PUBLIC HEALTH ASSESSMENT

ONONDAGA LAKE
SYRACUSE, ONONDAGA COUNTY, NEW YORK

APPENDIX A

FIGURES


Figure 1

Figure 2

Figure 3

Figure 4

Figure 5

APPENDIX B

TABLES

TABLE 1
Onondaga Lake Site, Onondaga County, New York Public Health Assessment ComparisonValues for Recreational Exposure to Antimony and Manganese in Surface Water
[All values in micrograms per liter (mcg/L)]

Comparison Values
Contaminant	Cancer*	Basis**	Noncancer*	Basis**
antimony	--	--	2,353	EPA RfD
manganese	--	--	29,410	EPA RfD

*Comparison values are determined for a 21 kilogram child who swallows while swimming/wading 0.05 liters of surface water per day, 2 days per week for 3 months per year.
**EPA RfD = EPA Reference Dose
-- Indicates "not applicable"

TABLE 2
Bacteriological Water Quality Standards of Interest to Onondaga Lake

Application	Indicator	Standard	Source
bathing beaches	TC	"the total number of organisms of the total coliform group shall not exceed a logarithmic mean of 2400/100 ml for a series of five or more samples in any 30 day period, nor shall 20% of total samples during the period exceed 5000/100 ml. When the above prescribed standards are exceeded, the permit-issuing official shall cause an investigation to be made to determine and eliminate the source or sources of pollution, or	Chapter I. State Sanitary Code, Part 6, Subpart 6-2, bathing beaches (1988)
bathing beaches	FC	the fecal coliform density from the five successive sets of samples collected daily on five different days shall not exceed a logarithmic mean of 200 per 100 ml. When fecal coliform density of any sample exceeds 1,000 per 100 ml, consideration shall be given to closing the beach. Daily samples shall immediately be collected and analyzed for fecal coliform for at least two consecutive days"	Chapter I. State Sanitary Code, Part 6, Sub-part 6-2, bathing beaches (1988)
quality standards for class B and C waters	TC and FC	"the monthly median coliform value for 100 ml of sample shall not exceed 2,400 from a minimum of five examinations, and provided that not more than 20% of the samples shall exceed a coliform value of 5,000 for 100 ml of sample and the monthly geometric mean FC value for 100 ml of sample shall not exceed 200 from a minimum of five examinations. This standard shall be met during all periods when disinfection is practiced."	Section 701.19, Classifications and Standards of Quality and Purity (1986)

TABLE 3
Onondaga Lake Site, Onondaga County, New York
Public Health Assessment Comparison Values for Contaminants Found in Sediments
[All values in milligrams per kilogram (mg/kg)]

Contaminant	Typical Background Range*	Comparison Values
		Cancer**	Basis***	Noncancer**	Basis***
Organics:
benzene	ND	674	EPA CPF	410	NYS RfG
bis(2-ethylhexyl)phthalate	ND	1,393	EPA CPF	11,660	EPA RfD
1,4-dichlorobenzene	ND	813	EPA HEAST	52,470	EPA RfD
hexachlorobenzene	ND	9.3	NYS CPF	466	EPA RfD
monochlorobenzene	ND	--	--	11,600	EPA RfD
petroleum hydrocarbons	ND	--	--	--	--
1-phenyl-1-(4-methylphenyl)ethane	ND	--	--	--	--
1-phenyl-1-(2,4-dimethylphenyl)ethane	ND	--	--	--	--
PCBs	<0.01-0.04	2.5	EPA CPF	12	ATSDR MRL
polycyclic aromatic hydrocarbons (PAHs)+
carcinogenic	<1-3a	1.4b	NYS CPF	--	--
noncarcinogenic	<1-13c	--	--	17,490	EPA RfDd
toluene	ND	--	--	116,600	EPA RfD
Metals:
antimony	0.6-10	--	--	233	EPA RfD
barium	300-500	--	--	40,810	EPA RfD
cadmium	<0.5-1	--	--	410	ATSDR MRL
chromium	10-40	--	--	2,915	EPA RfD
copper	<1-25	--	--	75,790	EPA HEAST
lead	10-300	--	--	--	--
manganese	500-3,000	--	--	81,600	EPA RfD
mercury	0.01-3.4	--	--	175	EPA HEAST
nickel	<5-20	--	--	9,900	EPA RfD
zinc	50-100	--	--	174,900	EPA RfD

