concentrations above ATSDR comparison values for residential areas. In the past, people may have been exposed to elevated lead levels in surface soil that had the potential to pose a heath hazard to children.
- Current and potential future exposure to contaminated soil at WNY is largely prevented because the majority of the land's surface is either paved, covered by buildings, or lies in restricted land use areas.
WNY lies on terrace deposits and filled areas of the Anacostia River and slopes generally from the northern part of the facility southward to the river. The ground surface elevation ranges from a high of approximately 55 feet above mean sea level in the northeast part of the facility to just above mean sea level along the bulkhead adjacent to the Anacostia River. The soil appears to consist primarily of poorly sorted silt, sand, and gravel, mixed with variable amounts of construction materials, such as brick, concrete, and wood (CH2MHILL 1999).
Admiral's Row (Site 10) is the area of primary concern for public contact with surface soil contamination (CH2MHILL 1998, NFEC 1996). Admiral's Row lies along Warrington Avenue and consists of a group of residential buildings and Luetze Park. Some Admiral's Row residences have fenced yards and gardens. Luetze Park is the only non-paved area accessible to public visitors and WNY residents.
Nature and Extent of Soil Contamination
The main source of surface soil contamination at WNY is lead paint from site buildings, specifically buildings in Admiral's Row (Navy 1999). Surface soil samples collected from the yards of the residences located on Admiral's Row had detected lead concentration up to 18,700 ppm and above EPA's residential soil level of 400 ppm (Navy 1999). Ten surface soil samples were also taken from Luetze Park located on Admiral's Row. The maximum detected lead concentration in Luetze Park was 441 ppm, which just slightly exceeded EPA's residential soil level of 400 ppm. The other nine samples contained detected lead levels below 400 ppm. In all Luetze Park samples, the testing laboratory indicated that analytes were present, that the reported values may be biased high, and that the actual lead values are expected to be lower. Therefore, actual lead levels are probably below 400 ppm.
Soil contaminants were also found at other WNY sites, but the detected contaminant concentrations are low, infrequent and/or located in publically inaccessible areas. For example, surface soil underlying Building 292 at Site 14 was tested for PCBs. Aroclor 1260 was detected at a maximum concentration of 20 ppm, which exceeds ATSDR's comparison values of 10 ppm (adult) and 1 ppm (child) for Aroclor 1254 (NFEC 1996). (ATSDR does not have a comparison value for Aroclor 1260, so the maximum detected concentration of 20 ppm was screened against the most conservative Aroclor compound comparison value, which is Aroclor 1254.) The Navy also found visible liquid mercury at Site 16 in the subsurface soil of a confined area, approximately 5 or 6 feet below the surface and close to the water table. In June 1999, the Navy removed about 1 cubic foot (5 gallons) of the mercury-contaminated soil from above the water table (Navy 2001). Twelve cubic feet of soil were removed from this area during remedial activities (Navy 2000). Although site 16 contains soil contamination in fill, the soil is not accessible to the public.
Evaluations of Potential Public Health Hazards
Contamination is present in soil at certain locations of the WNY. The likelihood, however, that workers in their routine responsibilities (e.g., landscaping, gardening, or construction), or residents and visitors during their infrequent access to Admiral's Row soils, will contact the most contaminated soil for an extended period is remote. If workers or trespassers do contact contaminated soil, exposure most likely is intermittent and brief. Moreover, workers entering these areas must wear protective clothing, which further reduces exposure and any associated health effects. Such minimal, infrequent exposure to on-site contaminants, if it occurs at all, would not be expected to result in adverse health impacts. Appendix A provides a detailed evaluation of potential public health hazards associated with soil contamination at each WNY site. All sites, except for Admiral's Row, are not associated with any known public health hazards because: 1) no site-related contaminants are present where exposure to the public could occur; 2) contaminant concentrations detected are too low to pose a health hazard; and/or 3) past and current exposures to the general public have been prevented. In addition, most WNY sites (including Admiral's Row) are surrounded by perimeter fencing and covered surfaces (e.g., vegetative growth, paved areas)--both of which prevent and/or reduce potential exposure to contaminated soil. In other locations, contamination occurs in inaccessible subsurface soils where exposure is not possible.
