ML20080G020

Statement of Matl Facts as to Which There Is No Genuine Issue

ML20080G020
Person / Time
Site:	Harris
Issue date:	02/07/1984
From:	Carrow H CAROLINA POWER & LIGHT CO., NORTH CAROLINA MUNICIPAL POWER AGENCIES
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20080G006	List: ML20080G004 ML20080G020 ML20080G037
References
ISSUANCES-OL, NUDOCS 8402130238
Download: ML20080G020 (50)

Text

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o February 7,1984 UNITED STATES OF AMERICA E IJ All 19 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BUARDL.

2:

c A ch In the Matter of

)

)

CAROLINA POWER & LIGHT COMPANY

)

AND NORTH CAROLINA EASTERN

)

MUNICIPAL POWETI AGENCY

)

)

Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant,

)

50-401 OL Units 1 & 2)

)

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON WELLS EDDLEMAN'S CONTENTION 83/84B Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in support of their motion for summary disposition of Wells Eddleman's Contention 83/84B in this proceeding, that there is no genuine issue to be heard with respect to the following material facts:

1. The Atomic Safety and Licensing Board has characterized Eddleman Contention 83/84B as questioning whether the health effects of halogenated organic compounds that l

l are carcinogenic as a result of the chlorination of cooling waters in the Harris Plant have

(

been assessed. Memorandum and Order (Ruling on Motions for Summary Disposition of Eddleman Contentions 29/30,64(f),75,80 and 83/84), dated November 30,1983.

2.

On December 21, 1983, the Board of Directors of Carolina Power & Light l

Company (CP&L) approved the cancellation of Unit 2 of the Shearon Harris Nuclear l

Power Plant. Letter of E.E. Utley, Executive Vice President of CP&L, to Harold R.

Denton, Director of the Office of Nuclear Reactor Regulation for the NRC, dated December 21,1983; Affidavit of William T. Hogarth ("Hogarth Affidavit") at 2.

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3. The cancellation of Unit 2 means that the Cape Fear water intake structure has, also been cancelled because make-up water from the river will no longer be needed for Harris plant operations. Hogarth Affidavit at 2.

8402130238 840207 PDRADOCK05000g Q

4. Thus the only possible mixing of SHNPP discharges with Cape Fear River water would occur where Buckhorn Creek flows into and mixes with the Cape Fear downstream of Buckhorn Dam. Hogarth Affidavit at 2.

5.

It has been predicted by a study done by Lawler, Matusky & Skelly Engineers (LMS) that no free available chlorine would be discharged to the Harris reservoir or the Cape Fear River. Hogarth Affidavit at 3.

6.

Models done by LMS conservatively estimated that total residual chlorine concentrations in the Harris lake and the Cape Fear River would be extremely small.

Hogarth Affidavit at 3.

7. Studies performed on the discharges of other known r.uclear power plants which use a hyperbolle cooling tower indicate that the only chlorination by-products formed and discharged which are regulated as known or suspect carcinogens are chloroform, other halomethanes, and 2,4,6-trichlorophenol. f.ffidavit of Dr. James A. Fava and Mr. Hans Plugge (" Fava Affidavit") at 6.

8.

Chloroform and other halomethanes are within the grouping of halogenated organic compounds called haloforms.

2, 4, 6-Trichlorophenol falls within the subset of halogenated organics known as halophenols.

Chlorination dosages and discharge concentrations of the haloforms and halophenols from the report of Dr. Roger M. Bean and dilution calculations from the models done by LMS conservatively show that the concentrations of these compounds which may be found in the Harris reservoir and in the The Cape Fear River at the confluence of Buck Horn Creek are extremely minimal.

haloform concentrations in the 200-acre mixing zone allowed by the NPDES permit was 0.009 ppb, and where Buckhorn Creek flows into the Cape Fear River, concentrations were estimated at 0.00005 ppb. Halophenol concentrations in the same locations were~

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estimated to be 0.005 ppb, and 0.00003 ppb, respectively. Fava Affidavit at 8.

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9.

Comparisons of these estimated concentrations to bloaccumulation data and Environmental Protection Agency water quality criteria for consumption of aquatic organisms demonstrates concentrations of haloforms and halophenols even in a 5 acre mixing zone in Harris reservoir would be at least 100 times lower than the EPA water quality criteria for the applicable designated use of Harris reservoir waters.

The concentrations of those chemicals at the Cape Fear River would be 0.003 percent of EPA criteria for surface water used for drinking purposes and 0.0004 percent of the criteria for fish consumption only. &at 12.

10. Risk assessment analysis indicates the probability of incurring cancer as a result of the incremental contribution by SHNPP to haloforms in drinking water from the Cape Fear River would be 1 in 3,850,000,000 given 70 years of exposure. The risk for halophenols is 1 in 40,000,000,000. Both risks are substantially below even the most conservative risk estimates used by the EPA. &at 13.

11. Further comparison of the estimated concentrations of the SHNPP discharges was made to trihalomethanes concentrations found in drinking waters of North Carolina.

The haloform concentration from SHNPP discharges calculated at the confluence of Buckhorn Creek with the Cape Fear River averages 200,000 to often 1 million times lower than concentrations normally encountered in North Carolina municipal drinking water supplies. & at 17.

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12. There will be no measurable increase in health risks to those using Harris reservoir for recreational purposes (including fish consumption) or those drinking, or l

l eating organisms from, Cape Fear River water downstream of SHNPP as contended. &

at 18.

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13. Health effects which might be caused by the formation of halogenated organic compounds that are carcinogenic as a result of the chlorination of the cooling waters in the Harris plant have been adequately assessed and have been demonstrated to have no adverse impact on the cost / benefit balance under NEPA.

l This the 7 day of February,1984.

AAh6 *t)

Hill Carrow Attorney Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6839 Attorneys for Applicants:

Thomas A. Baxter John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 I

m _ _. _ _ _ - - -

S

.9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'C.

i a ai :19 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD LF:

In the Matter of

)

YilIld

)

CAROLINA POWER & LIGHT C0dPANY

)

AND NORTH CAROLINA EASTERN

)

Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY

).

50-401 OL

)

(Shearon Harris Nuclear Power Plant, )

Unit 1)

)

AFFIDAVIT OF JAMES A. FAVA AND HANS PLUGGE IN SUFPORT OF

SUMMARY

DISPOSITION OF EDDLEMAN CONTENTION 83/84B (CHEMICAL DISCHARGES)

County of Baltimore

)

)

State of Maryland

)

James A. Fava and Hans Plugge, being duly sworn according to law, deposes and says as follows 1.

We are Vice President and Senior Scientist, respectively, within the Scientific Operations Division of Ecological Analysts, Inc., Sparks, i

Maryland. We have personal knowledge of the matters set forth herein and believe them to be true and correct to the best of our knowledge, information, and belief. A statement of our professional i

l l-qualifications and experience is attached.

i 2.

Eddleman Contention Issues l

On 30 November 1983, the Atomic Safety and Licensing Board stated that the affidavit of Dr. William T. Hogarth failed to address "the I.

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effects on human health that might be caused by the formation of i

halogenated organic compounds that are carcinogenic, as a result of chlorination of the cooling waters in the Harris plant." This affi-davit utilizes technical information to address these issues for the

_Shearon Harris Nuclear Power Plant (SHNPP).

i 1

In this affidavit, we will first show which carcinogenic organic chemicals may be present in discharges at SENPP.

Then we will analyze the most up-to-date report of chlorination and organic by-product formation to determine which carcinogens are formed within I

nuclear power plants. Next, based on chemical testing at other nuclear power plants, and mathematical modeling specifically for q

SENPP, concentrations of carcinogenic organic by-products are conservatively estimated for both the reservoir and the Cape Fear River. Then, to assess the potential human health effects of these (suspected) carcinogens, exposure via both drinking water and the consumption of contaminated aquatic organisms is evaluated by com-

' paring reservoir and river concentrations to appropriate U.S. EPA water quality criteria for the protection of human health, i

3.

In order to assess which carcinogens may be present in the discharge from SHNPP we first listed all chemicals expected to be p esent in the SENPP discharges and then evaluated their carcinogenicity. The presence of chemicals in the discharge was based on the most compre-.

hensive and up-to-date report of the for=ation of chemicals in cool-ing waters as a result of chlorination (Bean 1983). This report surveyed chlorination by-product formation at eight nuclear power 2

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plants.

Given the variety of power plant designs and their influence on chlorination by-product formation, it was felt that data for installations using natural draft cooling were the most representa-tive with regard to predicting the chemicals expected to be formed as a result of SENPP operation.

SRNPP will use natural draft hyper-bolic cooling towers. The Bean (1983) report evaluated three plants with similar systens:

- Arkansas Nuclear One, Unit #2, Russelville, Arkansas Beaver Valley Power Station, Unit #1, Shippingport, Pennsylvania Trojan Nuclear Plant, Rainier, Oregon Further= ore, like SHNPP, each of these facilities discharges to freshwater.

I Exhibit A details the chemicals found by Bean (1983) in discharge and intake waters of these three nuclear power plants.

As evidenced by the fact that the analytical detection limits reported by Bean (1983) l l

are one to three orders of magnitude lower than standard U.S. EPA l

l priority pollutant analysis methodology (EPA 1982), the results pre-f l

sented by Bean (1983) are the best and most sensitive date, presently I

available.

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The determination of which of these chemicals found in the discharge are carcinogens or suspected carcinogens was based on careful reviews of U.S. EPA water quality criteria documents and the cancer research databases listed below:

RTECS--Registry of Toxic Effects of Chemical Substances.

Produced by the National Institute of Occupa. ion 21 Safety and Health (NIOSH) with the on-line data file naintained by the National Library of Medicine.

Updated quarterly, RTECS contains data for approximately 53,000 substances.

PBS-149--U.S. Department of Health, Education and Welfare's Survey of Compounds Which Have Been Tested for Carcinogenic Activity.

CANCERLINE--Sponsored by the International Cancer Research Data Bank Program of the National Cancer Institute, this database contains over 260,000 citations pertaining to all aspects of cancer.

It is updated monthly with approxi-mately 4,000 citations.

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[

NCI BI0 ASSAY--National Cancer Institute reviews and summary of NCI carcinogenicity tests.

IARC Review--Monographs by the International Agency for Research on Cancer which address the carcinogenic risks i

of numerous chemicals to humans.

4

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Exhibit A includes the following suspect carcinogens which were determined to be present in cooling water discharges evaluated in the Bean (1983) report:

Volatiles

- carbon tetrachloride

- chloroform

- 1,1-dichloroethylene

- 1,2-dichloropropane

- methylene chloride

- (tri)halomethanes (bromodichloromethane, chlorodibromomethane, tribremomethane)

- tetrachloroethylene

- trichloroethylene Phenols

- 2,4,6-trichlorophenol t

Base-Neutral - dichlorobenzene l

It should be noted here that, although 2-chlorophenol has been i

reported to cause skin papillomas following topical applications, U.S. EPA currently _ deems the scientific evidence inadequate to regulate 2-chlorophenol as a carcinogen (see also Section #7 of l

this affidavit and Exhibit D).

