Page
1
of
3
Memorandum
From:
Lynn
Zipf
USEPA/
OW/
OST
ph:
(
202)
566­
1429
zipf.
lynn@
epa.
gov
To:
MP&
M
Record
Date:
February
10,
2003
Re:
Fish
Consumption
This
memo
describes
EPA's
decisions
regarding
fish
consumption
and
BCF/
BAF
for
the
benefits
analysis
associated
with
the
final
rule.

FISH
CONSUMPTION
RATES
Fresh
Water
and
Estuarine
Fish
Consumption
Rates
for
Sport
fishers
and
Subsistence
fishers:

"
New
studies
have
addressed
water
consumption
and
fish
tissue
consumption.
These
studies
provide
a
more
current
and
comprehensive
description
of
national,
regional
and
specialpopulation
consumption
patterns
that
EPA
has
reflected
in
the
2000
Human
Health
Methodology."
(
U.
S.
EPA
2000)

OW
has
determined
that
the
fish
consumption
rate
of
142.4
g/
day
for
subsistence
fishers
falls
within
the
range
of
the
arithmetic
mean
of
subsistence
fisher
studies
representative
of
the
United
States.(
U.
S.
EPA,
1998,
Section
2.3).
It
represents
the
average
consumption
rate
for
this
population
of
fishers.
142.4g/
day
represents
uncooked,
fresh
and
estuarine
finfish
and
shellfish.
The
reason
it
is
reported
on
an
uncooked
basis
is
that
pollutant
concentration
data
are
reported
on
an
uncooked
weight
basis.
The
two
key
studies
in
the
EFH
(
1997),
CRITFC
(
1994)
and
Wolfe
and
Walker
(
1987)
were
reviewed
in
the
process
of
development
of
national
rates
as
well
as
10
other
studies.
The
other
studies
represent
subsistence
fishers
from
the
Great
Lakes,
Idaho,
American
Samoan,
Wisconsin
Chippewa
Indians,
Miccousukee
Indians,
Wisconsin
tribes,
tribes
from
Puget
Sound,
Native
Americans
near
Clear
Lake,
California,
Hawaiian
Islands,
and
Alaska
Natives
(
U.
S.
EPA,
1998).

The
fish
consumption
rate
of
17.5g/
day
falls
within
the
average
consumption
rate
for
sports
fishers.
17.5g/
day
represents
uncooked,
fresh
and
estuarine
finfish
and
shellfish.
Four
of
the
five
key
studies
in
the
EFH
(
1997)
were
reviewed
in
the
development
of
the
national
rate
as
well
as
17
other
studies.
The
other
studies
represent
sports
fishers
from
Alabama,
California,
Louisiana,
Page
2
of
3
Wisconsin,
Ontario,
Idaho,
Washington,
Alaska,
Savannah
and
Florida.
(
U.
S.
EPA
1998).
The
fifth
study,
Connelly
(
1992)
has
since
been
included
and
found
to
support
the
17.5g/
day
fish
consumption
rate.

Both
these
values,
142.4
g/
day
and
17.5g/
day,
are
being
used
for
the
specific
subpopulation
which
they
represent.
We
were
not
able
to
break
them
down
by
gender
or
age
group
for
the
use
in
our
analysis.

The
draft
TSD
(
USEPA
1998)
from
which
the
above
fish
consumption
rates
have
been
excerpted
has
undergone
peer
review
in
accordance
with
EPA's
Peer
Review
Handbook.
The
peer
review
process
was
initiated
in
April
1999
with
15
technical
experts
(
reviewers)
participating
(
U.
S.
EPA.
1999).
Offices
within
EPA,
including
ORD,
participated
in
the
EPA
workgroup
that
reviewed
and
commented
on
the
draft
TSD.