Admiral's Row surface soil is a completed past exposure pathway for on-site workers, residents, and visitors. Historically, public contact with Admiral's Row surface soil was not deterred or restricted. Therefore, dermal contact with and incidental ingestion of lead concentrations above EPA's residential soil level of 400 ppm likely occurred. Because all age groups have accessed WNY, either as residents or museum visitors, ATSDR evaluated potential health hazards at WNY for both adult and child past exposures (Appendix C). Based on ATSDR's estimated exposure doses, past blood lead levels for children living at WNY may have been elevated above the recommended action level of 10 µg/dL in blood. Due to conservative assumptions in the calculation made by ATSDR, this estimated dose probably overestimates actual past exposure levels. Due to insufficient historical data on the extent of and exposure to this lead contamination, the exact health implications from past exposures cannot be assessed.
To deter people from contacting contaminated surface soils at Admiral's Row, the Navy currently enforces several interim measures. The Navy has constructed yard and garden fences surrounding contaminated areas of soil, posted signs warning the public about the contaminated surface soils, and implemented and enforced stringent land use restrictions to stop residents and the general public from contacting yard and garden soils. Only trained contractors following Occupational Safety and Health Administration safety requirements and wearing protective gear are currently permitted to dig, garden, and/or landscape in the Admiral's Row vicinity. The Navy also initiated a public education program. This lead-awareness initiative alerts WNY construction workers, employees, and residents about the hazards of working and living in a 200-year old military base. These interim measures have effectively deterred WNY residents, employees, and visitors from contacting Admiral's Row contaminated surface soils (ATSDR 1999a). ATSDR concludes that current and potential future exposures to on-site soil pose no apparent public health hazards. Past soil exposure is a completed exposure pathway with the potential for adverse health effects to children, but, due to the lack of historical data, the health implications from past exposure can not be assessed.
Will eating fish caught from the lower Anacostia River near WNY cause adverse health effects?
- Fish in the lower Anacostia River have been impacted by chemical contaminants from a variety of sources. How much of the pollution originates from WNY operations is unknown. Historically, PCB and chlordane in certain fish of the river have exceeded FDA guidance levels (for commercial fish). People who eat contaminated fish in sufficient quantities could develop adverse health effects.
- A fish consumption advisory posted in Anacostia Park recommends that people refrain from eating certain fish caught from this river. People who fish from the lower Anacostia River can best protect themselves against potential harmful effects from contaminants in fish by following the recommendations in the advisory.
The Anacostia River is a popular recreational fishing spot for Washington, D.C. area anglers, particularly in the vicinity of Hains Point (at the confluence of the Anacostia and Potomac Rivers). Most anglers fishing along the river practice catch and release fishing (82%), although some anglers still cook and eat their catches. Of fish inhabiting the river, catfish and bass are the most commonly caught species (D.C. Department of Health 1999). A public park (Anacostia Park) lies across the lower Anacostia River from WNY with posted signs to warn anglers against cleaning their catch on the picnic benches. During the site visit, however, ATSDR noted that public signs warning anglers against eating their catch are not readily apparent. ATSDR recommends that the National Park Service improve the fish consumption advisory signs so that they are more easily seen in Anacostia Park. The Washington, D.C., Department of Public Health (D.C. Health Department) has posted signs in the area since it issued a fish consumption advisory for the Anacostia and Potomac Rivers in July 1989. ATSDR recommends additional fish consumption advisory warning signs in visible locations along the lower reaches of the Anacostia River.