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Although these carcinogens were determined to be present in dis-j charges, the majority of them were not produced as a result of chlorination but were instead already present in intake waters (see Section #4 below).

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4.

Following the identification of carcincgens which may be present in the discharge from SENPP, one needs to determine which of these chemicals are actually formed as a result of chlorination of the cooling water. Exbibit B' presents an exten?ive discussion of the results of Bean's report (1983) as well as personal communications with Dr. Roger M. Bean (1984).

Based on this discussion and the results presenttd in Section #3 of this affidavit, only the following chem 1cals will be conside~ red in our discussion of hesith effects of carcinogens present in Cape Fest River and SHNPP reservoir w2ters:

Chloroform Halomethanes (the sum of bromodichloromethane, chlorodibromomethane, and tribromomethane) 2,4,6-Trichlorophenol Please note that chloroform and 2,4,6-trichlorophenol are the only two identified carcinogens formed in the plant as a result of chlo-rination and discharged. The trihalomethanes are regulated by U.S.

EPA as suspect carcinogens based on their structural similarity to chloroform but without sufficient data to indicate their actual carcinogenic potency, if any. Also note that all of these carcino-gens are present in intake water, albeit at lower concentrations (Exhibit A).

5.

Concentrations of chlorine and chlorination by-products expected to

. result from operation of SHNPP were addressed by Lawler, Matusky and Skelly Engineers (LMS). This LMS study is included as an exhibit in 6

Dr. W.T. Hogarth's affidavit.

Based on the LMS study, we calculated the following equations which mathematically describe the dilution processes occurring between end-of-pipe discharge, two different mixing zones in the reservoir (5-and 200-acre) and the contribution /

dilution to the Cape Fear River. These equations are as follows:

Equation 5.1 Chemical Concentration (ppb) in 5 acre mixing zone

= chemical fl.ux (1b/ day) at end-of-pipe x 0.42 Equation 5.2 Chemical Concentration (ppb) in 200 acre fully mixed mixing zone

= chemical concentration (ppb) in 5 acre fully mixed mixing zone x 0.025 Equation 5.3 Chemical concentration (ppb) discharged to Cape Fear

= chemical concentration (ppb) in 200 acre fully mixed mixing zone x 0.57 Equation 5.4 Average incremental contribution fr6m SRNPP for chemical to Cape Fear (ppb)

= chemical concentration (ppb) discharged to Cape Fear x 0.01 As an estimate of the quantity of discharged by-products that were t

created by the chlorination of nuclear power facilities, power plant specific chemical data presented in Bean (1983) were utilized to calculate the formation rates of haloforms and halophenols which might be expected from SHNPP chlorination practices.

Exhibit C presents estimated daily discharges of haloforms and halogenated phenols by the three operating nuclear power plants studied by Bean 7

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a (1983) which use natural draft hyperbolic cooling towers and dis-charge into freshwater.

Exhibit C ladicates that a maximum level of O.12 percent of the initial chlorine dose is recovered at end-of pipe as haloforms in the cooling water discharge plume.

Similarly, a maximum of 0.07 percent of the initial chlorine dose is recovered at end-of-pipe as halophenols in the discharge. Thus, using a maximum total chlorine dose of,725 pounds / day at SENPP, Ecological Analysts (EA) computed a maximum haloform discharge of 0.87 pounds / day. Using the equations above, this discharge is diluted to 0.36 ppb over a 5-acre mixing zone (Equation 5.1) and to 0.009 ppb over the NPDES permitted 200-acre mixing zone (Equation 5.2).

The average incre-mental total haloform input to the Cape Fear River is estimated to be only 0.00005 ppb (Equations 5.3 and 5.4).

Using EA's estimate of 0.07 percent of the chlorine dose forming halogenated phenols, the total halogenated phenol levels would be approximately half of the total haloform inputs computed above.

Thus, over the NPDES permitted 200-acre mixing zone, the concentration of halogenated phenols is estimated to be 0.005 ppb and the incremental halogenated phenol dose to the Cape Fear River would be 0.00003 ppb, a very small contribu-tion (Exhibit E).

Although not accounted for in this assessment, the already low halogenated organic concentrations that are predicted in both the reservoir and the river would be reduced further as a result of evaporative transport, especially at the reservoir spillway into Buckhorn Creek, during the 2.5-mile transit down Buckhorn Creek and 8

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the 15 miles of the Cape Fear River prior to the water's first con-i 4

sumptive use at Lillington.

It is noteworthy that the Final Environmental Statement and the LMS exhibit (see Hogarth affidavit) indicate that no free chicrine will be released into the reservoir thereby precluding the formation of chlorinated compounds in the reservoir itself or in the Cape Fear River.

6.

As aquatic species have been demonstrated to bioaccumulate many chemicals, there is a potentisl that consumption of contaminated organisms could adversely affect human health. The protection of

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human health from contaminated aquatic organisms is carefully con-sidered by the U.S. EPA's water quality criteria. Thus the criteria for chloroform, halomethanes, trichloroethylene, tetrach: 3roethylene, i

2,4,6-trichlorophenol, and dichlorobenzene include specific termi-nology which limit the concentrations of these chemicals in water from which aquatic organisms are consumed (see the column titled l

"At 10-5 consumption only" in Exhibit D).

j.

For.the halogenated carcinogens found in the power plant as a result of chlorination (see Section #4 above), U.S. EPA's water quality cri-l teria documents report the following bicaccumulation data which indi-I cate that bioaccumulation potentials for these chemicals are low:

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4 Chloroform - The bioconcentration factor (ECF) was determined 4

to be 6 in 14 /nys (EPA 1980s p. B-2).

This means that in 14 days, concentrations of chloroform measured in tissues were only six times higher than the concentration in the exposure water.

4 Halomethanes "no re'sidue data for freshwater fish are available for halomethanes other than for chloroform and carbon tetrachloride, for which bioconcentration factors were 6 and 30 respectively."

(EPA 1980b p. B-3) i 2,4,6-Trichlorophenol "no measured steady-state BCF is available for trichlorophenols, but the equation ' Log BCF =

(0.85 Log P)-0.70' can be used to estimate the steady state BCF for aquatic organisms."

(EPA 1980c p. C-53).

It is noteworthy that Bean (1983) performed a limited study of bioaccumulation and concluded that "no halogenated material was found to be bioaccumulated in mussels [the only organisms evaluated] exposed to the chlorinated discharge of a marine power station (Millstone)."

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4 Under contuact to the U.S. Nuclear Regulatory Commission, Anderson and Lusty (1980) researched the bioaccumulation and depuration of chloroform by four freshwater fish species:

rainbow trout (Salmo rairdneri), bluegill (Lecomis macrochirus),

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largemouth base (Microcterus salmoides), and channel catfish 10

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(Ictalurus nunctatus). The authors concluded that "in all species tested, the bioaccumulation of chloroform from the.

concentration in the water (1.0 to 1.5 ppm] was less than one 1

order of magnitude" (Anderson and Lusty 1980, p. 11.) Depuration rates were also experimentally,shown to be rapid.

7.

The potential'for human health effects from the consumption of contaminated aquatic species and/or drinking water for these three carcinogens can be assessed by direct comparison with appropriate water quality criteria (see Exhibit D).

Unlike water quality standards, criteria are not enforceable numbers. Rather, they utilize the most complete database available to indicate concentrations that vill protect human populations from adverse health effects which might result-from continuous lifetime expo-sures. Thus, when states establish enforceable water quality standards, the published U.S. EPA criteria are used as guidance, and the resulting standards are almost always higher (less i

stringent) than the criteria on which they are ultimately based.

Chloroform represents a classic example of this, as the water l

quality criterion for drinking water is 1.9 ppb whereas the enforceable primary drinking water standard is 100.0 ppb (Exhibit D).. Using the bicaccumulation potential data discussed in Section #6 above, U.S. EPA calculated the following water quality criteria which are specifically designed to protect human health from the consumption of aquatic organisms living in a waterbody:

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Comoound 10-5 Criterion Chloroform 157.0 ppb Halomethanes 157.0 ppb 2,4,6-Trichlorophenol 36.0 ppb The reservoir concentrations (within a 5-acre mixing zone) which are expected to result from the operation of SENPP are conservatively estimated to be at least 100 times lower than these appropriate cri-teria which are established specifically to protect humans from the consumption of contaminated aquatic arganisms (Exhibit E).

A far greater degree of safety will exist relative to concentrations expected in the 200-acre mixing zone and in the Cape Fear River (Exhibit E). Thus, concentrations of haloorganics in the reservoir will, even using extremely conservative assumptions, be less than 1 percent of U.S. EPA water quality criteria for the protection of human health corresponding to the North Carolina Class C use cate-gory of the reservoir, i.e., recreational with no drinking water consumption.

The incremental contribution of total baloforms from SENPP discharges into the Cape Fear River is expected to be at most 0.00005 ppb, less than 0.003 percent (three one-thousandth of one percent) of the EPA water quality criteria for surface water used for drinking purposes, and 0.00004 percent of the U.S. EPA water quality criteria for fish consumption only (Exhibit E).

Both of these numbers were calculated assuming a health effect probability of 10-5 These health effect probabilities (see also Exhibit D) indicate the exposure levels 12

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(i.e., 1.9 ppb for chloroform in water) which need to be consumed for 70 years to result in an upper limit likelihood (highest chance) of contracting one additional case of cancer in a population of 100,000.

Note that the number does not imply that 1 in 100,000 vill get can-cer, but that the highest possible chance (at 95 percent confidence upper limit) will be 1 in 100,000. These models highly overestimate risk, and the " average" risk is normally 1 to 4 orders of magnitude lower than the " upper limit" risk used in the criteria (Rodricks and Taylor 1983). The incremental contribution of SENPP discharges to total halophenols in the Cape Fear River is expected to be at most 0.00004 ppb or 0.0005 percent of the U.S. EPA water quality criteria for drinking water for 2,4,6-trichlorophenols (Exhibit E).

The actual " risk levels" associated with the haloforms and halophenols are as follows:

Halophenols Haloforms 200-acre dilution zone Fish consumption 1.4 x 10-9 5.7 x 10-10 Cape Fear River Drinking water 2.5 x 10-11 2.6 x 10-10 l

Fish consumption 8.3 x 10-12 3.1 x 10-12 l

What this means is that the probability of incurring canc:: as a result of SHNPP contribution to haloforms in drinking water from the Cape Fear River would be 2.6 x 10-10 or 1 in 3,850,000,000 given 70

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years of exposure to the 0.00005 ppb in Cape Fear River water. These l

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levels are far below even the uost strict (conservative) estimates of 1 in 10,000,000 (10-7) provided by U.S. EPA in their water quality criteria.

