RCRA RECORDS CENTER

FACILITY JLJLJ^Lkty I D. NO. t*\ft b oo A o 8_ <jLQJj FILE LOC. A-A OTHER , • • : 1 _.

HOUSATONIC RIVER STUDY - PCDF ANALYSES OF SEDIMENT AND FISH S/WPLES

General and Background Information

In response to the Consent Order between the General Electric Company,

the United States Environmental Protection Agency (EPA) and the Massachusetts

Department of Environmental Quality Engineering (DEQE), General Electric has

been performing an extensive study of the Housatonic River since 1981.

One aspect of this study involves the analysis of fish and sediment

samples for a chemical known as Polychlorinated Dibenzofurans (PCDFs).

Specifically, three sediment samples and four fish samples from the Housatonic

River in Massachusetts and two fish samples from the Housatonic River in

Connecticut were selected for analysis. Samples with high concentrations of

PCBs were selected for analysis from the more than one thousand samples

available. By selecting the samples on this basis, a worst case scenario

would be portrayed by the PCDF analysis.

The samples selected for analysis were formally conveyed (using chain­

of-custody documentation) on September 23, 1982, from Dr. Ann Yoakum of the

nationally-recognized Stewart Laboratories (the organization that originally

collected and analyzed the samples for PCBs) to Dr. Christoffer Rappe of the

University of Umea in Sweden. Dr. Rappe and his associates were chosen to

perform the analysis for PCDFs as they clearly had the recognized inter­

national reputation in environmental samples for PCDFs. In addition, much of

the analytical methodology for performing this type of analysis was developed

as a result of Dr. Rappe's efforts and his experience in this area was

significantly stronger than all other researchers world-wide.

SDMS DocID 000213339

PAGE 2

Analysis of Sediment Samples

The analysis of the sediment samples from the Housatonic River for PCDFs

proved to be not only difficult but, after exhaustive efforts, also impossible.

The combined expertise of Dr. Rappe and his associates, along with independent

efforts by the General Electric Research and Development Laboratory in Schenec­

tady, NY, could not develop analytical techniques which were conclusive. The

specific problem which could not be overcome was when "control" samples (samples

with known contaminant concentrations) were "spiked" with isotopically labelled

PCDFs (the chemical was purposely added to the samples), subsequent analysis

could not properly recover or identify the "spiked" PCDF. This problem has

been discussed over the past two years with both the EPA and the DEQE.

As a result of the difficulties in performing the analyses, different

analytical techniques were pursued, however, these also proved to be inef­

fective. It is believed that these particular sediments have an unusual

ability to strongly bind the PCDF to themselves, therefore, not releasing them

to allow for analysis. It should be noted that although this represents a

difficult situation to the analytical chemists, it also represents a signifi­

cant finding in that to the extent that PCDFs do exist in the sediment samples,

they would be essentially immobilized in the sediment.

Studies by other researchers have indicated that the normal presence of

PCDF in sediment samples containing PCBs is at a ratio of approximately 50-200

parts per trillion of PCDF for 100 parts per million of PCB. For this reason,

we cannot conclude that PCDFs are totally absent from the sediment samples;

however, it is beyond the ability of recognized scientists to quantitatively

analyze for PCDFs in the river sediments utilizing state-of-the-art tech­

niques. General Electric, therefore, has no capability for completing the

sediment analysis portion of the PCDF study.

PAGE 3

Analysis of Fish Samples

The analysis of fish fillet samples was successful in measuring

concentrations of PCDFs in the fish samples in the parts-per-trillion (ppt)

range (one part-per-trillion equals one part PCDFs for each 1,000,000,000,000

parts fish fillet). The attached table "Levels of PCDFs in Fish Samples"

completely summarizes the results in terms of each isomer and source of

sample.

In an attempt to understand this data, General Electric has spent con­

siderable time and effort in researching PCDF literature to determine what

level or concentration constitutes a concern. Unfortunately, very little, if

any, research of significance has been developed which defines a level of

concern for PCDFs. Recent inquiries to the appropriate Federal Agencies

(including the U.S. EPA Carcinogen Assessment Group and the National

Institute of Environmental Health Sciences) have not provided any additional

insight into this problem.

Specific ongoing comments have been limited to statements made by

scientists from the Center for Disease Control (CDC) at Atlanta, GA, to the

effect that PCDF is 10 times less hazardous than Dioxin and many times more

than PCBs and "to extrapolate (available) animal data -- to someone consuming

fish that may be contaminated every so often is a big jump."*

* "Woods Pond Yields Too Hjch Chemicals" by J. Katz, Berkshire Eagle, January 21, 1981.

