### MEMORANDUM

TO : Bill Swietlik, EPA

FROM : Jill Lucy, ERG

DATE : September 2 1 , 201 5

SUBJECT : Fish Consumption Rates U sed in the Environmental Assessment (EA)

Human Health Module (DCN SE044 82 )

The U.S. Environmental Protection Agency (EPA) proposed revised effluent limitations guidelines and standards (ELGs) for the Steam Electric Power Generating Point Source Category (40 CFR Part 423) on June 7, 2013 (78 FR 34432) . In support of the development of the revised ELGs, ERG supported EPA in conducting an environmental assessment (EA) to evaluate the potential environmental and human health impacts of pollutant loadings associated with current ( i.e. , baseline) discharges and assess the potential improvement from pollutant loading removals under varying regulatory options.

ERG developed a national

- scale i m mediate receiving w ater (IRW) model: human h ealth

m odule to estimate the daily contaminant doses for human receptors re sult ing from eating trophic level 3 ( T3 ) and trophic level 4 ( T4 ) fish caught in the immediate receiving waters from steam electric power plant discharges

. This memorandum presents the following updates to the IRW Model : Human Health Module input data for the final rulemaking :

 Revised fish consumption rates based on consumer

- only data, rather than per capita data, for finfish, where available

.

 Added cohorts based on race population to support the environmental justice (EJ) analysis

.

The memorandum includes the following sections:

 Section 1 : Overview of Input Data in the Human Health Module

.

 Sectio n 2 : Methodology to Select Fish Consumption Rates

.

 Section 3 : Fish Consump tion Rates f or Standard Cohorts.

 Section 4 : Fish Consumption Rates for Cohorts in Environmental Justice Analyses

.

 S e ction 5 : References

.Memorandum

September 21, 2015 Page 2

1. O VERVIEW OF I NPUT D ATA IN THE H UMAN H EALTH M ODULE

The IRW m odel : human health m odule evaluate d the cancer risk and potential to cause

non

- cancer health effects from the consumption of fish within the following age and consumption categories ( i.e. , cohorts) :

 Child recreational fishers.

 Child subsistence fishers

.

 Adult recreational fishers.

 Adult sub sistence fishers.

The model estimate d the daily contaminant ( i.e.

, pollutant ) 1 doses for human receptors as a result of eati ng T3 and T4 contaminated fish. The model calculate d the average concentration of pollutants in a fish filet consumed by humans bas ed on a consumption diet of 36 percent T3 and 64 percent T4 fish

. 2 The IRW m odel : human health m odule then calculate d the daily dose of pollutants from fish consumption for each cohort included in the analysis. The model calculate d average daily doses (ADDs) and lifetime average daily doses (LADDs) to human receptors . The ADD ( for noncarcinogenic substances ) and LADD ( carcinogenic substances )

we re specific for each pollutant and each immediate receiving water. Equations 1 and 2 show the calculation of ADD and LADD.

ADD = C

fis h

_ filet × CR

fis h × F

fis h 1000 × BW E quation 1

Where:

ADD = Average d aily dose of pollutant from fish

consumption (m illi g ram [mg] /k ilo g ram [kg] body weight [ BW ] /day)

. Output from Equation 1.

C fish_filet = Average fish fil et concentra tion consumed by

humans (mg/kg). Calculated in the Human Health Module

. CR fish = Consumption rate of fish ( grams wet weight [g

ww] /day). Cohort

- specific value.

F fish = Fraction of fish intake from contaminated

source. Assumed value of 1.

1 The IRW m odel includes ten pollutants: arsenic, cadmium, chromium VI, copper, lead, mercury, nickel, selenium, thallium, and zinc.

2 To determine the fraction of T3 and T4 fish intake for humans, ERG used data in Table 10

- 74 of the EPA Exposure Factor Handbook: 2011 Edition . The table includes total consumption of freshwater fish, listed by species, caught by survey respondents during o ne season. ERG determined the trophic level of each species and calculated a percentage of T4 and T3 fish consumed. See Appendix E , Table E

- 1 of EPA’s Environmental Assessment for the Effluent Limitations Guidelines and Standards for the Steam Electric Pow er Generating Point Source Category (EPA

- 821

- R

- 15

- 006 ) lists the type of fish and assigned trophic level used to estimate percent of T3 and T4 fish eaten.Memorandum

September 21, 2015 Page 3

1,000 = Conversion factor (g/kg)

.
BW = Body weight (kg). Cohort

- specific value

LADD = ADD × ED × EF

AT × 365 E quation 2

Where:

LADD = Lifetime av erage daily dose (mg/kg BW/day). Output from Equation 2.