Such calculations, as made above, inherently incorporate some very conservative assumptions:

all haloforms are carcinogenic (not proven) all haloforms are as potent as chloroform (not proven) the methodology uced to calculate the cancer risk estimate is very conservative and uses upper 95 percent confidence limits rather than mean values resulting in overestimation of risk by several orders of magnitude (Ruckelshaus 1983) assumes that all of the haloforms and halophenols present in the discharges are formed in the plants, whereas much of the concentration discharged was already present in the intake waters of the facility (see Exhibits A and B) l all halophenols are carcinogenic (not proven) l all halophenols are as toxic as 2,4,6-trichlorophenol i

(not proven) l no evaporative transport, metabolism, or binding to organic material occurs between the discharge point and i

the Cape Fear River l

there is no dilution beyond the 200-acre mixing =ene in l

a 4,000-acre reservoir l

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t SENPP chlorination will result in a formation rate for haloforms and halophenols equal to the highest rates observed in Bean (1983), rather than the average rate.

Thus, at the 10-5 criteria level, all applicable U.S. EPA water quality criteria for the organchalechemicals formed as a result of chlorination practices at SHNPP are expected to be met with at least two orders of magnitude safety margin in the reservoir (5-acre mixing zone) and at least four orders of magnitude in the Cape Fear River beyond the levels established by U.S. EPA for the protection of human health.

It is also important to note that the concentrations of regulated haloorganics within the SHNPP reservoir (5-acre and 200-acre mixing zones) and the Cape Fear River also comply with U.S.

EPA water quality criteria for the protection of human health at the much more conservative 10-6 and 10-7 criteria.

Stated differently, this means that expected concentrations also comply with the federal criteria which are conservatively designed to limit the highest possible chance of producing 1 additional cancer in a population of 1,000,000 (at 10-6) and a population of 10,000,000 (at 10-7). As noted by Dourson and Stara (1983), these U.S. EPA criteria already have several safety factors incorporated during their development.

8.

In order to put the concentrations of trihalomethanes (TEMs) and other chlorination by-products further into perspective, it is informative to compare expected SENPP effluent concentrations with concentrations measured in finished drinking waters of North Caro-lina.

Based on mathematical modelling by LMS for SHNPP, and measured 15

discharge concentrations at nuclear power generation facilities studied by Bean (1983) which utilize natural draft cooling towers, total haloform levels in the reservoir (200-acre mixing zone) are expected to be approximately 0.009 ppb. The nearest downstream com-munity that withdraws water from the Cape Fear River for consumptive purposes is Lillington (Harnett County).

Therefore, prior to human consumption, these already low THM concentrations will be reduced via simple dilution and volatilization during transit down 2.5 miles of Buckhorn Creek and an additional 15 miles down the Cape Fear River before reaching the Lillington water treatment plant.

Like most municipal water treatment plants, Lillington utilizes chlorination to disinfect water supplies to protect public health.

As in power plant applications, THMs are an unavoidable by-product of municipal drinking water chlorination.

Based on conversations with Lassiter (1984 personal communication) measured total THM concentrations for the four municipalities of the Harnett County Utilities system for the las: turee quarters of 1983 are presented below.

Summer Spring Winter (August 1983)

(May 1983)

(February 1983)

Community (pob)

(pob)

(opbi Lillington 134 116 61 Buies Creek 210 158 89 Coats 186 155 120 Angier 195 135 87

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The geometric mean of these total THM finished drinking water measurements is 129.5 ppb, a value which is more than 14,000 times higher than the haloform concentration in the reservoir estimated to occur as a result of SENPP chlorination activities and more than 2,500,000 times higher than SENPP's expected contribution of halo-forms into the Cape Fear River.

Although these Harnett County total THM finished drinking water measurements occasionally exceed the U.S. EPA's primary drinking water standard of 100 ppb (Exhibit D), total TEM concentrations in the Lillington water supply system are not atypical of North Creolina municipal water supplies.- Singer et al. (1982) evaluated TEM forma-tion in nine of the larger cities in North Carolina. Average THM concentrations in finished waters ranged from 11 ppb in Asheville to 120 ppb in Raleigh (Exhibit F).

Finished water THM concentrations in Durham were reported to average 55 ppb, a concentration that is 6,000 times higher than are conservatively estimated to be present in the SENPP reservoir and 1,000,000 times higher than SENPPs estimated haloform contribution to the Cape Fear River. These data show that concentrations normally encountered in North Carolins municipal drinking waters are at least 200,000 times and of ten one million times higher than those expected to be discharged into the Cape Fear River by the operation of SHNPP.

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In conclusion, it is our opinion based on the evidence presented above that operation of SENPP and the organchalogen levels that are expected to be produced will not result in a measurable increase in health risk to either the population using the reservoir for recreational purposes (including fish consumption) or the use of Cape Fear water for drinking water or recreational purposes.

4 February 1984 M

James A.' Fava c

3 M/

/,Hans(Plugge

(

Sworn to and subscribed before me, this the 4th day of February 1984.

td Y Am Notary Public My Commission Expires aba /, / 970 O

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r LITERATURE CITED Anderson, D.R. and E.3. Lusty.

1980. Acute toxicity and bioaccumulation of chloroform to four species of freshwater fish.

Prepared for the U.S. Nuclear Regulatory Commission.

NUREG/Cr-0893, PNI-3046. 33pp.

Bean, R.M.

1983.

Organohalogen products from chlorination of cooling water at nuclear power stations.

Prepared for the U.S. Nuclear Regulatory Commission.

NUREC/CR-3408.

155 pp.

Bean, R.M.

1984. Personal communication.

Battelle Pacific Laboratory, Richland, Washington. January 1984 Dourson, M.L. and J.F. Stara.

1983. Regulatory history and experimental support of uncertainty (safety) factors.

Regulatory Toxicology and Pharmacology 3:224-238.

Lassiter, B.

1984. Personal communication.

Earnett County Utilities Authority', Lillington, N.C.

4 January 1984.

Rodricks, J. and M.R. Taylor.

1983. Application of risk asses,sment to food safety decision making.

Regulatory Toxicology and Pharmacology 3:275-307.

Ruckelshaus, W.D.

1983. Statenent of William D. Ruckelshaus, Administrator, U.S. Environ = ental Protection Agency, befora the Subcommittee on Oversight and Investigations Co=mittee on Energy and Commerce.

U.S. House of Representatives.

7 November 1983.

Singer, P.C., J.J. Barry, G.M. Palen and A.E. Scrivner.

1982.

Trihalomethane formation in water treat =ent plants in North Carolina.

Water Resources Research Institute, Report No.179.

U. S. EPA.

1980 a.

Ambient Water Quality Criteria for Chloroform.

I PB81-117442 or EPA-440/5-80-033.

U.S. EPA.

1980b. A=bient Water Quality Criteria for Hale = ethanes.

P381-117624 or EPA-440/ 5-80-051.

U. S. EPA.

1980c. Ambient Water Quality Criteria for Chlorinated Phenols.

P381-117434 or EPA-440/5-80-032.

U.S. EPA.

1982. Analytical test methods 624 (purgeables) and 625 (base / neutrals and acids).

Environmental Monitoring and Support Laboratory.

Cinc inna ti, Ohio.

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EXillBIT A.

COMPOUNDS IDENTIFIED IN SAMPLES FROH NUCLEAR POWER PLANTS (All Concentrstions in Parts-Per-Billion)

Arkansas Nuclear One Beaver Valley Power Unit #2 Statioin Unit il Troian Nuclear Plant Intake Discharge Intake Di scha rge Intake Discharge t

volatiles I,1-Dichloroethylene tr 0.1 1,1-Dichloroethane 0.01 1,2-Dichloropropane 0.2 0.2 1,3-Dichloropropane, (cis + trans)

Hethylene Chloride 0.1 0.4 5.9 2.9 B romoilichlorooie t hane 0.7 0.02 0.06 tr Chloroform 0.2 0.7 0.3 0.5 0.2 0.3 1,1,2,2-Tetrachtoroethane 1,2-Dichloroethylene 0.1 1,2-Dichloroethane 0.02 Chlorobenzene 1,1,1-Trichloroethane 0.1 Carbon Tetrachloride tr Chlorodibromomethane 0.8 0.3 0.1 Trichloroethylene 0.2 0.2 0.03 0.03 Tetrachloroethylene 3.1 2.5 0,1 0.01 0.02 Bromoform 0.2 tr tr Note: IIS = identified by GC/HS analysis of XAD-2 extracts, but not found by electron capture analysis of 1-liter extracts, tr - Concent rations detected by electron capture detectors but were below 0.1 ppb.

Source:

Bean (1983).

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EXHIBIT B FORMATION OF (SUSPECT) CARCINOGENS IN COOLING WATERS OF NUCLEAR POWER PLANTS FOLLOWING CHLORINATION FOR BI0 FOULING CONTROL This exhibit discusses in detail the formation of three classes of chlorinated chemicals--volatiles, phenols, and base-neutrals as a result of chlorination of cooling waters in nuclear power plants.

These three classes are defined as follows:

volatiles-a group of chemicals which volatilize (go into the gaseous state) easily at room temperature, and are analyzed by purging (bubbling air through a vessel) the volatiles out of a water sample into a trap.

ohenols-a group of chemicals having the basic structure of a benzene group with a hydroxyl substitution.

They are analyzed following extraction from an acidified water sample, and are thus often called acid-phenols.

base-neutrals-a group of chemicals which is nonvolatile and nonphenolic.

They are analyzed following extraction from either a basic or neutral water sample and are thus known as base-neutrals.

Exhibit A identifies the specific chemicals found in operating nuclear power plant intakes and discharges for each of these three chemical groupings.

Conclusions regarding which chemicals are formed B-1

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in nuclear power plant cooling waters are based on the data presented in Bean (1983) for the three operations 1 nuclear facilities mentioned in Section #3 of this affidavit, as well as personal communications with Dr. Roger M. Bean (January 1984).

Volatiles For the volatiles at the Arkansas Nuclear One, Unit #2, the data presented in Bean (1983) indicate that chloroform is the only identi-fied carcinogen of the volatiles group formed in the plant, although the other tribalomethanes (bromodichloromethane, chlorodibromo-i methane, and brosoform = tribromcmethane) are regulated by U.S. EPA (45 Federal Register 79318) as suspect carcinogens under the assump-tion they have the same potency as chloroform based on structure-activity relationships.