PAGE 4

The CDC study effort mentioned above was in comment on data generated in

1981 by the Columbia National Research Laboratory of the U.S. Fish and Wi ld ­

life Service. This included analysis of composite whole fish samples from

various sites on the Housatonic River. The data from this 1981 study is

presented in the attached report entitled "Residues of dibenzo-p-dioxins and

dibenzofurans in composite sample of whole fish from different sites on the

Housatonic River." The portion of this study which addressed the same stretch

of river as the Consent Order is presented under the heading "Woods Pond-

Yellow Perch." This 1981 analysis consisted of various composite fish samples

having total PCDFs ranging from 8.3 to 2.50 parts-per-trillion, with an

average analysis of 408 ppt.

As presented in the Rappe Report, the analysis of fillet samples yielded

total PCDF concentrations between 22.6 ppt and 187 ppt, averaging 110.8 ppt.

Although it is difficult to compare the limited amounts of data between

the studies performed in 1981 and 1983, it is nevertheless of interest to

note that the average PCDF concentration decreased between the 1981 study,

408 ppt (0.000408 parts per million) and 1983 study, 110.8 ppt (0.0001108

parts per million).

Independent studies have also been performed on fish from the Hudson

River in New York. A report presenting this information entitled "PCB in

Hudson River Striped Bass, 1984" is attached. Of interest in the Hudson

River Study are the results of analysis for a specific type of PCDF (referred

to as 2,3,7,8-tetrachlorodibenzofuran or 2,3,7,8-tetra-CDF). These analyses,

which were performed by the New York State Department of Health, detected an

average of 54 ppt in two fish in 1982 and an average of 56 ppt in four fish

in 1984. For comparison purposes, the study efforts performed by Dr. Rappe

in 1983 detected an average of 28.8 ppt 2,3,7,8-tetra-CDF in the Housatonic

River fish samples, while the high concentration detected was 60 ppt.

PAGE 5

An additional comment which should be noted from the Housatonic River

Study is that neither the Food and Drug Administration nor the New York State

Department of Health has official guidance regarding the level of PCDF which

is acceptable in fish for human consumption.

Conclusions

1. PCDFs may exist in sediment samples from the Housatonic River; how­

ever, it is impossible to quantitatively analyze for them.

2. Fish analyses detected PCDF concentrations in the parts per trillion

range, at concentrations significantly less than other researchers

detected in a 1981 study effort. No existing criteria is available

with which to compare these results.

Attachments 6/20/85

TABLE 1

ANALYSIS REPORT BY DR. CHRISTOPHER RAPPE

LLVELS OF PCDFs IN FISH SAMPLES FROM THE HOUSATONIC RIVER

Sample Number C 6490 86:3

C 6491 86:4

C 6467 86:5

C 6470 86:6

C 6472 86:7

C 6475 86:8

Sample Origin Sample Speldes

CT Trout

CT Sm. Mouth Bass

MA Yellow Perch

MA Lg. Mouth Bass

MA Trout

MA Trout

Recovery Percentageof Spiked Samples

65* 86% 75* 54X 64*

PCDF Isomers

iTetra-COFs 1247/1367 1248/13462378 2367

37.1 ppt 0.7 -"­2.6 -"­29.7 -"­3.4 -"­

6.1 ppt0.5 -*­0.6 -"­3.9 -"­0.8 -"­

30.1 ppt 0.7 -"­1.0 -"­26.4 -"­1.5 -"­

21.9 ppt 0.3 -"­0.6 -"­18.8 -"­1.9 -"­

•» **

60 ppt

34.9 pp<0.l ­0.3 -" 34.0 -" 0.3 -"

t ----1249 0.7 -"­ 0.3 -"­ 0.6 -"­ 0.3 -"­ 0.3 -" -

I Penta-CDFs 12468 12368 12478 12467 12378/1234812367 23478 23467

63.4 -"­1.1 -"­8.1 -"­1.7 -"­1.6 -"­10.8 -"­0.6 -"­38.8 -"­0.7 -"­

13.1 -"­0.5 -"­1.1 -"­0.5 -"­0.7 -"­1.8 -"­_.

8.2 -"­0.3 -"­

21.0 -"­1.5 -"­3,0 -"­0.8 -"­0.4 ­M -4.5 -"­..