ADD = Daily dose of pollutant from fish consumption

(mg/kg BW/day). Output from Equation 1.

ED = Exposure duration for oral ingestion ( year

[ yr ] )

. Cohort

- specific value.

EF = Exposure frequency (days/yr). Assumed value of 350.

AT = Averaging time (yr). Standard value of 70

. 365 = Conversion factor (days/yr).

T he model evaluate d the cancer risk (using LADD) and potential to cause non

- cancer health effects (using ADD) from the consumption of fish for the following cohorts :

 Recreational Fishers

— Adult

— Child, age 1 to < 2 years

— Child, age 2 to < 3 years

— Child, age 3 to < 6 years

— Child, age 6 to < 11 years

— Child, age 11 to < 16 years

— Child, age 16 to < 21 years  Subsistence Fishers

— Adult

— Child, age 1 to < 2 years

— Child, age 2 to < 3 years

— Child, age 3 to < 6 years

— Child, age 6 to < 11 years

— Child, age 11 to < 16 years

— Child, age 16 to < 21 years

To determine the ADD and LADD from fish consumption, the model use d th e following information :

 Concentration of Polluta nt in Fis h (T3 and T4)

– calculated in the IRW m odel:

w ater q uality m od ule for immediate discharge receiving waters

. These data we re not cohort dependent.

 Fish C onsumption R ate

– Section 2 presents the methodology to select fish consumption rates. Section 3 discusses updates for standard cohorts

, and Section 4 pres e n ts values for cohorts based on race or Hispanic origin

. These data are cohort dependent.Memorandum

September 21, 2015 Page 4

 Body Weight

– values provided in the EPA Exposure Factors Handbook: 2011

Edition ( Table A

- 1

, A ttachment A )

. These data are cohort dependent.

 Exposure Duration

– values based on time spent in respective cohort ( Table A

- 1

, Attachment A )

. These data are cohort dependent.

2. M ETHODOLOGY TO S ELECT F IS H C ONSUMPTION R ATES

In the U.S., large quantities of finfish and shellfish are caught, both recreationally and commercially

, for human consumption . Some finfish and shellfish might accumulate contaminants from the water body or from the food they eat. Whe n residents of nearby water bodies eat the fish harvested from contaminated waters, they also are exposed to these contaminants based on the amount of fish they consume.

EPA estimates of f

ish consumption rates among potentially exposed human populations are typically based on surveys and studies. This section presents background on how estimates of fish consumption rates are developed.

The data collected from fish consumption surveys and studies can be parsed in multiple ways to represent the following:

 P op ulation basis ( “ consumer only ” or “ per capita ,”) ; see Section 2.1

.

 Statistical percentiles (used to represent different population subgroups, such as general po pulation, recreational fishers, subsistence fisher s, and Native American fishers) ; see Section 2.2

.

 Type of fish consume d (finfish, shellfish, or both) ; see Sectio n 2.3

.

 Habitat and salinity (w ater body type ) where fish are caught (freshwater, estuarine, marine) ; see Section 2.3

.

 Fish tissue preparation (cooked or uncooked) ; see Section 2.4

.

 D emographic groups ( e.g. , income, race, or geographic location ) ; see Section 4

.

2.1 Population Basis for Fish Consumption Rates

General population studies may include two types of intake data: 1) “consumer only” is the average intake across only those individuals that consumed fish and shellfish during the survey time period and 2) “per capita” is the average intake across the entire survey population, including respondents that did not consume fish or shellfish during the survey time period. In the Exposure Factors Handbook: 2011 Edition , EPA note d that per capita intake rates are appropriate for use in exposure assessments where average doses across the entire potentially

exposed population of interest are used, because the average doses represent both individuals thatMemorandum

September 21, 2015 Page 5

consumed fish during the survey period and individuals who may eat fish sometimes but did not consume fish during the survey period. However, use of per capita intakes may undere stimate the actual exposure to fish consumers. Consumer

- only data may be of greater interest in exposure analysis and risk assessment applications where impacts to fish consumers are a specific concern.