ND = not determined
^aBased on reported background levels for total carcinogenic polycyclic aromatic hydrocarbons (Menzie et al., 1992).
^bUsed cancer potency factor for benzo(a)pyrene. This chemical can be considered a surrogate for carcinogenic PAHs.
^cBased on reported background levels for total PAHs of <1 to 13 milligrams per kilogram in soil (Edwards, 1983).
^dUsed oral reference dose (RfD) for pyrene. This chemical can be considered a surrogate for many noncarcinogenic PAHs.
*ATSDR (1993b); Adriano (1986); Clarke et al. (1985); Connor et al. (1957); Davis and Bennett (1983); Dragun (1988);
Frank et al. (1976); McGovern (1988); Schacklette and Boerngen (1984)
**There is evidence that in the past, sediments were dredged from Onondaga Lake and placed in the park area. Comparison values for cancer risk are determined for a 70 kilogram adult who ingests 50 mg of soil per day, 2 days per week for 3 months per year; comparison values for noncancer risk are determined for a 21 kilogram child who ingests 100 mg of soil per day, 5 days per week for 6 months per year.
***EPA CPF = EPA Cancer Potency Factor
NYS CPF = NYS Cancer Potency Factor
EPA RfD = EPA Reference Dose
NYS RfG = NYS Reference Guideline
EPA HEAST = EPA Health Effects Assessment Summary Tables
ATSDR MRL = ATSDR Minimal Risk Level
-- Indicates "not applicable"
+Contaminant selected for further evaluation

TABLE 4
Onondaga Lake Site, Onondaga County, New York
Public Health Assessment Comparison Values
for Contaminants Found in Fish
[All values in milligrams per kilogram (mg/kg)]

Contaminant	Comparison Values
	Cancer*	Basis**	Noncancer*	Basis**
benzene	0.1	EPA CPF	1.5	NYS RfG
bis(2-ethylhexyl) phthalate	0.2	EPA CPF	44	EPA RfD
cadmium	--	--	1.5	NYS RfG
DDT	0.0006	NYS CPF	1.1	EPA RfD
1,4-dichlorobenzene	0.1	EPA HEAST	197	EPA RfD
hexachlorobenzene	0.001	NYS CPF	1.8	EPA RfD
lead	--	--	--	--
mercury+	--	--	0.01	ATSDR MRL***
	--	--	0.7	EPA RfD
monochlorobenzene	--	--	44	EPA RfD
PCBs+	0.0003	EPA CPF	0.04	ATSDR MRL
1-phenyl-1-(4-methylphenyl)ethane	--	--	--	--
1-phenyl-1-(2,4-dimethylphenyl)ethane	--	--	--	--

*Comparison values are determined for a 70 kilogram adult who eats 32 grams
of fish per day, except for acute exposures.
**EPA RfD = EPA Reference Dose
EPA CPF = EPA Cancer Potency Factor
EPA HEAST = EPA Health Effects Assessment Summary Tables
NYS RfG = NYS Reference Guideline
NYS CPF = NYS Cancer Potency Factor
ATSDR MRL = ATSDR Minimal Risk Level
***ATSDR MRL for acute (short-term) exposures based on one 224 gram meal.
-- Indicates "not applicable"
+Contaminant selected for further evaluation

TABLE 5
Summary of Annual Contaminant Air Emissions and Releases for the Year 1992 from Facilities Near the Onondaga Lake Site as Reported in the US EPA Toxic Chemical Release Inventory (TRI) Database, Onondaga County, New York.