10.6 -"­0.2 -"­

78.6 -"­0.4 ­H -3.2 -"­0.6 -"­0.5 -"­10.3 -"­

-­63,0 -"­0.6 -"­

50 ppt

60 ppt

41.4 -" 0.7 -" 4.3 ­M

-­-­6.0 -" -­35.5 -"

0.3 -"

„

--

-

--

'E Hexa-COFs 234678 124678/134679134678 123478/123479 124689 123467

5.8 ­M -0.9 -"­0.4 -"­0.4 -"­1.1 -"­1.8 -"­1.2 -"­

1.1 -"­Tr Tr 0.3 -"­0.3 ­H -0.3 -"­Tr

2.5 -"­0.3 ­M -0.2 ­M -0.3 -"­0.6 -"­0,7 -"­0.4 -"­

8.5 -"­0.6 -"­Tr 0.3 -"­4.6 ­M ~ 1.7 -"­1.2 -"­

10 ppt

9.6 ­H 1.0 -" 0.2 -" 0.4 -" 5.4 -" 1.5 -" 1.1 -"

„

--->

--

I Hepta-COFs1234678 1234679 Octa-CDF

3,0 -"­2.2 -"­0.8 -"­2.7 ­M -

2.3 -"­1.8 -"­0.5 -"­1.1 ­M -

2.2 -"­1.7 -"­0.5 -"­1.9 -"­

2.7 -"­2.1 -"­0.6 -"­1.0 -"­

7 ppt 5 ppt 2 ppt

3.1 -" 2.7 -" 0.4 -" <0.6 -"

-» >

-Total PCOF 109.3 ppt 22,6 ppt 55.8 ppt 111.7 ppt 187 ppt 89.0 ppt

L

v>

U J- >«-' in vO K

CM c ^ xCM o w, :̂

•H o r­«j 5s rj nj wi I- O 60 u O O = U *J

1I w r~ •

1 C i< C

o r. v­0 O J=

W c OS U t41 o a

^ • U", *-• f-H f^

u (C UJ o 1/1 «J U U C

C 4) £ 41 H O 3 .41 •O

.. j (.A 4W> •̂ wv ^^

0 0 4) CM

CM vD CO u C 0 «» r: -H o •a O rH

.MJ ^^ t"' « \̂

*O w j: cj wi 3 U U (0

«H W t-( e tM NO VO O i-l CM & »H To co O

C JO Ou N O » X-^

.

41 v) n .n 10 » W 41 W X. •H 41 >•! Ui U)

4 U 3 00 o ooo o O "O C uCM CM U vO >J 41 «H a•c- o 0. U W M

O 3 o 4J )J n c a >» 4) l> : g -O JJ . . 3 tj? J= 4> d JZ *^4 •—' 0 f. R (J > O

U CM ^ •H O O >i U CS CO «1 sl >-• nj Vi CM <3 "J kO

41 I § I 4-> CM Oi l/l vO <n *! C u u

IT* 41 4-1 UiJ -H O I/I ,-t O. a. 1-1 H a 4) y a vt r-l t3

T 3 •N •4-1 (X « n., ,̂ O C6 o -r^ rt W 1J <T •» C O M ••-1 3 CS

u -H V / rt *J U) —i —l O ro .-1 •-- «J »_x -^ C W a ~j <n 1 f-4 c to 0 «) CM •0 ! s-l K W ^H |fl - •-1 4t00 CX.O oo -"g M E 41 03 )j .-( Ul .,-| r^ 4J

rt *M 6 o :.- 3 s: CM trt 4J 4)

C M jr o O •H c w> c v> ~j «: « W) • c- 4) CO o ̂ o •̂ t: «

O4-1 f- (0 C V C «rl P. a -H (*« O

o C .M •̂ c c • •* Wi •o C • W %•o -^X O O 73 N n •«! 5c c •w^ r-H «^ O «H e —< ^H

u O C 0 «w O ••H .C 0 t, 0

•o u •H CJ nj -H, *J tO pju-i CM -o •a u e • r; ^J V U O «H I O •o S-X C c •s.C X -ri «•§ ."s o O •o •o 41 <H UN U sD c rj c »—( ••-* C 41 M•o -H e41 J3 J3 O 41 e 41 M jr GC tf*'C 3•H • 41 U

41 •a c •o -o V *o rH •0 v_x c O.0

*« X c c •o •o •§0 g c0 U o .a c O »-» -1

3«fl C•a n o w •o o ••J ^K 3 -H fk ^

>^ rt T-C T3 tH _Q t> ^* ™^ -»H .-I *o w' • Vc Wl -r-( v^ X rt ti 0) J3 00 41 W••H 3 co •r* <UNO