For the EA and benefits analyses in support of the s t eam e lectric ELGs , the focus of human exposure to contaminated fish wa s on recreational and subsistence fishers. Recreational fishers are non

- commercial, non

- subsistence fishers and are more vulnerable to pollutant exposure by intake of contaminated fish f rom a specific water body compared to the general population. Subsistence fishers are individuals who consume fresh caught fish as a major food source. Intake rate s for subsistence fishers are generally higher than for the general population

, and subsisten ce fishers are more vulnerable to pollutant exposure by intake of contaminated fish from a specific water body compared to both recreational fishers and the general population.

At proposal, ERG used per capita fish consumption rates in the IRW m odel : human health m odule

. However, because the be nefits analysis includes only those populations that are recreational and subsistence fishers ( i.e. , population s that consume fish from receiving waters), ERG updated the fish consumption rates in the IRW Model: Human Health Module to reflect fish consumption rates based on consumer

- only data

. See Section 3 and Section 4 for details on the fish consumption rates used for the standard cohorts and cohorts based on race or Hispanic origin , respectively.

2.2 Statistical Percen tiles for Fish Consumption Rates

Statistical percentiles (percentiles) indicate the value below which a percentage of data fall . For example, the 90 th percentile is the value below which 90 percent of the data points may be found. The EPA document, Method ology for Deriving Ambient Water Quality Criteria for the Protection of Human Health ( Table 5

- 1 ) [U.S. EPA, 2000] determined protective fish intake rates using the following percentiles by fisher type:

 General population and r ecreational fish er : 90 th perce ntile of per capita data

.

 Subsistence fisher: 99 th percentile of per capita data

.

Use of a consumer

- only dataset, however, would require the selection of lower percentiles to represent recreational and subsistence fishers (b ecause a consumer

- only survey should yield higher fish intake rates than a corresponding per capita survey ). The EPA document, Methodology for Deriving Ambient Water Quality Criteria for the Protection of Human Health [U.S. EPA, 2000] does not provide reco mmendations for the statistical percentiles of consumer

only intake rates that would best represent recreational and subsistence fishers . ERG used best professional judgment and selected the following percentiles by fisher type:

 Recreational fisher: mean 3 of consumer

- only data.

3 The data available in EPA’s Exposure Factor Handbook: 2011 Edition provided mean fish consumption r ates, rather than median fish consumption rates.Memorandum

September 21, 2015 Page 6

 Subsistence fisher: 9 5 th percentile of consumer

- only data.

2.3 Type of Fish Consumed and Habitat for Fish Consumption Rates

Fish consumption rates may be divided into types of fish ( finfish and shellfish ) and into habitat and salinity type (freshwater, estuarine, or marine)

. Table 2

- 1 shows typical finfish and shellfish found in freshwater, estuarine, and marine water bodies. The I RW model: w ater q uality

m od ule quantifie d the environmental risks within freshwater habitats , specifically rivers/streams and lakes/ponds/reservoirs. Shellfish species are more commonly found in marine and estuarine environments; only two shellfish species were common in f reshwater environments, as shown in Table 2

- 1

. Based on the model capabilities and water bodies represented, ERG chose to use fish consumption rates based on finfish only (where available) and/or on freshwater /estuarine habitats (where a vailable).

2.4 Fish Tissue Preparation for Fish Consumption Rates

Fish consumption rates are also presented as uncooked or cooked ( i.e. , “as

- prepared”) fish. ERG used the consumption rates based on uncooked fish weight. As detailed in EPA’s Exposure Factors Ha ndbook: 2011 Edition , contaminant concentrations in fish are generally measured in the uncooked samples. Cooking of the fish results in moisture loss and reduction in fish weight, and the moisture loss varies based on the cooking method used. Because the m ass of the contaminant in the fish tissue remains constant, the contaminant concentration in the cooked fish tissue will increase. To ensure comparison on the same basis, ERG used uncooked fish consumption rates.