Facility Name	Approx. Distance From Site+	Chemical Name	Contaminant Emissions (lbs/yr)
			Stack/ Point Source	Fugitive/ Non-Point	Total (#) Maximum
Syracuse Heat Treating Corp.	1.5	Ammonia	500-999	11-499	1,498
General Chemical Corp. (929 ft.)	0.18	Ammonia	None	96	96
Caldwell & Ward Brass Company	2.0	Copper	None	589	589
Chemtech Industries	0.83	Sulfuric acid	11-499	10	509
Marcellus Casket Co.	1.16	Xylene	None	31,109	31,109
Pass & Seymour	1.16	Xylene	None	2,516	2,516
Church & Dwight Company, Inc.	0.33 (1742 ft.)	Ammonia	29,000	1,000	30,000
		Glycol ethers	5	4	9
		Sulfuric acid	None	4	4
Strathmore Products,Inc. (Plant #2)	1.0	Acetone	11-499	1,085	1,579
		1,1,1-Trichloroethane	None	2,009	2,009
		Glycol ethers	1-10	134	144
		Methyl ethyl ketone	11-499	1,440	1,939
		Ethylbenzene	11-499	263	762
		Methyl isobutyl ketone	11-499	1,066	1,565
		Xylene	11-499	2,964	3,463
		Toluene	11-499	4,505	5,004
Boorum & Pease, Inc.	1.16	1,1,1-Trichloroethane	13,900	None	13,900
Syracuse China Corp.	2.65	Lead	500-999	11-499	1,498
Meloon Foundries, Inc.	1.83	Copper	None	1,400	1,400
Anoplate Corp.	0.33 (1,742 ft.)	Hydrochloric acid	11-499	11-499	998
		Sulfuric acid	None	11-499	499
		Nitric acid	11-499	1-10	509
		1,1,1-Trichloroethane	19,910	1-10	19,920
Crouse-Hinds Co. (Wolf Street Plant)	1.16	Methylene chloride	13,000	700	13,700
		Styrene	38	None	38
		Toluene	13,000	None	13,000
		Hydrochloric acid	1,200	None	1,200
B.G. Sulzle, Inc.	2.16	1,1,1-Trichloroethane	None	19,300	19,300
		Trichloroethene	66,500	3,500	70,000
Martin Marietta-General Electric Co.	1.16	Acetone	4,200	6,300	10,500
Syrtek, Inc. (formerly Pico Products, Inc.)	0.83	Ammonia	2	2	4
Deluxe Check Printers	2.33	1,1,1-Trichloro- ethane	726	20,794	21,520
Crucible Inc. (Specialty Metals Division)	0.09 (470 ft.)	Manganese (total)	374	374	748
		Nickel	158	158	316
		Chromium	643	622	1,265
		Cobalt (total)	28	24	52
		Copper	71	71	142
		Hydrochloric acid	None	11,800	11,800
		Nitric acid	None	4,800	4,800

Adapted from: Toxic Chemical Release Inventory (TRI), Calendar Year 1992.

Note: All emissions data reported in pounds/year (lbs/yr).
- Indicates no emissions/release data reported.
# Indicates estimated worst case emissions based on reported data.
⁺ Distance is in miles; in some cases, the distance in feet is also provided in parentheses.

Refer to Figure 4 (Appendix A) for facility locations.

TABLE 6
Summary of Annual Contaminant Releases for the Year 1992 to Surface Water or Publicly Owned Treatment Works (POTW) from Facilities Near the Onondaga Lake Site as Reported in the US EPA Toxic Chemical Release Inventory (TRI) Database, Onondaga County, New York.