Fish
Consumption
rates
for
children
under
18
of
sport
and
subsistence
fishers:

To
calculate
the
consumption
rate
for
sport
fisher
children,
West
(
1989)
in
the
Exposure
Factors
Handbook
(
USEPA
1997)
had
the
most
specific
data.
West
et.
al.
cited
an
intake
of
7.27g/
day
of
fresh
water
and
estuarine
fish
for
children
of
sport
anglers.
We
took
that
consumption
rate
of
7.27
g/
day
and
extrapolated
to
subsistence
fisher
children,
using
the
proportional
relationship
between
adult
sport
and
subsistence
fishers
(
17.5g/
day
divided
by
142.4
g/
day).
The
rate
for
subsistence
children
is
calculated
to
be
60.58
g/
day.

Fish
Consumption
rates
for
for
children
between
ages
1­
7
of
sport
and
subsistence
fishers:

For
sport
fisher
children,
we
calculated
a
weighted
consumption
average
of
6.03
g/
day.
This
is
based
on
the
West
et.
al.
data
(
USEPA
1997)
for
children
ages
1­
5
(
5.63
g/
day)
and
children
ages
6­
10
(
7.94
g/
day).
For
the
children
of
subsistence
fishers,
we
used
the
1994
CRTFIC
data
of
19.6
g/
day
for
children
under
age
5
and
the
data
from
the
Estimated
Per
Capita
Fish
Consumption
in
the
US
document
(
USEPA
2002)
for
the
children
who
ate
fish
for
ages
3­
5
(
40.31
g/
day)
and
ages
6­
10
(
61.49
g/
day)
to
calculate
a
weighted
average
consumption
rate
of
30.33
g/
day.

Marine
Fish
Consumption
Rates
for
Sport
fishers,
Subsistence
fishers
and
their
children:

The
data
for
marine
fish
consumption
rates
for
sport
fishers
and
subsistence
fishers
is
not
readily
available.
Given
the
time
constraints
as
well
as
the
few
number
of
marine
reaches
affected
by
the
MP&
M
effluent
guideline,
we
decided
to
use
the
fresh
and
estuarine
fish
consumption
rates
in
lieu
of
marine
fish
consumption
rates.
This
may
result
in
underestimating
the
benefits,
but
some
would
argue
that
few
subsistence
fishers
eat
fresh/
estuarine
fish
and
marine
fish
at
the
same
rate.

BCFs/
BAFs
Page
3
of
3
We
decided
to
continue
using
bioconcentration
factors
recognizing
that
they
will
underestimate
the
risk.
Field
measured
BAFs
are
not
yet
available,
and
using
a
food
chain
multiplier
model
leaves
us
too
vulnerable
at
this
late
date
so
therefore
we
have
not
used
the
BAF
in
this
effluent
guideline.

References:

Connelly,
N.
A.;
Knuth,
B.
A.;
Bisogni,
C.
A.
(
1992)
Effect
of
health
advisory
and
advisory
changes
on
fishing
habits
and
fish
consumption
in
New
York
sport
fisheries.
Human
Dimension
Research
Unit,
Department
of
Natural
Resources,
New
York
State
College
of
Agriculture
and
Life
Sciences,
Fernow
Hall,
Cornell
University,
Ithaca,
NY.

Columbia
River
Intertribal
Fish
Commission
(
CRITFC)
1994.
A
Fish
consumption
survey
of
the
Umatilla,
Nez
Perce,
Yakama.
and
Warm
Springs
Tribes
of
the
Columbia
River
Basin.
Portland,
OR:
CRITFC.
Technical
Report
94­
3.

USEPA
1997.
Exposure
Factors
Handbook.
Volumes
I,
II,
and
III.
National
Center
for
Environmental
Assessment,
Office
of
Research
and
Development,
Washington,
DC.
(
EPA/
600/
P­
95/
002Fa,
b,
c)
August.

USEPA
1998.
Ambient
Water
Quality
Criteria
Derivation
Methodology:
Human
Health.
Technical
Support
Document
(
EPA/
822/
B­
98/
005)
July.

USEPA
1999.
Summary
Report
from
the
Peer
Review
Workshop
(
EPA/
822/
R­
99/
015)
September.