Table 2

- 1 . Type of Fish Consumed by Humans by Habitat and Salinity (Water Body Type)

Freshwater Estuarine Marine

Finfish Shellfish Finfish Shellfish Finfish Shellfish Carp Catfish Cisco Eel Perch Pike Roe Salmon Smelts, Rainbow Sturgeon Trout Whitefish Crayfish

Snails Anchovy

Catfish Croaker Eel Flatfish Flounder Halibut Herring Mackerel Mullet Perch Pompano Rockfish Roe Salmon Shad Shark Smelts Clam

Crab Lobster Mussels Octopus Oyster Scallop Shrimp Snails Barracuda

Cod Flatfish Haddock Halibut Herring Mackerel Ocean Perch Pollock Pompano Porgy /Scup Roe Salmon Sardine Sea Bass Shad Shark Smelts Abalone

Clam Conch Crab Lobster Mussels Octopus Scallop Shrimp Snails SquidMemorandum

September 21, 2015 Page 7

Table 2

- 1 . Type of Fish Consumed by Humans by Habitat and Salinity (Water Body Type)

Freshwater Estuarine Marine

Finfish Shellfish Finfish Shellfish Finfish Shellfish
Smelts, Rainbow Sturgeon Trout Snapper Swordfish Tuna Whitefish Whiting

Sources : U.S. EPA, 2011. Exposure Factors Handbook: 2011 Edition. EPA

- 600

- R

- 09

- 052F . (September) and U.S. EPA

, 2014. Estimated Fish Consumption Rates for the U.S. Population and Selected S ubpopulations (NHANES 2003

- 2010). EPA

- 820

- R

- 14

- 002. (April).

3. F ISH C ONSUMPTION R ATES U SED FOR S TANDARD C OHORTS

This section details the updated fish consumption rates for the IRW m odel : human health

m odule standard coho rts

. Table 10

- 1 of the Exposure Factors Handbook: 2011 Edition includes per capita and consumer

- only fish intake rates based on EPA analysis of the National Health and Nutrition Examination Survey (NHANES) data from 2003 to 2006. As discussed in Section 2.1

, ERG revised the fish consumption rates to be based on consumer

- only data, rather than per capita data. Table 3

- 1 presents
, by cohort

, the fish consumption rates used at proposal and the fish consumption rates used for the final rule. 4

4 ERG also examined a document published by EPA in April of 2014 (U.S. EPA, 2014) that provides consumption rates using NHANES data from 2003 to 2010; however, the document presents fish consumption rates on a per capita basis only; therefore, ERG did not use the document for fish consumption rate updates.Memorandum

September 21, 2015 Page 8

Table 3

- 1 . Fish Consumption Rates (Uncooked) for the IRW Model: Human Health Mod ule (Standard Cohorts)

Receptor Cohort Consumption Rate Used for Proposed Rule (per capita) Consumption Rate Used for Final Rule (consumer only)

CR fish , g/day Reference CR fish , g/day Reference

Recreational 1 to <2 years 2.5 T able 10

- 1 of (a): Mean, per capita fish intake for finfish (excludes shellfish)

. 1 18.2 Table 10

- 1 of (a): Mean,

consumer

- only fish intake for finfish (excludes shellfish)

. 1 2 to <3 years 3 22.1 3 to <6 years 3.5 24.2 6 to <11 years 5.1 35.0 11 to <16 years 5.7 37.5 16 to <21 years 7.2 47.3

Adult 20 Table 10

- 5 of (a)

. 2 53.2 Table 10

- 1 of (a): Mean,

consumer

- only fish intake for finfish (excludes shellfish)

. 1,4

Subsistence 1 to <2 years 13.7 Table 10

- 1 of (a): 95th percentile, per capita fish intake for finfish (excludes shellfish)

. 1 55.9 Table 10

- 1 of (a): 95th percentile, consumer

- only fish intake for finfish (excludes shellfish)

. 1 2 to <3 years 16.6 67.6 3 to <6 years 26 67.0 6 to <11 years 35 92.2 11 to <16 years 39.8 96.6 16 to <21 years 50.1 121.7

Adult 88 Table 10

- 6 of (a)

. 3 164.0 Table 10

- 1 of (a): 95th percentile, consumer

- only fish intake for finfish (excludes shellfish)

. 1,4

a U .S. EPA, 2011. Exposure Factors Handbook: 2011 Edition. EPA

- 600

- R

- 09

- 052F

. ( September )

. 1 Values provided as g/kg

- day. ERG multiplied values in Table 10

- 1 of the reference by cohort body weight to calculate a consumption rate as g/day.