As noted in the Surface Water and Sediment discussion, the Anacostia River water quality and the sediment have been impacted by a number of pollutant sources, including urban development, untreated sewage from combined sewer overflows, non-point source surface runoff from agricultural activities and storm drains, and chemical releases from industrial and federal facilities (DC DCRA 1996). Fish take in and accumulate the contaminants over time as a result of a very slow rate of elimination. Larger, older fish tend to accumulate the highest levels of contaminants (EPA 1994). Some Anacostia River fish have accumulated contaminants to levels high enough to pose a health risk to certain people who eat fish.
In 1989, the Washington, D.C., Department of Health issued a public health advisory, urging anglers to limit their consumption of channel catfish, carp, and eel caught in the D.C. waters of the Anacostia and Potomac Rivers. This advisory was primarily based on elevated levels of PCBs and chlordane in certain bottom-dwelling fish species (see Fish Tissue Data section below). (Bottom-dwelling fish were targeted because, as bottom feeders, they are in frequent contact with sediment and they generally have a high body fat content where organic contaminants, such as PCBs, are stored.) The Washington, D.C., Department of Health advised citizens to consume no more than one locally caught meal (one-half pound) per week and to eat only skinless, boneless fillets. The advisory discouraged women of childbearing age, nursing mothers, and pre-schoolers from eating any locally caught fish (DC DCRA 1994a).
Based on annual fish tissue data gathered by the Washington, D.C., Environmental Regulation Administration (DC ERA), the Washington, D.C., Department of Health reviewed and updated their fish consumption advisory with stronger language in 1994 (Interstate Commission 1996). The upgraded advisory called for a total ban on the consumption of locally caught catfish, carp, and eel (bottom-feeding species). Additionally, it advised citizens to eat only one-half pound per week of sunfish, one-half pound per month of largemouth bass, and 1 to 4 meals per month of other fish from the Anacostia and Potomac Rivers. The Washington D.C., Department of Health advised people to choose younger and smaller fish of legal size and encouraged catch-and-release fishing over consumption (DC DCRA 1994b). According to Washington, D.C., Department of Health officials, the vast majority of the public adheres to these posted warnings, but some community members continue to eat fish and eel caught from the lower Anacostia River.
A number of fish tissue studies have been conducted by various agencies and groups to determine whether and to what extent contaminants were accumulating in fish caught from the Anacostia and Potomac Rivers. Many studies compared contaminant levels to action or tolerance levels designed by the U.S. Food and Drug Administration (FDA) to protect consumers of commercial fish. FDA's action or tolerance levels, used by ATSDR as screening values and referenced in the following discussion, are (all wet weight): PCBs, 2.0 ppm; chlordane, 0.3 ppm; dieldrin, 0.3 ppm; 1,1,1-trichloro-2,2-bis(p-chlorophenyl)ethane (DDT), 5.0 ppm; and mercury, 1.0 ppm(1). Table 2 summarizes the results the maximum contaminant concentrations detected in fish fillet samples reported in these studies.
The collection of studies provide information on fish samples caught from many different points along the Anacostia and Potomac Rivers and for a range of fish sample types (i.e., fillet, carcass, and whole fish). For the purposes of this public health assessment, however, ATSDR was most interested in assessing data for fish most likely affected by WNY-related contaminants and for fish types most relevant to local population's eating habits. Therefore, ATSDR evaluated:
- Fish samples collected from the lower Anacostia River (defined as the portion of the river that lies between the railroad bridge just downstream of Kingman Lake and Hains Point at the Potomac River). This area includes the WNY and a sufficient upstream and downstream reach to account for fish migration from the water adjacent to WNY.
- Fish fillets, which represent the "edible" portion of fish. ATSDR is not aware of any groups of people visiting the lower Anacostia River whose diet consistently rely on other portions of fish (i.e., bones, fat, viscera).