1,2-Dichloropropane and tetrachloroethylene are not formed in the cooling water but are instead present in the intake water (Exhibit A).

Because these volatiles were not created by the operation of the plant, they are not of concern regarding this contention.

At the Beaver Valley Power Station, Unit #1, the only identified carcinogen formed is chloroform, while a single trihalomethane (bromodichloromethane) is also formed.

1,2-Dichloro ethylene,

methylene chloride,1,1-dichloroethane,1,2-dichloroethane, 1,1,1-trichloroethane, chlorodibromomethane, trichloroethylene, and tetrachloroethylene are not formed in the plant.

The conclusion regarding the non-formation of methylene chloride is based on its B-2

constant concentration in the intake and taver basin (Bean 1983),

observations at other plants, as well as the possibility of labora-tory variability.

Using the analytical methods of Bean (1983), the minimum detection (precision) limit for volatiles that is quantifi-able with certainty is 0.1 ppb (Roger Bean, personal communication 1984). This means that numbers quantified as 10.1 ppb cannot be used to indicate the formation of a chemical within a power plant with certainty. Although bromoform appears to be formed as evidenced by its elevated concentration in the tower basin (Bean 1983), there is no net discharge.

1,1-Dichloroethylene is not considered to be formed by plant operations based on the low concentration detected and the presence of 1,2-dichloroethylene in the intake and not in the discharge.

At.the Trojan Nuclear Plant, Bean's (1983) data indicate that only chloroform and a single trihalomethane (bromodichloromethane) are formed in the plant.

Methylene chloride and tri-and tetra-chloroethylene are not formed in the plant. Tetrachloroethylene was deemed to be not formed based on (1) its absence from the tower basin, (2) the results from the two other plants, and (3) confirma-tion by Bean (1984 personal communication).

Phenols 2,4,6-Trichlorophenol is a confirmed carcinogen and is appropriately regulated by the U.S. EPA (45 Federal Register 79318, and Exhibit D).

The data collected by Bean (1983) indicate that 2,4,6-trichlorophenol B-3 l

was the sole carcinogenic phenol formed at each of the three plants studied.

Base Neutrals None of the base-neutrals appear to be formed during chlorination of cooling water at any of the three plants studied by Bean (1983).

Further discussion of this chemical group thus appears unwarranted.

Thus, chloroform and 2,4,6-trichiarophenol are the only identified carcinogens formed in the cooling waters of these three operating nuclear power plants. The data also indicate that trihalomethanes are also formed within the plants.

Tribalomethanes are regulated by U.S. EPA (45 Federal Register 79318) as (suspect) carcinogens based on their structural similarity to chloroform, and assuming they have the same dose-response and potency data as chloroform.

It is noteworthy that both of the carcinogens that are expected to be formed within the plant are also present, albeit at somewhat lower levels, in intake waters.

B-4

EXHIBIT C.

ESTIMATED DAli.Y DISCHARGE OF HALOFORMS AND HALOCENATED PHENOLS BY NUCLEAR POWER PLANTS Chlorine Haloforms Percent Halophenols Percent Dose Dischargefb) f se that Dischargefb) of Dose that Facility pounds / day (,)

Rrams/ day is Haloforms Rrams/ day is Halophenols Arkansas Unit #2 125 70 0.12 17 0.03 Beaver Valley Unit #1 250 67 0.06 22 0.02 Trojan 250 120 0.11 75 0.07 (a) Source - Table 2 of Bean (1983).

(b) Source - Table 22 of Bean (1983).

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EXHIBIT D.

U.S. EPA CRITERIA FOR THE PROTECTION OF HUMAN HEALTH Maximum At 10-5 Drinking At 10-5 Concentration Organoleptic Health and Consumption Consumption Only (ppb)

(ppb)

_1 ppb)

(ppb)

(opb)

Applicable II.S. EPA Priority Pollutants. 28 NOV 80 (45 Fed Rea 19318)

Volatiles Carbon tetrachloride 4.0 69.4 chloroform 1.9 157.0 llaloethers No data IIalome t hanes 1.9 157.0 Pentachlorophenol 30.0 1,010.0 Trichloroethylene 27.0 807.0 Tetrachloroethylene 8.0 88.5 Chlorinated Phenols 2-chlorophenol 0.1 3-chlorophenol 0.1 4-chlorophenol 0.1 2,3-dichlorophenol 0.04 2,4-dichlorophenol 0.3 3,900.0 2,5-dichlorophenol 0.5 2,6-dichlorophenol 0.2 3.4-dichlorophenol 0.3 2,3,4,6-tetrachlorophenol 1.0 2,4,5-trichlorophenol 1.0 2,600.0 2,4,6-trichlorophenol 2.0 12.0 36.0 2-methyl-4 chlorophenol 1,800.0 3-methyl-6 chlorophenol 20.0 Base Neutrals Dichlorobenzene 400.0 2,600.0 Applicable II.S. EPA Primary Drinking Water Standards Total Tribalomethanes 100

EXHIBIT E.

COMPARISON OF PREDICTED CONCENTRATIONS WITH U.S. EPA WATER OUALITY CRITERIA (All values in earts ner billion (ur/ liter)

Halophenols Haloforms 10-5 Consumption Criteria (a) 36.0(b) 157.0(c) 5-acre concentration 0.21 0.36 200-acre concentration 0.005 0.009 10-5 Drinking and Consumption criteria (a) 12.0(b) 1,9(c) 200-acre concentration 0.005 0.009 Cape Fear River contribution 0.00003 0.00005 (a)

U.S. EPA Water Quality Criteria published 28 November 1980 (45 Federal Register 79318).

(b) Most restrictive (lowest) of the health related criteria for any chlorinated phenol (2,4,6-trichlorophenol).

(c)

Same criteria for chloroform and halemethanes.

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1

UtHIBIT F.

AVERAGE TOC AND THM CONCENTRATIONS FOR EACH OF THE FACILITIES INCLUDED IN THE NORTH CAROLINA SURVEY (a)

Finished Water Raw Water TOC INST THM Trestment Facility (Dom)

(Dom)

Asheville 0.7 11 Chapel Hill 6.6 105 Charlotte-Hoskins 2.1 41 Charlotte-Vest 2.1 73 Durham 6.9 55 Gastonia 3.0 33 Greensboro-Mitchell 4.3 52 Greensboro-Tcwnsend 4.2 32 Raleigh-Bain 4.5 120 Raleigh-Hohnson 6.4 90 Wilmington 7.7 148 Winston-Salem-Neilson 4.0 50 Winston-Salem-Thomas 4.8 47 (a) Each entry in this table, with the exception of Asheville, represents an average of at least three, and usually four, separate samples, collected at different times of the year, to avoid seasonal bias.

In the case of Wilmington, a large portion of the samples were collected during the spring and summer months in order to evaluate the impact of Wilmington's decision to discontinue prechlorination on June 2,1980.

Source:

Table 14 in Singer et al. 1982.

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ECCLOGICAL ANALYSTS. INC.

- */

JAMES A. FAVA, Ph.D.

Vice President, Toxicology Services Dr. Fava is responsible within Ecological Analysts for the management, design, and implementation of environmental toxicology and environ-mental health programs, including conceptual evaluations and bioassay assess =ents reisting to the Clean Water Act, Ocean Dumping Act, RCRA, FIFRA, TSCA, and "Superfund." He actively participates as a working professional scientist / consultant and interacts directly with clients concerning technical evaluations, impact assessments, bicassay evaluations, computerized database development, legal and legislative i=plications, and program design and implementation.

EXPERIENCE:

BI0 MONITORING (EFFLUENT T0XICITY TESTING): As a result of a number of research efforts, experience has been gained into the advantages, disadvantages, and limitations of conducting biological monitoring associated with NPDES permits. Activities have included the evalua-tion of the scientific validity of federal and regional guidelines for effluent toxicity testing (ETT); a survey of national, EPA region, and state approaches to ETT; participation in a joint EPA /

industry (API, CMA, and UWAG) meeting on the appropriateness of ETT; and conduct of onsite/offsite toxicity testing.

WATER OUALITY REVIEWS: Directed and actively participated in critiques of proposed and existing state / federal water quality criteria, standards, and end-of-pipe limitations for a variety of industrial clients. Substances evaluated included ac=onia, arsenic, s

asbestos, chlorine, cyanide, cadmium, copper, chromium, chloroform, chlorophenols, copper, iron, mercury, nickel, PAHs, and zinc.

In addition, U.S. EPA's various guideline methodologies for deriving toxic substance water quality criteria have been comprehensively evaluated as they have evolved. Recent efforts have critiqued proposed water quality standard regulations including use-attain-ability analyses and the approach to site-specific criteria formulation.

WATER CHLORINATION: Extensive research on the toxicological and ecologierl impacts associated with the use of chlorination has been conducted. The use of chlorine to control biofouling on once-through cooling systems, including OTEC was assessed. Toxicological effects examined include acute and preference / avoidance testing on

~

freshwater and marine fishes and macroinvertebrates. Some of these efforts have resulted in preparation and presentation of expert testi=ony. Conceptually, work has been conducted in areas of critiquing national and state draft chlorine water quality criteria

ECCLCC4 CAL ANALYSTS, INC.

,.g James A. Fava /page 2 and developing specific technical sessions at the last two Water Chlorination Conferences.

OCEANOGRAPHIC EVALUATION: Activities included the collection of water quality and plankton samples, bottom cores, and various oceanographic research ef forts while aboard NOAA.'s U.S. Research Ship Oceanographer during its year-long global cruise. Additional assessments relate to the biological, chemical, and toxicological evaluations of materials released--directly or dumped--into the marine environment. These efforts involved the integration of diverse scientific data and information into multidisciplinary assessments associated with predicting or measuring the impacts of man's activities in the oceans.

LEGISLATIVE ASSISTANCE: During reauthorization in 1962 and 1983 of the Marine Protectica, Research and Sanctuaries Act of 1977, actively provided technical assistance to New York City's Washington D.C. office to support its efforts relevant to the Ocean Dumping Act Amendment of 1962. Activities inc:uded (1) discussicas with various Congressional staff, (2) preparation of technical testimony to support hayor Koch's testimony bef ore Congressional hearings, and (3) a presentatica before the entire staff of the Merchant harine and Fisheries Committee of the House of Representatives concerning the adequacy of the existing Ocean Dumping Act and Regulaticas to allow for a comprehensive assessment of ocean dumping, including site designation rulemaking and special permit application.

SOLID /EAZARDOUS WASTE DISPOSAL: Evaluated the environmental ef fects of ocean dumped materials (e.g., sewage sludge in the hev Ycrk Bight) and participated in a comparative multimedia assessment of the impacts of sewage sludge disposal by composting, incineraticn, and ocean disposal.