X U PS «J (A W CO i-l •X C

s~\rH rj Xu•o « U JO I 41 "C 3 ^^ Q «*J «O

O 41 co S U N l-i • -̂( N U O C 3 C , p f «M 4* W c44 .* JD rt 5.0 M •O -H 41 oVl 4> j= 41 T3 6•O > li i w••t-l rt *O 41 • «« PS «x rt ii c in

<u fj t. U -H i C 55 41 rt 41 O

o. in u •H

Res

idu

es-

Hcu

sato

n 5 » c w « e O 41 ~H C ^M l­

T3 -H 41 4>

anoa

h i-l W X C] no 0 »H •H > C CL. C- U 41 O U (X 4J U ~4 atJ O u c 4) O

«­ E 3 > -" 3 4) -a >—i• O OJ <­ cj o !'u wC.

to • O -O O rj u I/I 1 W O O JJ VH u V) ^ AJ ! 4i U N U *O CL «iH V»

*J (U 4J

3 »- ' —t •oI­

•Ce c r-t ' »-• C C VOc

'•> c r\. v •-• •? a0 3 O O O _

PCI IM HUDSON RIVLk EiKlfrtu BASS 1984

Prepared by

Edward Born and Ron Sloan Division of Flab and Wildlife

Bureau of Environmental Protection

BACKGROUND

la 1980, the New York State Department of Environmental Conaervation (DEC) made • commitment to commercial fiahermen on the Hudson liver to review the annual PCB data prior to mid-November of each year. Thie date waa established to provide an adequate amount of time to prepare any necessary changes In the regulations regarding the closure of commercial striped bass fishing in the lower Hudson liver and to provide commercial fishermen with an adequate opportunity to purchase new nets in the event that the fishery would be opened in the subsequent year.

Commercial fishing for striped bass in the Hudson liver has been prohibited since 26 February 1976 (6NYCR1 11.4) as s consequence of elevated PCB contamination. although the average PCB level in striped baaa has declined substantially since 1976, until 1983, fish on the sverage, exceeded the now obaolete FDA tolerance limit of 5 parta per million (ppm).

In 1977, the U.S. Food and Drug Administration (FDA) proposed to lower its tolersnce level from 5 ppm to 2 ppm. The final decision by the FDA Commissioner was published in the Federal Register on May 22, 1984 effective August 20, 1984. Thus, the official FDA tolerance is now 2 ppm.

In recent years, contaminants other than PCB have been reported In striped bass from the Hudson liver. In 1982, the New York State Department of Health (DOH) reported 2,3,7,8, tetrachlorodlbenzo-p-dloxin (TCDD) at levels averaging 20 ppt (parts per trillion) for 10 fish end 2,3,7,8, tetrachlorodlbenzofuran (TCDF) at 54 ppt (2 flah). Additional striped bass analyaes reported in 1984 strengthened the eerlier results. TCDD concentrations in the four latest Hudson liver striped bass were 42 ppt, on the average, and TCDF levels averaged 56 ppt. One of the four fish from this last sampling contained 120 ppt TCDD which indicates the hasard of small sample sizes. The average of the other three fish waa 19 ppt, which is comparable with the 1982 analyses. The FDA has no tolerance levels for TCDD or TCDF, but in 1981 the FDA provided guidance to Governor Mllliken (Michigan) that fisheries should be closed when fish exceed 50 ppt of TCDD. DOH has identified a "level of concern" at 10 ppt for TCDD. Neither organization has provided official guidance regarding TCDF. Mercury and chlordane have alao been reported from striped bees in the Hudson liver; however, the levels do notion the average, exceed FDA limits for these contaminants.

The 1984 results of PCB monitoring in striped baas from the Hudson liver are presented in this report which updstes the one Issued in 1983. DEC and DOH staff have reviewed the Information herein.

RESULTS

In the lete winter end eprlng of 1984. 243 fish over 18" total length were collected from the Hudson liver between the George Washington Bridge (RM12) and Troy (1K153). Collections of 167 fish were made during the time's and in the regione of the river normally subject to commercial fishing. A ssmple of 48 fish was collected in February near Ossinlng, and another 28 fish were collected from locstlons north of Poughkeepsie.