2 Table 10

- 5 includes freshwater recreational fish consumption rates from eight studies at eight U.S. locations . For proposal, ERG used mean values for "all respondents." See ERG memorandum, “ Fish Consumption Rate for Cohorts for the Steam Electric ELGs Environmental Assessment ” ( DCN SE01963 )

. 3 Table 10

- 6 includes Native American fish consumption rates from seven studies for ten locations/ Trib es . For proposal, ERG used mean values for adults. See ERG memorandum, “ Fish Consumption Rate for Cohorts for the Steam Electric ELGs Environmental Assessment ” ( DCN SE01963 )

. 4 Use average fish intake for two age categories: 1) 21 to <50 years and 2) 50+ y ears.

4. F ISH C ONSUMPTION R ATES U SED FOR C OHORTS B ASED ON R ACE OR H ISPANIC O RIGIN

The EPA web site defines EJ and Agency goals as, “ the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. EPA has this goal for all c ommunities and persons across this Nation. It will be achieved whenMemorandum

September 21, 2015 Page 9

everyone enjoys the same degree of protection from environmental and health hazards and equal access to the decision

- making process to have a healthy environment in which to live, learn, a nd work. ” To help achieve the Agency goals, ERG examined both the impacts of income and race on fish consumption rates.

4.1 EJ Factor: Income Demographic

ERG examined the impacts of income on fish consumption rates using the EPA document Estimated Fish Consu mption Rates for the U.S. Population and Selected Subpopulations (NHANES 2003

- 2010) [U.S. EPA, 2014 ]

. 5 This document included finfish consumption rates for low income populations. The rates provided in the document are divided into two age groups: adults ( 21 years and older) and youth (<21 years). Table B

- 1 (Attachment B ) presents the consumption rates by income demographic. The consumption rates are based on general population data ( i.e.

, per capita data and not limited to consumers only); therefore, ERG

u sed the 90 th percentile to represent recreational fishers and the 99 th percentile to represent subsistence fishers. Because the fish consumption rates are based on per capita data, t he consumption rates for the income groups (adult and child cohorts ) are lower than the recommended updated consumption rates presented in Table 3

- 1 for standard cohorts.

To examine further

, ERG plotted the fish consumption rates by increa sing income to identify any trends (Figure B

- 1 , Attachment B ) . The data suggest that national consumption rates tend to increase with increased income for adults. For child cohorts, there does not appear to be a strong correlation between income and fish c onsumption rate. Based on this analysis, an EJ analysis that defines cohorts according to income demographics is not likely to reveal disproportionate impacts among low

- income communities as a result of fish consumption. Therefore, ERG did not include coho rts based on income demographics in the IRW m odel : human health m odule

.

4.2 EJ Factor: Race or Hispanic Origin

ERG used the Exposure Factors Handbook: 2011 Edition [ U.S. EPA, 2011 ] to determine if fish consumption rates vary according to race or Hispanic origin

. 6 This document includes

consumer

- only fish consumption rates by the following population groups : Non

- Hispanic Black, Non

- Hispanic White, Mexican

- American, Other Hispanic, and Other, including multiple races.

5 ERG also examined the reference Estimated Per Capita Fish Consumption in the United States, August 2002. Office of Water, Engineering and Analysis Divi sion. This document, however, does not provide consumption rates by age group. Because more recent data were available and fish consumption rates were not provided by age for the cohorts, ERG did not use this reference as a source of consumption rates for low income cohorts.

6 ERG also examined the EPA document Estimated Fish Consumption Rates for the U.S. Population and Selected Subpopulations (NHANES 2003

- 2010) [U.S. EPA, 2014 ]. This document include d fish consumption rates for the same race/Hispanic origin groups as listed in Table 4

- 1. The 2014 document divided fish consumption rates into two age groups: adults (21 years and older) and youth (<21 years). The consumption rates we re based on general population data ( i.e. , per capita data). Because these data we re not based on consumers only, ERG decided to use the fish consumption rates from the Exposure Factors Handbook: 2011 Edition , presented in Table 4

- 1

.Memorandum

September 21, 2015 Page 10

Beca use t he consumption rates are based on consumer

- only intake

, ERG used the mean consumption rate to represent recreational fishers and the 95 th percentile to represent subsistence fishers. Table 4

- 1 presents the consumption rates as grams per day (g/day) . As with the fish consumption rates in Table 3

- 1 , the consumption rates are based on EPA analysis of NHANES data 2003 through 2006.