PHYSIOLOGY / T0XICOLOGY: Extensive research conducted on the physio-logical ef f ects of chemical, thermal, and complex mixtures on numerous marine, estuarine, and freshwater fish species. Effects examined include pref erence/ avoidance, lethal, sublethal, bio-accumulation, and acute responses. Additional research evaluated the acute toxicity of chicrine and ammonia and the interactive ef f ects of chemical pollutants and temperature on the behavior of several estuarine organisms.

ENVIR0hhlNTAL IMPACT ASSESShihT: Evaluated the potential impacts of point-source discharges relating to sewage treatment plant and industry operatien. These ef forts included water quality analysis, field biological assessments, ef fluent evaluaticus, literature 4

i

n ECCLCGiCAL ANALYSTS,INC.

James A. Fava /page 3 reviews, bicassays, biostatistics, and preparation of expert testimony.

STATE-OF-ThE-ART REPORTS: Directed and pa.rticipated in the prep-aration of monographs on cyanice, ammonia, and chrcmium that evaluated the sources, cSemistry, environmental fate, and aquatic effects of these ccmpounds. These efforts required the interactica of scientists from several disciplines.

CRITICAL REVIEW: Referee for technical papers submitted to the Transactions of the American Fisheries Society, Journal of The Fisheries Research Board of Cansda, and Water Chicrination Confer-ences. Reviewed and critically examined the rechnical validity and appropriateness of various. proposed f ederal and state environmental regulations as to protection of the aquatic environment. Recent activities included the critical evaluation of proposed onsite effluent toxicity testing protocols relevant to the second round of hPDES permits. These ef forts included conceptual ciscussions with leading scientists, regulatory authorities, and attorneys relevant to the technical direction of the critiques.

C0hFEREhCE PLANNING: Organized and participated in the development of technical programs associated with scientific conferences, including the National American Fisheries Society's meeting, and the Third and Fourth Water Chlorination Conferences. As part of these activities, informal and formal discussion sessions were organized to provide increased exchange of inf ormation among scientists f rco various disciplines.

JACILITIES DEVELOPMENT: Designed, constructed, and directed the research programs of freshwater and estuarine laboratories.

Facilities have featured static and ficw-through capabilities designed for studies of acute toxicity, temperature pref erence, avoicance, thermal toxicity, and other chronic ef f ects.

12kCATI0h:

Ph.D. (behavioral toxicology), University of Maryland, College Park, Maryland 1975 M.S. (fisheries biology), University of Haryland, College Park, Paryland 1973 3.S. (zoolcgy), University of Maryland, College Park, Maryland 1970

Y, ECCLCGiCAL ANALYSTS. INC.

y James A. Fava /page 4 PREVIOUS EXPERIENCE:

ECOLOGICAL ANALYSIS, INC., Baltimore, Md.

Manager, Environmental Toxicology Services 1960-19b1 ECOLOGICAL ANALYSTS, INC., Baltimore, Md.

Scientist. Environmental Toxicology and Chemistry Group 1977-1960 ICBIHY0 LOGICAL ASSOCIATES, INC., Middletown, Del.

Senior Research Biologist 1975-1977 UNIVERSITY OF hARYLAhD CENTER FOR ENVIROUNEhTAL AhD ESTUARINE STUDIES, College Park, Md.

Faculty Research Assistant and Research Graduate Assistant 1970-1975 TRIDENT ENGINEERING ASSOCIATES, INC.

Research Associate 1973-1974 NATIONAL OCEAh1C AND ATEOSPEERIC AEMIh1STRATION Assistant Survey Technician 1967-1966 PROFESSIONAL ACTIVITIES:

Society of Environmental Toxicology and Chemistry American Association for the Advancement of Science The American Fisheries Society American Society for Testing and Materials Atlantic Estuarine Research Society Vater Pollution Control Federatica Phi Sigma Society C0hhITTEES:

Society of Environmental Toxicology and Chemistry -

Publication Ccmmittee i

PUBLICATIOhS AND PRESENTAT10hS:

l 1

Gift, J.J., J.A. Fava, A.F. Maciorowski, and W.L. McCulloch. 1963.

The use and implication of sewage sludge toxicity tests in ocean disposal management divisions. Ocean Waste Management:

Policy and Strategies.

2-6 May 1963. University of Rhode Island.

Gift, J.J., J. A. Fava, A.F. hacierowski, and W.L. McCulloch. 1963.

Marine organism sewage sludge toxicity tests and their use in making ocean disposal management decisions. Presented at the Fourth International Ocean Disposal Symposium. Plymouth, England. April 1963.

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ECCLCGCAL ANALYSTS. INC.

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Jame's A. Fava /page' 5 r

~Cumbie, P.M...J.A. Yava, P.D. Movery, and'G. Seegert. 19b3.

Some limitations of the naticnal guidelines final acute value calculacion. Presented at the Seventh ASTH Symposium on Aquatic Toxicology. Milyaukee. Wis.

17-19 April.

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~ Fava, J.A., G. Seegert, and'P.h. Cumbie. 19b3. Assessment of data quality used to derive national crileria' ~with suggested data evaluation criteria. Presented it the Seventh, ASIM Symposium on Aqua tic Tosicology. Milwaukieh Wis.

17-i? April.

3,,-,.;-

Seegert, G., J. A.'

Fav'a,' and P.M. Cumbi e, 1963. Analyses of the underlying distribution of the national database. Pre-sented at the Seventh ASTM Symposium on Aquatic Toxicology.

Milwaukee, Wis. 17-19 April.

C Fava, J. A., J.J. Gif t, A.F. hacierowski, W.L. McCulloch, and B.J. Reisinger, II.

1963. An integrated ccmparison of total and liquid phase sewage sludge chemical constituency and marine organisms acute toxicity. Presented at the Seventh ASTH Sycposium on Aquatic Toxicology. Mi;waukee,Wis.

17-19 April 19S3.

Macierowski, A.F., J. A. Fava, and W.L. McCulloch. 1963. An

~

approach to sewage sludge bioaccumulation potential tr'sts.

Presented at th'e Seventa ASTH Syuposium on Aquatic Tciicology.

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C Milwaukee, Wis. 17-19 April 1963., '

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Mowery, P.D..-J. A. F,ava, and L.W./Claflin. 1963. A statistical test proceduzc.for ef fluent toxicity screening. Presen_ted at the Seven:b ASTH Symposium on Aquatic Toxicology. Milwaukee, W is. 17-19 April 1963.

Fava, J. A. and G. Seegert.' IVB3./.Facters to be considered in the design of ' chlorine toxicological res'earch, in Proceedings of

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the Fourth Water Chlorinatica Conferences, Asilcmar Conference

/

Center, Ib-2L 0ctober 1961.

Davis, W.I. and J. Ah Fava. 1963. Interactica of aquatic ecosystem components with chierination: An overview, in Proceedings of the Fourth Water Chlerination Conf erence, Asilcmar Conference Center,16-23 October 1961.

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w ECCLOGICAL ANALYST 5. INC.

y James A. Fava /page 6 Fava, J.A.

1962. Biomonitoring: Practical Considerations Relevant to NPDES Permits. Presented at the hPDES Workshop Sponsored by the Utility Water Act Group (UWAG), Atlanta, 23-24 June.

Gif t, J.J., J. A. Fava, G.J. Lauer, H. Plugge, and W.J. Rue. 1962.

Briefing o'n Present Status of Ocean Disposal cf Sewage Sludge -

Site Designation Rulemaking and Special Permit Application -

for the City of New York.

Presented at meeting of the U.S.

House of Representatives Committee of Merchant harine and Fisheries, Washington, D.C., 2 April.

Fava, J.A., J.J. Gift, W.J. Rue, and H. Plugge. 1962. Ocean Dumping Assessment Issues.

Presented at Meaningful Measures of Marine Po11utica Eff ects, Pensacola, Fla., 26-29 April.

Fava, J.A., W.J. Rue, Jr., and R.h. Kapp.

1962. Factors necessary to establish site-specific water quality standards, in Proceedings of The Fertilizer Institute's Environmental Symposiuu '82, San Antonio, Tez.

Fava, J. A., R.M. Kapp, J.J. Gif t, C.R. Flynn, and J.A. DelPup.

1962. A biological risk assessment approach to establish water quality-based effluent limits, in Aquatic Toxicology and Hazard Assessment (J.G. Pearson, R.b. Foster, and k.E. Bishop, eds.), pp. 341-355. Presented at the Fifth Conference, ASTM STP 766, American Society for Testing and

. Materials.

Fava, J.A., R.M. Kapp, and W.J. Rue.

1961. Comprehensive Evalu-

. ation of Ammonia Toxicity in Site-Specific Environmental Assessments. Presented at International Society of Petroleum Industry Biologists Fourth Annual Meeting, 22-25 September.

Rue, W.J., Jr. and J. A. Fava.

1961. The relative contribution of point sources of ammonia to surface waters, in Industrial Waste--Proceedings of the 13th Mid-Atlantic Conference (C.P. Huang, ed. ), pp. 608-617.

Brungs, W. A., W.P. Davis, J. A. Fava, D.H. Hamil ton, J.S. hattice,

R.J. Ruane, and R. B. Samworth. 1960. Reaction products and ecological ef fects of aqueous chlorination. Chapter 97, in Proceedings, Third Conference on Water Chicrinaticn: Env iron-mental Impact and Health Effects. Ann Arbor Science, Ann Arbor, hich.

ECCLCGICAL ANALYSTS INC.

ys James A. Fava /page 7 Fava, J.

1960. Environmental Descriptors Data Base. Presented at Electric Power Research Institute Workshop entitled," Engineer-ing and Environmental Data Bases for the Electric Utility Industry: What We Bave and How to Use It.," Washington, D.C.,

14-15 October 1980.

Fava, J.A., R.h. Kapp, L. Claflin, J.J. Gift, S. Fullerton, L. Milask, K. Bewitt, and V. Spence. 1960. Development of EPRI's Cooling Water Data Base and Analysis System. Presented at Poster Session, Fif th National Workshop on Entrainment and Impingement, San Francisco, 5-7 May 1960.

Fava, J.A., R.M. Kapp, and J.A. DelPup.

19b0. Environmental fac-tors affecting the toxicity of free cyanice to fish. Presented at Meeting of the Northeast Division of The American Fisheries Society, Ellenville, N.Y., 27-30 April 1950. (Abstract).

Fava, J.A., R.M. Kapp, and J.A. DelPup.

1960. An approach to improve water quality criteria, in Proceedings of the AhSA Conf erence on Water Quality Criteria.

Gray, R. and J. Fava. 1960. Can Studies of Organism Behavior Provide Useful Data for Environmental Assessment. Presented at Nat. Am. Fish. Soc. meeting, Louisville, Ky., September 1960.