Facility Name	Approx. Distance From Site+	Chemical Name	Contaminant Discharges (lbs/yr) to:
			Surface Water	POTW*
CrucibleInc. (Specialty Metals Division)	0.09 (469.9 ft.)	Manganese	128
		Nickel	251
		Chromium	194
		Cobalt	74
		Copper	33
General Chemical Corp.	0.18 (929.3 ft.)	Ammonia	562
Syracuse China Corporation	2.65	Lead	11	1
Benbow Chemical Packaging, Inc.	0.98	Phosphoric acid		1-10
H.P. Hood, Inc.	2.84	Phosphoric acid		14,033
Syrtek,Inc. (formerly Pico Products, Inc.)	0.83	Ammonia		2
Crouse-Hinds Co. (Wolf St. Plant)	1.16	Zinc Compounds		1,300
Church & Dwight Company, Inc.	0.33 (1,742 feet)	Glycol Ethers		700
		Ammonia	2,000	300,000

Adapted from: Toxic Chemical Release Inventory (TRI), Calendar Year 1992.
Note: All emissions data reported in pounds/year (lbs/yr).
+Distance is in miles; in some cases, the distance in feet is also provided in parentheses.
*POTW - Publicly owned treatment works.
Refer to Figure 4 (Appendix A) for facility locations.
Blank space indicates "not applicable".

APPENDIX C

FISH ADVISORY

The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services
Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

APPENDIX D

PROCEDURE FOR EVALUATING POTENTIAL HEALTH RISKS
FOR CONTAMINANTS OF CONCERN

To evaluate the potential health risks from contaminants of concern associated with the Onondaga Lake site, the New York State Department of Health assessed the risks for cancer and noncancer health effects.

Increased cancer risks were estimated by using site-specific information on exposure levels for the contaminant of concern and interpreting them using cancer potency estimates derived for that contaminant by the US EPA or, in some cases, by the NYS DOH. The following qualitative ranking of cancer risk estimates, developed by the NYS DOH, was then used to rank the risk from very low to very high. For example, if the qualitative descriptor was "low", then the excess lifetime cancer risk from that exposure is in the range of greater than one per million to less than one per ten thousand. Other qualitative descriptors are listed below:

Excess Lifetime Cancer Risk

Risk Ratio	Qualitative Descriptor
equal to or less than one per million	very low
greater than one per million to less than one per ten thousand	low
one per ten thousand to less than one per thousand	moderate
one per thousand to less than one per ten thousand	high
equal to or greater than one per ten thousand	very high

An estimated increased excess lifetime cancer risk is not a specific estimate of expected cancers. Rather, it is a plausible upper bound estimate of the probability that a person may develop cancer sometime in his or her lifetime following exposure to that contaminant (i.e., there is only about a 5 percent chance that the risk of a response is greater than the estimated value).

There is insufficient knowledge of cancer mechanisms to decide if there exists a level of exposure to a cancer-causing agent below which there is no risk of getting cancer, namely, a threshold level. Therefore, every exposure, no matter how low, to a cancer-causing compound is assumed to be associated with some increased risk. As the dose of a carcinogen decreases, the chance of developing cancer decreases, but each exposure is accompanied by some increased risk.

There is no general consensus within the scientific or regulatory communities on what level of estimated excess cancer risk is acceptable. Some have recommended the use of the relatively conservative excess lifetime cancer risk level of one in one million because of the uncertainties in our scientific knowledge about the mechanism of cancer. Others feel that risks that are lower or higher may be acceptable, depending on scientific, economic and social factors. An increased lifetime cancer risk of one in one million or less is generally considered an insignificant increase in cancer risk.

For noncarcinogenic health risks, the contaminant intake was estimated using exposure assumptions for the site conditions. This dose was then compared to a risk reference dose (estimated daily intake of a chemical that is likely to be without an appreciable risk of health effects) developed by the US EPA, ATSDR and/or NYS DOH. The resulting ratio was then compared to the following qualitative scale of health risk:

Qualitative Descriptions for Noncarcinogenic Health Risks

Ratio of Estimated Contaminant Qualitative

Intake to Risk Reference Dose Descriptor

equal to or less than the risk reference dose	minimal
greater than one to five times the risk reference dose	low
greater than five to ten times the risk reference dose	moderate
greater than ten times the risk reference dose	high

