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MEMORANDUM
TO:
Jesse
Pritts
and
Pat
Harrigan,
EPA
EAD
CC:
Kathy
Monk,
EPA
EAD
FROM:
Betsy
Bicknell,
ERG
DATE:
February
3,
2003
SUBJECT:
Brief:
National
Fish
Tissue
Study
This
memorandum
is
a
partial
response
to
Technical
Direction
received
from
Jesse
Pritts
on
January
15,
2003.
Among
other
things,
ERG
was
directed
to
review
briefs
prepared
by
EAD.
These
briefs
evaluate
the
utility
of
data
sources
for
determining
specific
industrial
categories
or
facilities
that
may
pose
a
risk
to
human
health
and
the
environment
or
may
be
significant
dischargers
of
toxic
or
conventional
pollutants
to
waters
of
the
U.
S.
due
to
wastewater
and
stormwater
discharges.
This
memorandum
addresses
the
brief
describing
the
National
Fish
Tissue
Study.

Overview
Ongoing,
four
year
study
to
develop
national
estimates
of
the
mean
levels
of
Persistent,
Bioaccumulative,
and
Toxic
(
PBT)
chemicals
in
fish.
The
process
began
in
1998,
with
sampling
scheduled
for
1999
to
2003.
Only
the
first
year's
results
are
available
at
this
time.

Comments
°
265
chemicals
are
included
in
the
study.
These
include
pollutants
no
longer
discharged
(
PCBs
and
certain
pesticides);
pollutants
believed
to
currently
enter
waters
predominantly
through
atmospheric
deposition,
not
discharge
(
dioxins
and
mercury,
though
there
may
be
sediment
accumulations
from
past
discharges);
and
other
analytes.

°
Polynuclear
aromatic
hydrocarbons
(
PAHs)
and
metals
(
and
their
metabolites)
are
also
included
in
the
study.

°
Of
the
fish
composites
tested
in
the
first
year
of
the
study,
all
showed
concentrations
of
dioxin/
furans
and
PCBs.
More
than
90
percent
showed
concentrations
of
mercury
and
total
DDT.
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°
The
only
non­
pesticide
found
during
the
first
year
of
the
study
was
octachlorostyrene,
detected
in
eight
fish
tissue
samples.
Octachlorostyrene
is
a
by­
product
of
wastes
from
the
electrolytic
production
of
chlorine
prior
to
1970
when
graphite
anodes
and
coal
tar
pitch
binder
were
used.

°
From
a
brief
review
of
the
first
year's
data,
it
does
not
appear
that
currently
discharged
pollutants
were
detected
in
fish
tissue
samples.

Short­
term
Follow­
up
(
February
­
March,
2003)

°
Review
the
pollutants
included
in
the
study,
and
using
OPPT
tools,
identify
those
that
may
be
currently
discharged
from
point­
sources.
Chemicals
no
longer
in
commerce
and
metabolites
would
be
eliminated.

°
Use
OPPT
data
to
identify
pesticides
no
longer
in
commerce.

°
Use
OPPT
tools
to
identify
industries
from
which
the
identified
pollutants
may
be
discharged.

°
PAHs
are
included
in
the
Fish
Tissue
Study
and
they
may
be
currently
discharged.
Review
potential
sources
of
point
source
discharges
of
PAHs
for
use
in
EAD
targeting.

Long­
term
Follow­
up
(
after
March
2003)

°
Review
results
over
the
duration
of
the
study,
focusing
on
contaminants
that
may
be
discharged
from
point
sources.