(Abstract).

DeGraeve, G.M., W.J. Blogoslawski, W.A. Brungs, J.A. Fava, B.J. Finlayson, J.P. Frost, T.h. Krischan, J.W. heldrim, D.T. Michaud, R.E. 3akatani, and G.L. Seegert. 1979.

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Chlcrine, in A Review of the EPA Red Book: Quality Criteria for Water (R.V. Thurston, R.C. Russo, U.h. Fetterolf, Jr.,

T.A. Edsall, and Y.M. harker, Jr., eds.), pp. 67-75, Water Quality Section. American Fisheries Society, Bethesda, Md.

l Fav a, J.

1979. Developing an Expanded Cooling System Data Base to Include Environmental Descriptors. EPRI RP 1489-1. Proceed-ings of Acvisory Workshop on Aquatic Cooling System Effects.

Airle House, Va.

Fava, J.

1979. Behavioral toxicology:

Its use, in hazardous substance evaluation, in Proceedings of the 1979 National Conference on Hazardous haterial Risk Assessment, Disposal and Management, pp. 65-72. Miami Eeach, Fla.

w ECCLOGICAL ANALYSTS. INC.

James A. Fava /page 8 Willingham, W.T., J.E. Colt, J. A. Fava, B. A. Hillaby, C.L. Bo, M. Katz, R.C. Russo, D.L. Swanson, and R.V. Thurston.

1979.

Ammonia, in A Review of the EPA Red Book: Quality Criteria for Water (R.V. Thurston, R.C. Russo, C.h. Fetterolf, Jr.,

T. A. Edsall, and Y.h. Barker, Jr., eds.), pp. 6-18, Water Quality Section. American Fisheries Society, Bethesda, hd.

Fava, J., B. Hougart, and J. Tompkins. 1976. Will the birds return Maryland Conservationist 54(1):24-27.

Fava, J. and D. Thomas. 1976. Use of chlorine to control OTEC biofouling. Ocean Eng. 5:269-288.

Fava, J. and C. Tsai. 1976. Delayed behavicral repsonses of the blacknose dace, Rhinichthys atratulus, to chicramines and free chicrine. Comp. Biochem. Physiol. 60(2):123.

Fava, J. and J. heldrim. 1977. Avoidance and tolerance of Atlantic silverside and white perch to chlcrine. Presented at the hat.

Amer. Fish. Soc. Meeting, Vancouver, B.C.,16 September 1977.

Fava, J. and J.W. helcrim. 1977. Responses and tolerance of Atlantic silverside to chlcrine. Presented at the Northeast Fish and Wildlif e Conf erence, Boston, Mass., 3-6 April 1977.

Fava, J. and D. Thomas. 1977. Use of chlorine for antifouling on Ocean Thermal Energy Conversica (OTEC) power plants, ja Pro-ceedings of Ocean Thermal Energy Conversion (OTEC) Eiofouling and Corrosica Symposium (R.H. Gray, ed.), pp. 107-125.

Seattle.

Fava, J. A. and D.L. Thomas. 1977. Use of Chicrine for Antifouling cn Ocean Thermal Energy Conversion (OTEC) Power Plants.

Subtask Order 202-3.

45 pp.

Melcrim, J.W. and J. Fava. 1977. Behavicral responses of estuarine fishes to chierine. Chesapeake Sci. 18(1):154-157.

Fava, J. and C. Tsai. 1976. Tuberculation of the pearl dace, Semotilus marcinata (Cope). Copeia 2:370-37A.

Fava, J. and C. Tsai. 1976.

Immediate behavicral reactions of blacknose dace, Rhinichchys atratulus (Bermann), to domestic sewage and its toxic constituents. Trans. Am. Fish. Soc.

105(3):430-441.

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James A. Fava /page 9 Meldrim, J. and J. Fava. 1976. Behavioral avoidance responses of estuarine fishes to chlorine. Presented at the Chlorine Workshop, Chesapeake Biological Laboratory, Univ. Maryland, Solomons, hd., 25-28 March 197 6.

Fava, J.

1975. The behavioral responses of blacknose dace Rhinichthys atratulus (Bermann) to domestic sewage effluents and their toxic constituents.

Ph.D. dissertation.

Univ. Md.,

College Park.

Tsai, C. and J. Fava, 1975. Chlorinated Sewage Effluents and Avoidance Reaction of Stream Fish. Technical Report No. 35.

Water Resources Research Center. 59 pp.

Fava, J. and C. Tsai. 1974. The life history of the pearl dace, Secotilus carzinata, in Maryland. Chesapeake Sci.

15(3):159-162.

Tsai, C. and J. Fava. 1974. The response of blacknose dace to chicricated sewage effluents. Presented at the 1974 Northeast Fish and Wildlif e Conf erence, McAfee, N.J., 26-28 February 1974.

Tsai, C. and J. Fava. 1974. Chlorinated Sewage Effluents and Avoidance Reaction of Stream Fish. Tenth Annual Report.

Water Resources Research Center.

Univ. hd., College Park.

Fava, J.

1973. The habitat, distributica and lif e history of the pearl dace, Semotilus mgIrinata (Cope), in Maryland and adja-cent states. Masterfs thesis.

Univ. hd., College Park.

Tsai, C. and J. Fava. 1973. Chicrinated Sewage Effluents and Avoidance Reaction of Stream Fish. binth Annual Report.

Water Resources Research Center.

Univ. Md., College Park.

Tsai, C. and J. Fava. 1972. Chicrinated Sewage Effluents and Avoidance Reaction of Strean Fish. Eighth Annual Report.

Water Resources Research Center.

Univ. hd., College Parx.

Macierovski, A.F., W.L. McCulloch, and J.A. Fava. A comparative evaluation of LC50 estimation procedures with marine organism sewage sludge and deference toxicant tests.

Submitted for consideration of presentation at the Fourth Annual heeting of the Society of Environmental Toxicology and Chemistry, Arlington, Va.

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j James A. Fava /page 10 Fava, J. A., A.F. haciorowski, W.L. McCulloch, J.J. Gif t, R.J. Reisinger, J. Edinger, and E. Buchak. A multidisci-plinary approach to sewage sludge ocean disposal assessment.

Accepted for presentation at the Fourth Annual heeting of the Society of Environmental Toxicology and Chemistry, Arlington, Va.

SELECTED REPORTS AND CONSULTING EXPERIENCE:

4 American Petroleum Institute--

Analyzed the literature on the source, chemistry, fate, toxicity (aquatic and human health), and detectica of ammonia in surface waters.

Prepared a critique of the literature on the source, chem-istry, fate, toxicity, and detection of chromium in surf ace waters.

Conducted a survey and analysis of the existing and proposed biomonitoring test procedures relevant to the petroleum industry.

Evaluated the appropriateness of proposed ef fluent toxicity testing procedures relevant to their use with the petroleum industry.

Evaluated an approach to conduct use attainability analyses for surface waters relevant to proposed water quality i-standard regulations.

l Assisted in the development of technical comments on

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Protocols to derive site-specific water quality criteria.

Provided technical support on the use of biomonitoring including effluent toxicity tests and ecological surveys for

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use in wasteload allocation and total caily maxinium ~. c a d s.

Participated in a survey of national and state groundwater quality standards and aquifer classificatica systems.

Directed technical literature reviews on the source, chemistry, toxicity (aquatic, human heal *.h) of cadmium and vanadium.

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9 James A. Fava /page 11 Evaluated Michigan's proposed Rule 57 to control the release of toxic substances in Michigan surface waters.

Interacted with State technical staf f relevant to the technical suggestions.

Decartment of Enerzv--Evaluated the potential use of chlorine to control biofouling at OTEC plants.

Electric Power Research Institute--Evaluated the feasibility of integrating diverse environmental data into a numerical computerized database system to allcw use of existing inf ormation for future applications, such as siting.

The Fertilizer Institute--Analyzed the literature on the aquatic toxicity, fate, and sources of ammonia in surface waters.

General Public Utilities Corcoration--Prepared comments and testimony on the potential biological impact of chlorinated discharges frca a power generating statica on the Susquehann Riv er.

The Inter-Industry Cyanide Groue--Conducted an overview and analysis of the literature on the chemistry, fate, toxicity, and detection of cyanide in surface waters.

Keystone Bituminous Coal Association--Conducted critique and pre-pared comments and testimony on State of Pennsylvania proposed revisions of water quality criteria for ammenia, cyanide, irca, phenol, and total dissolved solids as influenced by several stream flow scenarios.

Michi2an Coalition for clean Water--Evaluated the use of aquatic toxicological principals relevant to their use in Michigaq's draf t Rule 57.

Minnesota Industrv Greue--Conducted technical critique and prepared comments on Minnesata Pollution Control Agency's Proposco Wcter Quality Standards for ammonia and total residual chlori:.e.

New York City Deeartment of Environmental Protection--

Assessed existing scientific and technical information and data to address the appropriateness for designating three sites (12-mile, 65-mile, and 106-mile) tor ocean disposal of sewage sludge.

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g James A. Fava /page 12 Evaluated draft amendments to the Ocean Dumping Act with respect to scientific framework to provide adequate protection to man and the environment.

Evaluated L'ue exi. sting chemical, physical, toxicological, and field data as part of a permitting process to consider sludge disposal at various sites.

Penn'vivania Power and Light Comoany--Conducted technical review and s

prepared comments on State of Pennsylvania proposed revisicus of water quality standards.

Public Service of New Jersev--Investigated the behavioral responses of estuarine and marine organisms to determine toxicity of chicrine and tenperature.

Utility Water Act Groue ( UWAG)--

Conducted technical critique and prepared cccments on U.S.

EPA Proposed Water Quality Criteria for the priority pollu-tants cadmium, copper, nickel, zinc, arsenic, chlorophenols, polynuclear aromatic hydrocarbons, chlorof orm, asbestos, chromium, and mercury.

Conducted technical critique and prepared comments on U.S.

EPA Draf t Guidelines f or deriving Water Quality Criteria for the protection of aquatic life.

Conducted technical critique and prepared commects on U.S.

EPA's proposed sction to list ammonia as a toxic pollutant.

Conducted technical critique and prepared Bioassay Evalu-ation Criteria for the review of the appropriateness of chlorine toxicity literature for use in deriving water quality criteria.

Evaluated the precision and variability associated s:tn the proposed preliminary ef fluent toxicity screening test.

Prepared critique of U.S. EPA's proposed effluent toxicity testing protocols relevant to their valicity and appropri-ateness for use in the second round of NPLES permits.

Participated in a joint EPA / industry meeting (June 1981) on the appropriateness of using bicmonitoring during the second round of NPDES renewals.