Noncarcinogenic effects, unlike carcinogenic effects, are believed to have a threshold, that is, a dose below which adverse effects will not occur. As a result, the current practice is to identify, usually from animal toxicology experiments, a no-observed-effect-level (NOEL). This is the experimental exposure level in animals at which no adverse toxic effect is observed. The NOEL is then divided by an uncertainty factor to yield the risk reference dose. The uncertainty factor is a number which reflects the degree of uncertainty that exists when experimental animal data are extrapolated to the general human population. The magnitude of the uncertainty factor takes into consideration various factors such as sensitive subpopulations (for example, children or the elderly), extrapolation from animals to humans, and the incompleteness of available data. Thus, the risk reference dose is not expected to cause health effects because it is selected to be much lower than dosages that do not cause adverse health effects in laboratory animals.

The measure used to describe the potential for noncancer health effects to occur in an individual is expressed as a ratio of estimated contaminant intake to the risk reference dose. If exposure to the contaminant exceeds the risk reference dose, there may be concern for potential noncancer health effects because the margin of protection is less than that afforded by the reference dose. As a rule, the greater the ratio of the estimated contaminant intake to the risk reference dose, the greater the level of concern. A ratio equal to or less than one is generally considered an insignificant (minimal) increase in risk.

APPENDIX E

Public Health Hazard Categories

The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services
Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

APPENDIX F

Summary of Public Comments and Responses
Onondaga Lake

This summary was prepared to respond to the public's comments and questions on the Onondaga Lake draft Public Health Assessment (PHA). The public was invited to review this document during the public comment period which ran from December 29, 1994 to February 24, 1995. Some of the comments with similar concerns have been grouped together. If you have any questions about this summary, contact the Health Liaison Program, toll-free at 1-800-458-1158, extension 402.

PUBLIC COMMENTS:

1. COMMENT: A few facilities and firms were inaccurately named in the text (e.g. AlliedSignal Inc., not Allied Chemical).
   
   RESPONSE: The text has been corrected.



2. COMMENT: The size of the Onondaga Lake shoreline wastebeds referred to in Appendix A occupies 716.3 acres, not 1,360 acres as stated in the document.
   
   RESPONSE: A new Figure 3 has been included which identifies in more detail all of the wastebeds surrounding the lake. The estimate of 1,360 acres was based on adding up the acreage in the Blasland, Bouck and Lee report (1989) for wastebeds labeled A through M and 1 through 8.



3. COMMENT: Most of the benzene levels near the "tar beds" are likely to be due to vehicular exhaust from Route 690 traffic.
   
   RESPONSE: The reported benzene levels at the tar beds are higher than at other nearby sites (e.g. Sawyer to Miller, Air monitoring data summary/AlliedSignal)
   
   Semet Tar Beds, Solvay, NY, November 4, 1992; Mo to Boyce, Semet-Solvay TAGA Survey Data Summary, June 20, 1990) and a 1989 sample of the tar bed wastes contained benzene. Thus the tar beds are one likely source of the benzene. The data are inadequate to evaluate relative contributions from nearby sites.



4. COMMENT: A former division of AlliedSignal that refined coke light oil via fractional distillation placed residue tars in the tar beds; no chlorinated compounds were involved in the process or deposited in the beds. The sludge from refining light oil which was placed in the beds contained benzene, toluene, xylene and polycyclic aromatic hydrocarbons (PAHs). AlliedSignal has signed an Administrative Consent Order agreeing to a temporary cover over beds 3 and 4 as an interim measure.
   
   RESPONSE: The text has been modified to reflect these comments.



5. COMMENT: An Interim Remedial Measure consisting of product recovery for a solvent containing a mixture of chlorobenzene and dichlorobenzene has been initiated by AlliedSignal Inc.; they are not collecting and treating groundwater in this project as stated in the report.
   
   RESPONSE: The text has been modified to reflect this comment.



