1. Evaluation of the Surface Water Contact Advisory Removal Program
Brittany Schuch
Candidate for the degree
Master of Public Health – Program for Experienced Professionals
College of Public Health
The Ohio State University
Columbus, Ohio, October 2015
Dr. Elizabeth Klein, Advisor
Dr. Michael Bisesi, Second Reader

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Abstract
Contact advisories have historically been posted on streams and rivers near or in areas
of egregious contamination. Currently, in the State of Ohio, there are four contact advisories in
place on rivers across the State. A more formalized and consistent approach to evaluate the
removal of contact advisories was determined to be a need, and this evaluation was created to
provide recommendations for consistent decision making. Its design is a mixed approach of a
formative and process evaluation. The scope of this evaluation is to recommend a consistent
approach for reevaluating and removing contact advisories when justified. Primary data
sources include in-depth, qualitative interviews and a standardized survey on Region V staff.
Secondary sources of data included peer-reviewed literature on impacts of contamination and
remediation efforts, Ohio EPA risk assessment documents, existing water quality and sediment
data, and agency website and publications.
The results from this evaluation will be an asset to Ohio Department of Health (ODH) to
review in a consistent manner in order to make a decision whether or not to remove a contact
advisory after a contaminated site has been cleaned up and remediated. The
recommendations include using visual inspections as the key element of information to remove
the contact advisories, create a visual inspection form, create a checklist process for contact
advisory re-evaluation for each contaminant of concern, and improve communication between
ODH and related agencies regarding sampling plans.

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Table of Contents: Page
List of Abbreviations 4
List of in Text Tables 4
Introduction 5
Literature Review 8
 Environmental Program Evaluations 9
 Issuing Contact Advisories 12
 Completed Ohio Case Studies 13
 Remaining Contact Advisories 22
 Contaminants of Concern 23
 Ongoing Remediation and Re-evaluation Case Study 25
 Remediation Standards 29
Agency/Organization Description 32
Evaluation Design 34
Methods 39
Ethics 42
Results 42
Discussion and Recommendations 50
References 58
Appendices 62

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List of Abbreviations:
ASTDR Agency for Toxic Substances and Disease Registry
DERR Ohio EPA Division of Environmental Response and Revitalization
DSW Ohio EPA Division of Surface Water
NPL National Priorities List
ODH Ohio Department of Health
Ohio EPA Ohio Environmental Protection Agency
PAHs Polycyclic Aromatic Hydrocarbons
PCBs Polychlorinated biphenyls
USACE United States Army Corp of Engineers
U.S. EPA United States Environmental Protection Agency
USGS United States Geological Survey
List of in-Text Tables: Page
Table 1. Current contact advisories in the State of Ohio 22
Table 2. Case comparison table for Black River and Middle Fork Little Beaver Creek 42
Table 3. Table display of qualitative data from two interviews of Ohio Department of Health
decision maker 44
Table 4. Survey Response to Questions from Region V states 47
Table 5. Comparison of sediment data for re-evaluation of contact advisory. Data sets from the
Little Scioto River and Black River case studies 48

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Introduction
Statement of Problem
Contact advisories have historically been posted on streams and rivers near or in areas
with egregious contamination, and currently in the State of Ohio, four contact advisories are
still in place on various rivers across the State. So far, three complete contact advisories have
been rescinded by ODH. In the past few decades, remediation efforts have aided the cleanup
and remediation of the four remaining sites, and Ohio EPA and ODH have been assessing the
sites to determine at what level of remediation the contact advisories can be lifted. The four
sites that currently have contact advisories are the following: Little Scioto River, Ottawa River,
Dicks Creek, and Mahoning River. All these sites are in different stages of remediation,
recovery, and re-evaluation, and eventually the goal for these sites is to rescind the contact
advisories post remediation and establishment.
Purpose
To formalize a more consistent approach to evaluate the removal of contact advisories,
a program evaluation was undertaken to help create more effective and efficient programs for
consistent decision making. The goal of this evaluation is to help determine which program
aspects or activities are most needed to enable Ohio Department of Health (ODH) decision
makers decide whether it is appropriate to remove the contact advisory.