T he Exposure Factors Handbook: 2011 Edition [ U.S. EPA, 2011 ] includes fish consumption rates as grams per ki logram body weight per day (g/kg

- day) for each race or Hispanic origin regardless of the cohort age (a single value represents all ages). ERG multiplied the fish consumption rate for the race or Hispanic origin by the body weight of each c ohort ( body weigh t varies by age). This resulted in a fish consumption rate in grams per day for each cohort by race or Hispanic origin and by age. See Table A

- 1 in Attachment A

. Because the fish consumption rates by race or Hispanic origin represent all ages, the values presented in Table 4

- 1 might not be directly comparable to fish consumption rates for standard cohorts, as presented in Table 3

- 1

.

Based on the national fish consumption rates in Table 4

- 1

, an EJ analysis that defines cohorts according to race and Hispanic origin suggests potential disproportionate impacts among minority c ommunities as a result of fish consumption

. Therefore, ERG included cohorts based on race or Hispanic origin in the IRW m odel : human health m odule

.Memorandum

September 21, 2015 Page 11

Table 4

- 1 . Fish Consumption Rates ( Uncooked ) by Race or Hispanic Origin

Receptor Race or Hispanic

Origin Reference /

Statistical Value CR fish ,

g/kg

- day (All ages) Consumption Rate (CR fish ), g/day, by Cohort 1

1 to <2
years 2 to <3

years 3 to <6

years 6 to <11

years 11 to <16

years 16 to <21

years Adult

Recreational Non

- Hispanic White Table 10

- 8 of (a): Mean,

consumer

- only fish intake for finfish (excludes shellfish). 0.67 7.6 9.2 12.5 21.3 38.1 48 53.6

Non

- Hispanic Black 0.77 8.8 10.6 14.3 24.5 43.7 55.1 61.6

Mexican

- American 0.93 10.6 12.8 17.3 29.6 52.8 66.6 74.4

Other Hispanic 0.82 9.3 11.3 15.3 26.1 46.6 58.7 65.6

Other, including Multiple Races 0.96 10.9 13.2 17.9 30.5 54.5 68.7 76.8

Subsistence Non

- Hispanic White Table 10

- 8 of (a): 95 th Percentile,

consumer

- only fish intake for finfish (excludes shellfish). 1.9 21.7 26.2 35.3 60.4 107.9 136 152

Non

- Hispanic Black 2.1 23.9 29 39.1 66.8 119.3 150.4 168

Mexican

- American 2.8 31.9 38.6 52.1 89 159 200.5 224

Other Hispanic 2 2.7 30.8 37.3 50.2 85.9 153.4 193.3 216

Other, including Multiple Races 2 3.6 41 49.7 67 114.5 204.5 257.8 288

a U.S. EPA, 2011. Exposure Factors Handbook: 2011 Edition. EPA

- 600

- R

- 09

- 052F

. ( September )

. 1 Values provided as g/kg

- day. ERG multiplied values in Table 10

- 8 of the reference by cohort body weight to calculate a cohort

- specific consumption rate as g/day.

2 Estimates are less statistically reliable based on guidance when using NHANES data.Memorandum

September 21, 2015 Page 12

5. R EFERENCES

1. U.S. EPA. 2000. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories. Volume 1: Fish Sampling and Analysis. EPA

- 82 3

- B

- 00

- 007. Office of Water. Washington, DC. ( November ).

2. U.S. EPA. 2002. Estimated Per Capit a Fish Consumption in the United States. EPA

- 821

- C

- 02

- 003. Office of Water . Washington, DC. (August).

3. U.S. EPA. 2011. Exposure Factors Handbook: 2011 Edition

. EPA

- 600

- R

- 09

- 052F. Office of Research and Development. Washington, DC. (September). DCN SE01912.

4. U.S. EPA

. 2013

. Environmental Assessment for the Proposed Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category

. EPA

- 821

- R

- 13

- 003. Office of Water

. Washington, DC. ( April ).