6. COMMENT: It is not made clear in the draft report what criteria the State Health Department uses in making the determination that a particular site is a "public health hazard," or what the consequences or implications of such a classification are.
   
   RESPONSE: ATSDR's criteria for determining that a site is a public health hazard have been added in Appendix E, and are referenced in the Conclusions section.



7. COMMENT: The draft report proposes to declare Onondaga Lake a "public health hazard" and raises issues about exposure to a number of potential health hazards in a manner that is likely to be alarming to the general public, but for which there is no apparent supporting documentation.
   
   RESPONSE: The meaning of public health hazard has been clarified in the document (see response 6).



8. COMMENT: The draft report provides no new information documenting human exposure to health hazards in or around the lake. Nor does the draft report provide the basis for taking actions beyond those already in place to prevent or reduce people's exposure to hazardous substances.
   
   RESPONSE: It is true that no new information documenting human exposure to health hazards was identified; however, data necessary to completely evaluate the site and health risks were identified, as well as the consideration of controls to reduce the amount of mercury and fecal contamination entering the lake.



9. COMMENT: The final report should make clear what the State views as actual health risks associated with the site. Based on our reading of the draft, the actual health risks are limited to consumption of fish and exposure to bacteria from water contact following storm events.
   
   RESPONSE: We agree that ingestion of fish and exposure to bacteria from water contact following storm events are known health risks associated with Onondaga Lake. Other health risks that could be present, but are not known with certainty due to limited sample data, include those listed under "Potential Exposure Pathways".



10. COMMENT: The potential placement of hazardous dredge spoils in public parkland should be better described to minimize public misperception. The only dredged material the County is aware of being placed in County parkland is the placement of dredge spoils from the Ninemile Creek delta in 1968. The County is unaware of dredged spoils being put any place else along the shoreline and that should be reflected in the Potential Exposure Pathways section regarding possible shoreline contamination. What are the specific findings that show the lake shore is a health hazard? In the absence of specific information about shore-line contamination, hazards related to use should be omitted from the PHA.
    
    RESPONSE: The Potential Exposure Pathways section has been modified to emphasize that the dredge spoils being discussed along the shoreline north of Ninemile Creek is the only documented case of placement of dredge material. Please note that the shoreline has been identified as a potential exposure pathway because not enough information is available to establish whether or not it represents a completed exposure pathway. The PHA does not state that the shoreline is a public health hazard, but emphasizes that since there are data gaps, more information is needed.



11. COMMENT: Although it would be prudent to characterize the contamination, if any, in the dredge spoils placed north of Ninemile Creek, this area has always been intended for low intensity use.
    
    RESPONSE: We agree that the dredge spoils should be characterized to determine to what extent, if any, contaminants are present. Recommendation #3 has been revised to state that the potential for accessibility to this area should also be evaluated.



12. COMMENT: In the draft report, mercury contamination of the lake seems disproportionately attributed to Ninemile Creek and the Onondaga County Metropolitan Syracuse Wastewater Treatment (Metro) Plant. To our knowledge, there is no documentation that mercury discharges from Metro differ from those attributed to other wastewater facilities of similar size and nature, or that this discharge represents a significant source to the lake relative to the tons of mercury in the sediments due to previous discharges from the chloralkali plant and continued discharges from adjacent wastebeds. The report does not provide information on the amount of mercury attributed to Metro, or its percent contribution relative to other inputs.
    
    RESPONSE: The percentage of mercury input to the lake from Ninemile Creek and Metro has been added to the PHA (see "Off-Site Contamination"). Approximately 48% of the mercury entering the lake is from Ninemile Creek, and approximately 25% is attributed to the Metro plant. The purpose of this PHA is to identify sources of contamination and complete or potential exposure pathways. Whether or not the mercury discharges from Metro differ from other wastewater facilities may be important in making future risk management decisions. We are unaware of mercury entering the lake from the wastebeds. The lake sediments are contaminated with mercury. The role of mercury in the sediments versus the mercury in water entering the lake in contributing to high mercury levels in fish is unclear.