' " The Berkshire Eagle, Wednesday, Jan. 21,1981-JF_ The lowest dose of the most

toxic PCDD laomer that win kill a dog to three milligrams per kilogram of weight, Liddle said. Tbe lowest amount that will pro­duce mutation In a mouse to 30 •• micrograms per kilogram of weight fed between the sixth and 1Mb day of pregnancy

David Stalling, chief chemist at Columbia, conducted the tasts. Although he said be does not know what effort. If any, the

have at such low lev­els, be did provide Information about a key experiment eon-ducted at the University of Wis­consin.

There monkeys were fed PCDD at levels from 60 to 500

parts per trilbon'over a long pe­riod of time. Like PCBs, PCDD accumulates In fatty tissues.

The monkeys tat hair, suf­fered malfunctions of the liver and spontaneously aborted their y<Liddk also cited that experi­ment. But be cautioned, "to ex­trapolate that to someone. consuming fish that may be con­taminated every so often is a big tump."

At higher levels, Uddk said, both PCDD and PCDF produce liver cancer hi test animals, darkening of the skin and nice-rations around the eyes and mouth.

Tbe only established effect in humans to chloracne, the skin disorder also associated with heavy or prolonged exposure to PCBs, he said. Both Liddle and Stalling said scientist* now be-Ueve that chloracne from PCB exposure may actually be caused by PCDF contaminants In the PCBs.

PCDF, LkKfle said, to about ten times less hazardous than PCDD. But both are much more toxic than PCBs. Stalling said that "It takes (exposure to) about SN times as much PCBs as PCDF or PCDD to develop symptoms."

Connecticut environmental of­ficials an reported to be an­noyed because preliminary results of SUUing's tests were nude public by Ooanecticut Con­gressman Anthony "Toby" Mof­fett before they had a chance to review them. ,

But Uddk said a final report 1s now In nil office la Atlanta, and the results have now been confirmed wtthte the limits of tv '

Woocls Pond yields two more chemicals

Federal reiearchen recently tested perch from Woods Pood for PCBs <po-IrcUarinated blpaenyls) and also found •loute traces of a toxic PCB byproduct and H "one of the most toxk chemicals known," according to a federal re-

Richard A. Schoettger, director of the Columbia National Research Laboratory of the VS. Fish and Wildlife Service in Columbia, Md., said his scientists check lor the presence of the two other chemi­cals when conducting tents for PCBs. They are PCDF (polychlorioated dfben­aofuran). an apparent contaminant of

*PCBs which can also be formed when PCBs are burned at temperatures too low to destroy them, and PCDD (potvcnloh­mtffl dibenzodkucloT which encompassei the extremely toxk dioxln family UuTtay'

./>,/

dudes me "agent orange" herbicide used during the war in Vietnam.

PCDD does not come from PCBs, ac­cording to Columbia Laboratory scien­tists, but appears to be formed during the manufacture or burning of certain phenol compounds. General Electric Co. is con­sidered the main source of PCB contami­nation to Hoosatonic River fish. But a spokesman said GE does not manufac­ture or use any of the phenol compounds Identified as sources of PCDD.

SboeUfer said he does not know at what levels PCDF and PCDD cause harm and so cannot say whether or not the lab's findings nave any health signifi­cance • '

That is "telling It like it is," said Dr. John A. LJddJe, chief lexicologist of the . .U si , --> •

• federal Center for Disease Con­trol in Atlanta, who to familiar with the research at the Colum­bia lab.

Liddle said more study Is needed to establish the effects of extremely low kvel exposure upon animals or man. Study of the substances to fairly new, he said, partly because of the diffi­culty of handling the toxic com­pounds in their pure form.

Shroettger said his laboratory has not studied toe effects of the substances, even on fish, "be­cause the chemicals are so toxic we cannot handle them in our lab. There to extreme hazard to technicians."

The Woods Pood perch were tested, along with fish from Con­necticut sections of the Hous­atonic River, at the request of Connecticut environmental offi­cials The traces of PCDF and PCDD in all the fish are so slight they are measured In parts per trillion. The largest amounts were detected in ftoh I from Woods Pond. . !

Levels of PCDD In Coonecti­- I cut carp were three and five i

parts per trillion. Woods Pond perch contained B parts per tril­lion. The carp tested at 9 parts per trillion of PCDF, the perch at 1,0*0 parts per trillion. Uddk termed that level significant.