Early fish tissue studies (1987 and 1992) of the Anacostia River were conducted by the U.S. Fish and Wildlife Service (1987), DC ERA (1989), the D.C. Environmental Control Division (1991), and Velinsky and Cummins (1989 to 1992). Fish, predominantly channel catfish, common carp, largemouth bass, brown bullhead, sunfish, and American eel, were collected and analyzed for PCBs and pesticides; selected samples were also analyzed for metals, VOCs, SVOCs, polychlorinated dibenzodioxins, and polychlorinated dibenzofurans. The data collected from these studies indicated that detectable levels of many chemicals were present in edible portions of fish from the Anacostia River. The chemicals ranged from trace levels of metals, such as mercury and lead, to higher levels of organic compounds. Of the organic contaminants tested, PCBs (up to 2.4 ppm) and the pesticide chlordane (0.633) were found in the highest concentrations and at levels above their respective FDA action or tolerance level. Fish most affected by the contaminants were channel catfish and other bottom-dwelling species. (Even higher PCB levels were reported for carcass [up to 2.9 ppm] samples.) Contaminants were also detected in top-level predatory species, such as the largemouth bass and sunfish, but at lower levels than those observed in the bottom-dwellers. The collective results of these early studies suggested that PCBs and chlordane were present at concentrations of public health concern (Velinsky and Cummins 1994).
Since the issuance of the fish consumption advisory, several restoration and source control measures were instituted to help reduce tissue residue levels in the local fish population (DC Department of Health 2001). To assess the effects of these measures, Velinsky and Cummins examined the trends in contaminant levels over time. They analyzed 20 fish composite samples obtained from the D.C.'s Environmental Regulation Administration [DC ERA] archived inventories of samples collected in 1993, 1994, and 1995. (It should be noted that not all species were collected from the same location each year.) The samples were analyzed for more than 129 chemical contaminants. PCBs, chlordane, dieldrin, DDT, and mercury were detected in one or more species of fish, but generally at concentrations below FDA action or tolerance levels and lower than values reported for earlier studies. Velinsky and Cummins concluded, however, that unacceptable levels of contaminants were still present in Anacostia River fish (Velinsky and Cummins 1996).
The most recent fish tissue study was conducted in November 2000, by DC Department of Health (DC Department of Health 2001). Results confirm earlier findings, mainly that PCBs (up to 2.49 ppm) and chlordane (up to 0.338 ppm) are the primary contaminants of concern and are present at concentrations above FDA action or tolerance levels, especially in bottom-dwelling fish species that include channel catfish, carp, and American eel (Velinsky 2000; DC Department of Health 2001).
Evaluation of Potential Public Health Hazards
Of all contaminants detected in fish from the lower Anacostia River, only PCBs and chlordane exceeded their respective FDA action or tolerance levels. These FDA action or tolerance levels serve as preliminary screening values, but ATSDR did not consider them to be very conservative for several reasons: (1) the FDA action levels apply only to fish sold in interstate commerce, (2) the FDA action levels factor in economic considerations and are not as conservative as health-based action levels, and (3) fish consumption rates for sport anglers could be higher than those assumed for the consumption of commercially bought fish. Therefore, ATSDR conservatively estimated exposure doses for individuals who eat fish contaminated with PCBs and chlordane from the lower Anacostia River. Appendix C describes the method and conservative assumptions ATSDR used to estimate exposure doses and potential health effects. The estimated exposure dose for PCBs exceeded levels considered acceptable for the general population. Based on current, available information, ATSDR concludes the consumption of local fish could pose a public health hazard and the fish consumption advisory for the Anacostia River should continue to be observed. Additional signs urging people to adhere to the advisory may be needed at key public access points along the Anacostia River.
The community surrounding WNY has concerns regarding the Anacostia River's surface water quality. No public health hazards were specifically attributed to chemical contaminants in local surface water, nor were WNY operations implicated as the primary source of Anacostia River pollutants. The public, however, expressed a desire for WNY to immediately address the issue by implementing remediation efforts to improve local surface water quality. The status of the various sites at WNY and remediation projects are outlined in the Public Health Action Plan section and Appendix A of this report.