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4 James A. Fava /page 13 Evaluated Draf t Ambient Water Quality Criteria document on chlorine, including assessment of completeness, adequacy, and appropriateness of toxicological data for use in setting water quality criteria.

Critiqued an approach to derive site-specific water quality criteria relevant to the proposed water quality standarc regulations.

Performed a sensitivity analysis on the use of procedures to calculate the water quality criterion's Final Acute Value (FAV). This was part of an evaluation of the usefulness of the l' National Guidelines for deriving water quality criteria f or the protection of aquatic life" to derive site-specific criteria.

Reviewed internal craf t versions of EPA's 1963 criteria documents for arsenic, cadmium, chronium, copper, cyanice, lead, and mercury.

Directed an effort to address variability issues associated with EPA's naticnal acute toxicity databases for 23 chemi-cals with the goal of developing a method to calculate the final acute values.

Water Resources Research Center--Studied the behavioral responses of freshwater fish to domestic sewage ef fluents and their toxic constituents--free chlorine, chicramines, and ammonia.

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ECCLOGICAL ANALYSTS. INC.

HANS PLUGGE Senior Scientist / Health Sciences and Risk Assesscent Mr. Plugge is the Senior Scientist for the Health Sciences and Risk Assessment group within the Environmental Toxicology division. As such, he is responsible for coordinating corporate services in risk assessment, risk perception, environmental and occupational health service _s, pollu-tion monitoring systems and industrial hygiene and safety engineering.

In addition, he provides expertise in toxicodynamics of xenobiotics in mammalian and other biota as well as structure-activity relations.

Mr. Flugge is also the corporate Saf ety Manager.

EX?!RIENCE:

OCCU?ATIONAL AND ENVIRONME' ITAL HEALTH: Managed the' development of a dozen short health effect assessment docu=ents as part of.a =ulti-media sewage sludge risk assessment. Managed and developed the EPA Drinking Water Criteria Document on carbon tetrachloride. Managed and developed a review of nasal encogens for C?SC that involved evaluation of 1,100 clinical and ani=al reports. Developed the mass balance for arsenic in the :ine industry. Reviewed nu=erous occupational health and safety studies in developing several health effects support documents on ITC chemicals list under TSCA for U.S.

EPA. Managed the development of eight environmental and health effect chemical profiles for U.S. EPA. Developed two special hazard reviews for NIOSH. Developed carbon tetrachloride SNARL for EPA.

Was safety officer in several academic chemistry and toxicology laboratories. Designed and manages EA's occupational safety and health program. Serves on the Corporate Committee on Occupational Saf ety and Health. Reviewed benzene, toluene, and xylene SNARLS as part of a gasoline derived ground-water contamination assesscents.

RISK ASSESSMENT: Pioneered development of =ulti=edia, multichemical risk assessment methodologies for evaluation of relative cost-effectiveness of engineering alternatives in controlling environ-mental releases and health risks. Developed =ethodology for uniform expression of health effect probabilities using perceived risk as a nor=alizing f actor. Perf ormed a 12 (15) chemical 3-=edia risk assessment of long-ters sewage sludge disposal alternatives.3r the City of New York: incineration vs. ocean disposal. Developed methodology for evaluating cost-effectiveness of SUPERFUND Hazardous Waste Site Re=edial Engineering Alternatives.

Performed Picillo SUPERFUND site cost-eff ectiveness assesscent of ground-water with-

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drawal and treatment alternatives. Managed a large-scale survey on the differencial perception of diseases by several socioeconomic groups in the Salti= ore SMSA. Performed ha:ard assessments of ?AH soil contoninatien at two separate construction redevelopment sites.

Present work in progress includes the development of a cost-benefit

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Eans Flugge/page 2

' risk assessment methodelogy for biofouling control alternatives in the utility industry and a cost-effectiveness assessment of remedial engineering alternatives at the Keefe Environmental Services SUPERFUND site.

REGULATORY REVIKK: Performed regulatory review of federal legis-lation, criteria documents and other publications. Participated in the review of several' State regulations regarding water quality and waste management.

AIR SCIENCES: Managed the design, construction, and installation of a mobile and automated air quality system for volatile organs.

Designed an automated air quality monitoring system for a hazardous vaste site. Managed the development of air quality data using UNAMAP for sewage sludge incinerators.

MAMMALIAN T0XICOLOGT: Conducted 'stu' dies on the hepatic effects of chlorinated ethylenes and chloroprene. Performed studies on the inhalation toxicity of chloroprene using pulmonary lavage. Con-ducted acute toxicity studies on NIAI-ESN, a polyurethane catalyst, resulting in,the identification of the causative agent of a clinical syndrome in exposed workers. Conducted a long-term feeding study of chloroacetaldehyde in rabbits. Conducted toxicity study on the interaction of PCBs with 1,1-dichloroethylene. Critically evaluated thousands of toxicology ctudies, both animal and hanan, on a variety of compounds, including sliphatic and aromatic hydrocarbons (chlori-nated benzenes, biphenyls, terphenyls and naphthalenes, halogenated mechanes, echanes and ethylenes) and organic nitrocompounds.

AOUATIC T0XICOLOGT: Developed a review of bioaccumulation of

$ xenobiotics in New York Sight biota. Reviewed marine impact data for site designations and special pernit applications for marine sewage sludge disposal. Reviewed experimental design and result of laboratory bicaccumulation data.

ANALT"ICAL/ ENVIRONMENTAL CHEMISTRY:

Extensive experience in the use of GC, GC/MS, and TLC in both quantitative and qualitative identifi-cation of chemical compounds, including analysis of complex =1xtures and environmental samples. Designed automated air monitoring system for remote sampling on hazardous waste sites. Responsible for analytical procedures and equipment start-up for two inhalation

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coxicology facilities. Experienced in the use of other analytical techniques such as UV-VIS fluoro, IR, NMR, and Raman spectroscopy.

Managed the design, engineering, and construction of a mobile

, automated air monitoring sfsten for measuring organics in air.

Designed and constructed automated dynamic gas dilution system.

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Hans Plugge/page 3 CARCINOGENESIS: Quantified carcinogenic risks associated with environmental and occupational levels of exposure to chemical car-cinog ens. krote a short evaluation of techniques in quantitative risk assessment of carcinogens. Evaluated a large number of.

carcinogenesis studies, including NCI bicassays, for validity, reliability of results, and quantification of carcinogenic risk.

Contributed a short overview of methods for quantitation of oncogenic risk for an Army standards development report.

MUTAGINESIS: Evaluated a large number of mutagenesis studies, including Salmonella (Ames), Drosophila, yeasts, dominant lethal, and cytogenetic assays. Developed critical evaluation criteria for Salmonella assay with respect to dose-response curves and quantita-tive corrections for cytotoxicity. Was involved in the start-up of a mutagenicity testing laboratory, including marketing efforts and steering committee. Contributed and evaluated mutagenicity sections of major regulatory support documents.

TERATOLOGY AND REPRODUCTIVE T0XICOLOGY: Conducted research in behavioral teratology on the effect of prenatal exposure to indus-crial solvents on operant behavior. Critically evaluated caracology and reproductive toxicology studies with specific emphasis on statistics, " biological significance," and confounding factors.

Contributed teratology and reproductive toxicology sections for major regulatory support documents. Postulated =echanisms of action for juvenile nasopharyngeal carcinoma.

T0XIC0 DYNAMICS:

Extensive experience in performing and evaluating metabolism studies. Made special study of the quantitative inter-actions of cytochrome P-450 components and their ef fect on the metabolism of compounds such as PC3s and chlorinated ethylenes.

Evaluated and wrote metabolism sections for regulatory support documents. Used metabolism data to determine =echanism of action of specific chemicals.

STRUCTURE-ACT!vtTY CORRELATIONS: Compared structural data via matrix analysis to postulate possible common =ecabolic pathw2vs.

Used metabolism data to identify similar mechanisms 2nd inter-mediates"of biocransformation. Used literature and theoretical considerations on mechanisms of biocransformation to postulate effects of untested chemicals. Specific emphasis on the use of structure-activity correlations in the evaluation of carcinogenic and mutagenic properties of chemicals.

ECCLOGICAL ANALYSTS, INC.

9 Hans Plugge/page 4 INHALATION T0XICOLOGY: Conducted static and dynamic inhalation exposures of animals (rodents) to a variety of organic compounds including chloroprene, vinyl chloride, dichloroethylene, toluene, trichloroethylene, and acetone. Designed and constructed a static inhalation system for the evaluation of the behavioral toxicology of industrisl solvents. Performed toxic dynamic studies of inhalation exposure to chlorinated hydrocarbons.

NEdROT0XICOLOGY: Conducted experiments using operant behavior on the behavioral toxicology mad ceratology of industrial solvents following low-level inhalation exposures. Established dose-response and long-term inhalation criteria for industrial inhalants.

Authored neurotoxicology sections for regulatory support documents.

Managed the design, engineering, and construction of a mobile automated air monitoring system for measuring org- '--

Designed and constructed automated dynamic gas dilution system.

INFORMATION MANAGEMENT: Designed online Automated Literature Manag ement System for EA.

Designed and conducted literature searches on several automated databases. Developed reference sections and methodologies for several assessment and review documents.

IDUCAT!ON:

S.M. (physiology, toxicology),

1979 Department of Physiology Earvard School of Public Health Boston, Massachusetts Y

M.Sc. (biochemistry),

1977 Department of Chemistry University of Guelph Guelph, Ontario, Canada Kandidaats in Chemistry (equivalent of honors 3.Sc.),

1975 Subfaculty of Chemistry, Taculty of Science and Mathematics, University of Amsterdan Amsterdam, The Netherlands FORIIGN LANGUAGES:

Dutch, Ger=an, and French.