5. U.S. EPA. 2014. Estimated Fish Consumption Rates for the U.S. Population and Selected Subpopulations (NHANES 2003

- 20010). EPA

- 820

- R

- 14

- 002. (April).Attachment A

September 21, 2015 Page A

- 1

ATTACHMENT A: BODY WEIGHT AND EXPOSURE DURATION

To calculate the average daily dose and lifetime average daily dose, the IRW m odel : human health m odule use d cohort

- specific body weights (BW) and cohort

- specific exposure durations (ED). Table A

- 1 presents the values used in the model.

Table A

- 1 . Body Weight and Exposure Duration for the IRW Model: Human Health Module

Receptor Cohort Body Weight Exposure Duration BW, kg Reference ED, yr Reference

Recreational 1 to <2 years 11.4 Table 8

- 1 of (a) 1 Set equal to time in cohort. 2 to <3 years 13.8 1 3 to <6 years 18.6 3 6 to <11 years 31.8 5 11 to <16 years 56.8 5 16 to <21 years 71.6 5

Adult 80 49

Subsistence 1 to <2 years 11.4 1

2 to <3 years 13.8 1 3 to <6 years 18.6 3 6 to <11 years 31.8 5 11 to <16 years 56.8 5 16 to <21 years 71.6 5

Adult 80 49

a U.S. EPA, 2011. Exposure Factors Handbook: 2011 Edition. EPA

- 600

- R

- 09

- 052F

. ( September )

.Attachment B

September 21, 2015 Page B

- 1

ATTACHMENT B : COMPARISON OF NATIONAL FISH CONSUMPTION RATES BY INCOME

As discussed in Section 4.1 , ERG reviewed fish consumption rates by income . Table B

- 1 presents the data reported in the EPA document, Estimated Fish Consumption Rates for the U.S. Population and Selected Subpopulations (NHANES 2003

- 2010) [U.S. EPA, 2014]. ERG also plotted the fish consumption rates by income in Figure B

- 1. Based on this review, ERG determined that income demographics do not suggest a disproportionate impact amo ng low

- income communities as a result of fis h consumption.

Table B

- 1 . Fish Consumption Rates (Uncooked) by Income Demographics

Receptor Cohort Income, $ Consumption Rate (CR fish ), g/day Reference/Statistical Value

Recreational Adult 0

- <20,000 35.4 Table 11a of (a): 90 th percentile, per capita fish intake for finfish (excludes shellfish). 20,000

- <45,000 36.1 40,000

- <75,000 37.7 ≥75,000 44.1 >20,000 b 38.9

Refused/Don't know c 43.6 Income Missing c 28.8

Child (<21 yrs) 0

- <20,000 20.0 Table 22a of (a): 90th percentile, per capita fish intake for finfish (excludes shellfish). 20,000

- <45,000 17.1 40,000

- <75,000 21.9 ≥75,000 16.8 >20,000 b 12.7

Refused/Don't know 23.1 Income Missing 26.4

Subsistence Adult 0

- < 20,000 78.0 Table 11a of (a): 99 th percentile, per capita fish intake for finfish (excludes shellfish). 20,000

- <45,000 75.0 40,000

- <75,000 78.3 ≥75,000 84.4 >20,000 b 81.4

Refused/Don't know 87.4 Income Missing 75.7

Child (<21 yrs) 0

- <20,000 50.9 Table 22a of (a): 99 th percentile, per capita fish intake for finfish (excludes shellfish). 20,000

- <45,000 48.5
40,000

- <75,000 64.9
≥75,000 43.7
>20,000 b 32.7

Refused/Don't know 73.3 Income Missing 65.3Attachment B

September 21, 2015 Page B

- 2

a U.S. EPA. 2014. Estimated Fish Consumption Rates for the U.S. Population and Selected Subpopulations (NHANES 2003

- 2010). EPA

- 820

- R

- 14

- 002. (April).

b The “> 20,000 ” income group appears to be a separate group where the respondent did not want to be more specific on their income.

Figure B

- 1 . Fish Consumption Rates By Income Adult
Recreational

Child
Recreational Adult
Subsistence

Child
Subsistence

0 10 20 30 40 50 60 70 80 90

0 - <20,000 20,000 - <45,000 40,000 - <75,000 ≥75,000 Fish Consumption Rate, g/day

Income, $