Liddle compared a part per trillion to "one white marbk in a swimming pool full of black marbles." when asked for a ref­erence point to help understand what levels an knowr V> be hii

United States Department of the Interior FISH AND WILDLIFE SERVICE

COLUMBIA NATIONAL FISHERIES RESEARCH LABORATORY ROUTE 1

COLUMBIA. MISSOURI 65201 IN REPLY REFER TO Gc=,,e R c ,

Ep i"~! 0 0-y CO

Freven'ab e D Conn S* '_ D *

H£"ttord'cJanuary 3, 1980 °"

Mr. Martin Gold Connecticut Dept. of Environment Protection State Office Bldg Hartford, CN 06105

Dear Mr. Gold:

At the request of Representative Moffett, Connecticut, the Columbia National Fisheries Research Laboratory has just completed the analysis of fish samples from the Housatinic River. The samples were provided to our laboratory by Mr. Curry of the Bureau of Health Promotion and Disease Prevention. I an herein providing you with copes of two data tables that pertain to the analysis of fish from the Housatonic River (Table 1). Table 2 summarizes residue levels that were detected in striped bass being analyzed for another laboratory project. These data are the first analyses that I am aware of on the occurrence of PCDFs in fish.

The residues encountered in the Housatonic River fish clearly document the occurrence of PCDF and PCDD residues. We have provided a draft report on these findings (copy enclosed) to our Washington office and it will be provided to Representative Moffett as soon as possible.

On December 19, I attended a meeting on residues on 2,3,7,8-TCDD residues in herring gulls that exchanged information from scientists and regulators of the Canadian and U. S. Governments. This meeting was hosted by the State Department and focused on the finding of 2,3,7,8-TCDD in herring gulls from two of the Great Lakes. At this meeting I had the opportunity to visit with Dr. Kimbrough, CDC, Atlanta, Ga.

I learned from her that Mr. Moffet had contacted her in regard to the significance of the findings to human health. At her request, I provided her with a copy of the data I have enclosed with this letter and she indicated that she would review the information.

Dr. Axelrod, Comissioner of Health for New York, also attented this meeting on TCDD and I found that he had obtained samples of the PCBs that were used at the GE plant. I requested that he send ne a subsample of this material in order that could attempt to measure the PCDF concentration in the PCB. We will also att^mt to d^t^rminn if 2 ,3 ,7 , fi-TCDD is orcscnt. It would be a very great surprise if the presence of TCDD were tound in the PCBs.

I have enclosed a draft copy of the response to Mr. Moffett. Please do not release any of the information to the public until you have received the formal response from either our Washington office or until you have discussed such releases with Mr. Moffett1 s office. I expect that it will be about January 15, 1981 before the draft letter enclosed is sent to Mr. Moffett by Dr. Hester, Director of Research, in our central offfice, Washington, D. C.

I have enclosed this data for your use as I know your agency will be carefully evaluating the problem of PCDF and TCDD residues in fish at Woods Pond and in the areas below this location.

We are pleased to have been able to provide the data requested by Mr. Moffet, but wish that the findings would have indicated the absence of PCDFs and 2,3,7 ,8-TCDD. Comments in the summary letter to Mr. Moffett reflect our ability to intrepret these data.

Sincerely,

David L. Stalling, Chief Chemist

Mr. George Curry Bureau of Health Promotion and Disease Prevention

cc: Mr. Tom Turick Department of Environment Protection State Office Building Capitol Avenue Hartford, Connecticut 06115

G E N E R A L fj| E L E C T R I C

ENVIRONMENTAL PROGRAMS GENERAL ELECTRIC COMPANV • 100 PLASTICS AVENUE • PITTSFIELD, MASSACHUSETTS 01201-3698

A/C 413, 494-3729

June 21, 1985

RE: Consent Orders: USEPA 81-964 and DEQE HW 81-8

-Mr. John Moebes U.S. Environmental Protection Agency John F. Kennedy Federal Building Boston, MA 02209

Mr. Stephen F. Joyce, Deputy Regional Environmental Engineer for Air and Hazardous Materials State House West Office Building 436 Dwight Street, 4th Floor Springfield, MA 01103

Gentlemen:

The attached report "Housatonic River Study - PCDF Analysis of Sediment and Fish Samples" is in compliance with terms of Consent Orders dated May 20, 1981 (USEPA), and June 27, 1981 (DEQE), Section III-b-1-v.

If you have comments or questions on this study and report, please contact me at your earliest convenience.

Very truly yours,

J. H. Thayer, Manager Environmental Engineering

-eaa Attachment

cc: C. Bering, USEPA-Boston