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Hans Plugge/page 5 PREVIOUS EXPERIENCE:

ECOLOGICAL ANALYSTS, INC., Sparks, Maryland, Scientist, Environmental Toxicology 1981-1983 4

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JR3 ASSOCIATES, INC., McLean, Virginia,

Staff Toxicologist 1979-1981 HOWARD UNIVERSITY, Dept. of Human Nutrition and Food, Washington, D.C., Gusst Lecturer Fall 1980, 1981 HARVARD UNIVERSITY MEDICAL SCHOOL, Laboratory of Psychobiology, Boston, Mass.,

Senior Research Assistant 1978-1979 HARVARD UNIVERSITY, Cambridge, Mass.,

Guest Lecturer Spring 1978, 1979 HARVARD UNIVERSITY SCHOOL OF PUBLIC HEALTH, Laboratory of. Toxicology, Boston, Mass.,

Research Assistant 1977-1978 UNIVERSITY CF GUELPR, Department of Chemistry, Guelph, Ontario, Canada, 1

Research Assistant 1975-1977 Teaching Assistant 1975-1977

?ROFESSIONAL ACTIVITIES:

Air Pollution Control Association American Association for the Advancement of Science American Chemical Society American College of Toxicology New York Academy of Sciences Society for Risk Analysis Society of Environmental Toxicology and Chemistry Board Member of Chesapeake-Potomac Chapter of the Society of Environmental Toxicology and Chemistry Conferences /7erkshops:

Symposium on Ocean Waste Management:

Policies and Strategies, University of Rhode Island, 2-6 May 1983 Fourth International Ocean Disposal Symposium, Plymouth, Devon, England, 11-15 April 1983 Workshop on Low Probability /High Consequence Events, Rossyln, VA, June 1982 Meaningful Measures of Marine ?ollution Effects,

?ensacola, Fla., 25-29 April 1982 Design of Sevage Sludge Incineration Systens, The Continuing Education Institute, Columbia, Md., 22-23 April 1982

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Hans Plugge/page 6 International Workshop on the Analysis of Actual vs. Perceived Risks, National Academy of Sciences, Washington, D.C., 1-3 June 1981 Malformations in Developmental Biology, FAES Graduate School, National Institutes of Health, Bethesda, Maryland 1980-1981 Ultrastructural Pathology, FAES Graduate School, National Institutes of Health, Sechesda, Md. - 1980-1981 First Annual Conference on Genetic Toxicology and Cytogenetics, Brookhaven National Laboratory, Upton, New York, 25-29 February 1980 Chemical Carcinogenies--Occupational and Environmental, Mt. Sinai School of Medicine, New York, N.Y., 21-23 June 1978 Health Effects of Halogenated Aromatic Hydro-carbons, New York Academy of Sciences, New York, N.Y., 24-27 June 1978 PU3LICATIONS AND ?RESENTATIONS:

Plugge, H.

1983. Comparative Risk Assess =ent.

Presented at " Air, Land, and Sea: Which is the best for the disposal of sewage sludge " 28 July 1983. SCCWRP Laboratories, Long Beach, Calif.

Hamner, S. and H. Plugge. 1983. An automated integrated capillary /

. packaged chromatographic system for mobile ambient air moni-toring of volatile organics. Presented at the Third Annual National Symposium on Recent Advances in the Measurement of Pollutants from Ambient Air and Stationary Sources. Research Triangle Park, 3-5 May.

Plugge, H.,

3. Rubin, and J.J. Gift.

1983. Multimedia risk assessment of sewage sludge disposal alternatives I Generic Methodology. Presented at symposium on Ocean Waste Management:

Policies and Strategies. Cniversity of Rhode Island, 2-6 May.

Plugge, H., P.A. Cruse, C. Beisser, J. Paull, and 3. Rubin.

1983. Multimedia Risk Assessment of sewage sludge disposal alternatives II.

Ocean disposal versus incineration -

Quantitative Risk Estimates. Presented at Symposium on Ocean Waste Management: Policies and Strategies, University of Rhode Island, 2-6 May.

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y o Hans Plugge/page 7 Rue, W.J., and H. Flugge. 1983. Analyses and Interpretation of New York Bight Bioaccumulation Data. Presented at Symposium on Ocean Waste Management: Policies and Strategies. University of Rhode Island, 2-6 May 1983.

Hamner S., and H. Plugge. 1983. An Automated Air Monitoring System for Volatile Organics. Presented at MASS-APCA Technical Conference on: RCRA and the Clean Air Act:

Interaction and Conflicts. Wilmington, Del., 18-19 April.

Plugge, H. and 3. Rubin. 1983. Comparative Hu=an Health Cost-Effectiveness Risk Assessment of Air Pollution Control Options. Presented at MASS-APCA Technical conference on:

RCRA and the Clean Air Act: Interactions and Conflicts.

Wilmington, Del., 18-19 April.

Plugge, H.

1983. Issues in Human Risk Assessment, Chapter 105 JIL Water Chlorination--Environmental Impact Health Effects, Vol. 4 Ann Arbor Science, Ann Arbor, Mich. (R.L. Jolpy, M.A. 3 rungs, J.A. Cotruvo, R.S. Cumming, J.S. Mattice,

V.A. Jacobs, eds.).

Plugge, H., W.J. Rue, and P.D. Mowery. 1983. Analyses and Interpretation of New York Bight Bioaccumulation Data.

Presented at Fourth International Ocean Disposal Symposium, Plymouth, Deven, England, 11-15 April 1983.

Plugge, H. and 3. Rubin. 1982. An algorithm for minimizing risk from hazardous vaste incineration. Presented at the Workshop on Low Probability /High Consequence Events, Rossyln, Va.

June.

Plugge, H., W.J. Ru,e, and P.D. Movery. 1982. Interpretation of Marine Bioaccumulation Data. Presented at Meaningful Measures of Marine Pollution Effects, Pensacola, Fla., 26-29 April.

Fava, J.A., J.J. Gift, W.J. Rue, and H. Plugge.

1982. Ocean Dumping Assessment Issues. Presented at Meaningful Measures of Marine Pollution Ef f ects, Pensacola, Fla., 26-29 Apri..

Gift, J.J., J. A. Tava, G.J. Lauer, H. Plugg e, and W.J. Rue. 1982.

3riefing on Present Status of Ocean Disposal of Sewage Sludge-Site Designation Rulemaking and Special Permit Application for the City of New York. Presented at meeting of Committee on Merchant Marine and Fisheries, U.S. House of Representatives, Washington, D.C., 26 March.

ECCLCGCAL ANALYSTS. INC.

Hans Plugge/page 8 Plugge, H. and G. Petrazzuolo. 1981. Issues in Human Risk Assessment II.

Presented at the Annual Meeting of the Society of Environmental Toxicology and Chemistry, Arlington, Va.,

22-25 November.

Plugge, H.

1981. Issues in Human Risk Assessment. Presented at Fourth Conference on Water Chlorination, Pacific Grove, Calif.,

18-23 October.

Jaeger, R.J., H. Plugge, and S. Szabo. 1980. Acute bladder toxi-city of a polyurethane foam catalyst, NIAX catalyst ES N,

containing dimethylaminoproprionitrile.

J. Env. Path. Tox.

4:555-562.

Plugge, H. and G. Petrazzuolo. 1980. Nasal Oncogens--A Review.

Prepared for Consumer Produe Safety Cocmission under contract CPSC-C-79-1052.

Plugge, H. and R.J. Jaeger. 1979. Toxicology of 2-chloro-1,3-butadiene (chloroprene): acute effects in liver and lung following inhalation exposures in rats. Tox. Appl. Pharm.

50:565-572.

Plugge, H. and R.J. Jaeger. 1979. Toxicology of 2-chloro-1, 3-butadiene (chloroprene): acute effects in liver and lung following inhalation exposures in rats. Presented at Meeting of the Society of Toxicology in New Orleans, La., March 1979.

Flugge, H.

1977. Vinyl chloride:

Its biological effects.

A review, Master's thesis.

University of Guelph.

Guelph, Ontario, Canada.

Plugge, H. and S.H. Safe. 1977. Vinyl chloride metabolism:

A review. Chemosphere 6:309-325.

Safe, S.H.,

H. Plugge, 3. Chittis, and J.F.S. Crocker. 1977.

Analysis of adjuncts used in formulatiens for the application of organophosphorus pesticides, in Proceedings of the Symposium on Fenitrochion: The Long-Term Effects of Its Use in Forest Ecosystems (J.R. Roberts, R. Greenhalgh, and W.I. Marshall, eds.).

NRCCICNRC No. 16073:51-76. National Research Council of Canada.

Safe, S.H. and H. Plugge. 1977. Analysis of an aromatic solvent used in a forest spray program. Chemosphere 6:641-451.

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Hans Plugge/page 9 SELECTED REPORTS AND CONSULTING EXPERIENCE:

American Petroleum Institute--Reviewed the human health section of the chromium monograph. Revised. State of Michigan's Rule 57 en establishment of water quality criteria. Contributed to i -

cadmium mud vanadium monographs.

City of New York--Developed methodologies for the quantitative assessment of human health risks in order to compare the differential risk associated with multimedia disposal of municipal sludge. Performed a multimedia risk assessment of municipal sludge disposal.- 3riefed congressional staff on

. issues associated with sewage sludge disposal.

Confidential Clients--Designed ccationary air monitoring system for a hazardcus waste disposal facility. Prepared an assessment of remedial action for and hazard assessment of PAH contamination 1

soil in a'already settled area. Prepared safety plans and monitoring for several hazardous waste sampling activities.

Recommended safety plans for excavation of nonsecure landfill calls.

Consumer Product Safety Commission--Managed and developed a review of nasal encogens 'oased on an extensive review of the world's literature. Disproved the widespread conviction that nasal problems result solely from inhalation of substances.

Electric Power Research Institute--Managed the development of a cost-benefit risk assessment methodology for biofouling control alterna tiv es.

EIION--Reviewed SNARLS for benzene, toluene, and xylenes. Prepared and delive, red expert testimony on health effect of benzene, toluene, and rylenes in ground water.

Haines. Lundberth and Whaler--Developed a ha:ard assessment of the health ha:ards associated with development of PAR contamination ex-industrial site.

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Marvland Decartment of Hestch and Mental Hveiene--Managed the design, engineering, and construction of an automated mobile air monitoring system including automatic calibration, packed /

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capillary gas choratography, dual detectors (FID/ electro-chemical) for each ef fluent as well as a computerized data system.

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Hans Plugge/page 10 National Institute of Occucational Safety and Health--

Developed the health effects section of special hazard reviews for the di-and trinitrotoluenes with a special emphasis on the general mechanism of action of aromatic nitro-compounds.

Developed a behavioral inhalacion toxicological facility to study the behavioral effects of industrial solvents at low concentrations, and developed dose-response relationships in behavioral toxicology.

In response to an industrial medical emergency, reviewed the literature and studied the toxicological properties of a polyurethane catalyst.

Identified a new bladder toxin in rat studies, confirming the causative agent in an occupational setting.

New Hamoshire Water ?ollution Control Commission--

Managed the sampling and analysis of the Keefe Environmental Services site lagoon (level 3).

Managed the cost-effectiveness assessment of remedial engineering alternatives at the Keefe Environmental Services site.

New York State Deoartment of Environmental Conservation--Developed safety plan and conducted safety training for site inspection of 20 sites under New York State Superfund. Performed assessment of mitre model scores for chemicals with " unknown" harards.

Rhode Island Deeartment of Environmental Manatement--Developed the methodology and perfor=ed cost-effectiveness analysis of re=e-dial engineering alternatives at Picillo SUPERFUND Site (NR15) with regard to human health, environmental, social and cost impacts.

U.S. Arev--Developed a short review of methods in quantitative encogenic risk assessment.

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