On September 26 and 27, 2000, ATSDR held sessions for the public to express their health and environmental concerns with respect to WNY. Our public sessions were held at Van Ness Elementary School and the Anacostia Park Pavilion. During these sessions, ATSDR spoke with representatives from the National Park Service, the Student Conservation Association, Inc., and the Navy. ATSDR also spoke with eight fishermen in Anacostia Park on September 27. Three fishermen said they were catching-and-releasing while five others indicated they eat the fish sometimes and were not aware of consumption advisories.
A draft of this public health assessment was released for public comment from September 28 through October 31, 2001. Although no public comments were received, ATSDR revised this assessment based on comments from the Navy (Navy 2001) and the DC Department of Health (DC Department of Health 2001b).
ATSDR recognizes that infants and children may be more sensitive to exposures than adults in communities with contamination in their water, soil, air, or food. This sensitivity is a result of a number of factors. Children are more likely to be exposed to soil or surface water contamination because they play outdoors and often bring food into contaminated areas. For example, children may come into contact with and ingest soil particles at higher rates than adults do; also, some children with a behavior trait known as "pica" are more likely than others to ingest soil and other nonfood items. Children are shorter than adults, which means they can breath dust, soil, and any vapors close to the ground. Also, they are smaller, resulting in higher doses of chemical exposure per body weight. The developing body systems of children can sustain permanent damage if toxic exposures occur during critical growth stages. Because children depend completely on adults for risk identification and management decisions, ATSDR is committed to evaluating their special interest at sites such as WNY, as part of the ATSDR Child Health Initiative.
ATSDR has attempted to identify populations of children in the vicinity of WNY and any completed exposure pathways to these children. During the 1999 ATSDR site visit, one adolescent child under the age of 18 lived on WNY property. The community surrounding WNY contains residential neighborhoods with children and schools, but children cannot easily trespass on to WNY property due to perimeter fencing and military security measures. Children, however, may infrequently visit WNY during group tours and visits to the on-site museum. The tours and museum do not expose WNY visitors to contaminated areas or public health hazards.
Residential and visiting children may access Luetze Park, but not Admiral's Row gardens and house lawns which contain lead levels above 400 ppm. Access to Admiral's Row is prevented by site fencing and land use restrictions. Luetze Park is grass covered and contains surface soil lead concentrations too low to pose a public health hazard to children.
In the past, prior to Naval land use restrictions, there may have been limited child exposure to the lead-contaminated surface soil. Currently, all child exposures to on-site contaminants are prevented because children do not drink the underlying groundwater, contact Admiral's Row surface soils, access subsurface soils, or come into contact with any other known contaminated areas.
The Anacostia River has been impacted by chemical pollutants released into the river from a variety of sources. Children should not come into prolonged direct contact with the pollutants since children do not swim in the Anacostia River. Children may eat fish from the river, however, if parents do not follow the Washington, D.C., fish consumption advisory for the Anacostia and Potomac Rivers. If children do eat locally-caught fish, the chemical residues in the fish could pose a public health hazard for children. ATSDR recommends that children and parents observe the Washington, D.C., fish consumption advisory. We also recommend raising awareness about the fishing advisory among residents and health care providers.
ATSDR concludes that past, current, and future exposures to groundwater, surface water, and sediment do not pose a public health hazard for children because exposure is minimal, if it occurs at all. Past exposure to lead in surface soil at Admiral's Row is a completed exposure pathway with the potential to have adversely affected child health. The consumption of local fish poses a potential child health hazard and children should not eat fish caught in the lower reaches of the Anacostia River.
1. The FDA action or tolerance levels were established for seafood sold through interstate commerce. They were developed to protect humans from harmful substances in commercial foods. Although the FDA levels were not developed as regulatory standards for freshwater fish, they are often used by states as guidance when setting freshwater fish consumption advisories.