13. COMMENT: The intensity of natural resource uses (e.g. waterfowl hunting, fishing and swimming) is quite low, and this should be specifically stated so as not to overestimate the size of the user group thought to be at risk.
    
    RESPONSE: The text has been modified to reflect this comment.



14. COMMENT: The soft and unstable inshore bottom created by past industrial waste discharges also presents a physical hazard, particularly if swimming was to become a future lake use.
    
    RESPONSE: The text has been modified to reflect this comment.



15. COMMENT: In Conclusion 2, although implied, it should be stated that there is no health hazard associated with the use of Onondaga Lake County Park. The sources or believed sources of PAHs and mercury should be stated as they are in Conclusion 4.
    
    RESPONSE: Based on the levels of mercury and PAHs in current sediments and the potential for exposure, there is no health hazard associated with the use of Onondaga Lake County Park. However, we have no data on contaminant levels along most of the shore, including in dredged sediments used as fill, and are recommending further investigation. The source of mercury in the sediments has been added to Conclusion #2; we do not know the source of PAHs.



16. COMMENT: With regard to the overall recommendations for additional contaminant investigations, how will such work be undertaken and how would it be financed?
    
    RESPONSE: Procedures involved in deciding how the work would be undertaken and financed are the responsibility of the lead environmental agency (in consultation with health agencies and others). Financing is generally the responsibility of the potentially responsible parties or in their absence, federal or state superfund monies.



17. COMMENT: While waterfowl and additional fish sampling is warranted, there is a virtual absence of contamination data for small mammal, reptile and amphibian species in the immediate Onondaga Lake area. Such analyses would be useful.
    
    RESPONSE: Analysis of small mammals, reptiles and amphibians is not recommended at this time since they are an unlikely exposure pathway for humans. However, a recommendation has been added to examine this potential exposure pathway (Recommendation #1). Please note that there is an advisory in New York State regarding ingestion of snapping turtles due to the potential for them to contain PCBs (refer to Fish Advisory, Appendix C). Whether or not snapping turles from Onondaga Lake are eaten is unknown.



18. COMMENT: Contaminant analysis of migratory or highly mobile animal species is of limited use. Additional animal species sampling should focus on the less migratory inhabitants of the Onondaga Lake system.
    
    RESPONSE: Since waterfowl hunting is reported to occur and these animals may be eaten, they represent a potential exposure pathway. Some evidence has shown that contaminants could be present in waterfowl after they live in a contaminated area, even if the length of time spent in the area was only a few months. Furthermore, some species of waterfowl will live in an area year-round, especially if open water is available to them. Therefore, the recommendation to conduct additional investigations to evaluate this potential exposure pathway was made.



19. COMMENT: A systematic monitoring program for contaminants and species of interest should be developed and implemented to track changes in contaminant concentrations over time.
    
    RESPONSE: We agree that a systematic monitoring program should be developed and address this by recommending additional investigations (see Recommendation #1).



20. COMMENT: The PHA appears to be a literature search that adds very little to the existing knowledge and it provides no analysis or evaluation of the real and potential health issues that it identifies.
    
    RESPONSE: The PHA is an analysis of the public health implications posed by the site. It is an evaluation of relevant environmental data, health outcome data, and community concerns associated with a site where hazardous chemicals have been released. The health assessment identifies populations living or working near hazardous waste sites for which more extensive public health actions or studies are needed. An analysis or evaluation of the real or potential health issues identified in the PHA are described in the Public Health Implications section.



21. COMMENT: The authors or editors of the NYS DOH, DEC and DOL publications should be identified.
    
    RESPONSE: Since most agency (e.g., NYS DEC, NYS DOH, NYS DOL) documents are compiled by a number of staff, the names of those who worked on a document are rarely identified or provided to us. If information on the author(s) of a specific document is desired, the appropriate agency may be able to identify the authors.

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