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Rationale
The results of the evaluation may influences changes in operation and review of
collected data to enable a consistent review of information prior to making a decision to either
designate or remove an advisory. Indeed, the results of this evaluation are intended to aid staff
to create successfully a formal program to remove contact advisories in the future.
In supporting this evaluation, several specific aims have been identified and are listed
below, and three specific evaluation questions were created for this project. Each aimdescribes
the specific activity, and the specific outcome for each activity is defined.
Specific Aim 1: Determine how other entities (State and Federal governments, universities)
have reviewed and assessed streams with contact advisories by conducting a review of
literature related to contact advisory development and removal.
 Activity: a review of literature related to contact advisory development and
removal with associated stakeholder involvement
o Outcome: determine themes on how other entities have determined a
site is safe again for human contact
Specific Aim 2: Determine what ODH considers the most important when evaluating
information to suggest removal of a surface water contact advisory (Evaluation Question 1).
 Activity: a semi-structured interview of ODH staff responsible for making the
recommendation to remove a contact advisory
o Outcome: to interpret and identify common themes from decision maker
Specific Aim 3: Determine how other contact advisory removals have occurred in Midwestern
states

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(related to Evaluation Question 3)
 Activity: a broader survey of other program staff in Region V states who are
engaged in activities related to contact advisory assessment
o Outcome: to interpret and identify common themes from decision
makers in other Midwestern states
Specific Aim 4: Determine what pieces of each Ohio case study are consistent and which pieces
are not consistent (Evaluation Question 2)
 Activity: development of a checklist with a side-by-side comparison that visually
shows what the two cases have in common and what they don’t have in
common
o Outcome: the two case studies examine the mechanisms used in the past
to evaluate sites to remove contact advisories
Specific Aim 5: Determine the “big picture” schematic of the current process and players
involved with the contact advisory removal process
 Activity: development of a logic model to describe the overall process of contact
advisory removal
o Outcome: make recommendations to streamline process for efficiency
and consistency through the development of a flowchart
The purpose for this evaluation is to suggest recommendations to ODH to aid in the
development of a formal program. This will help ODH identify the items throughout the contact
advisory process that should be considered when making a final decision regarding the contact

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advisory. The principle audience for the evaluation is an internal audience composed of Ohio
EPA and ODH staff.
Literature Review
Background
Completing program evaluations on environmental programs is a new concept that is in
its infancy in implementation. The purposes of program evaluations are to study systematically
how well a program is working and to create more effective and efficient programs after the
results of a program evaluation are determined. Program evaluations can assist decision
makers to make better program management decisions, entertain new and innovative ideas for
programs, and continuously improve programs. Formative evaluations are intended to furnish
information that will aid in program development. The target audience for these types of
evaluations is typically program planners, administrators, or funders, due to the interest in
optimizing the program’s effectiveness (Rossi et al., 1999). Typically, the evaluator works
closely with these individuals when designing, conducting, and reporting the evaluation (Rossi
et al., 1999). The purpose of a formative evaluation is to clarify activities in order to organize
better activities and procedures for the development of a more formal program.
The type of program evaluation conducted should align with the program’s maturity and
should be driven with the program’s maturity and the purpose for conducting the evaluation
(NCEI et al., 2009). The evaluation questions should also be considered when determining the
type of program evaluation to use (NCEI et al., 2009). Completing an evaluation on a program’s
design can be helpful when a program’s goals are less defined, if only a few staff members are
charged with developing the program, or if uncertainties exist about a program’s intended

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activities (NCEI et al., 2009). In summary, the type of program evaluation chosen should align
with the program’s maturity and should be driven by the evaluator’s purpose for conducting
the evaluation and the questions to be answered (NCEI et al., 2009). Because of this program’s
infancy and complexity, a blend of a formative and process evaluation was chosen for the
evaluation design. The formative aspect of the design aids to help produce recommendations
for the creation of a program to reevaluate and remove contact advisories. The process aspect
of the design aids to further study specific features of the contact advisory process to suggest
recommendations for consistent and efficient decision making.
Environmental Program Evaluations
There are several examples of evaluations that have included the review of complex
environmental programs with many stakeholders and associated goals. One such evaluation
was completed for the Office of Water, Office of Policy, Economics and Innovation, and Total
Maximum Daily Loads (TMDL) Innovations Workgroup. TMDLs are complex calculations that are
used to determine the maximum amount of pollutants that can go into a body of water. This
evaluation assessed how TMDLs can be developed and established to make it easier for
relevant parties to implement (IEc, 2007).
To evaluate this program, evaluators collected and analyzed information by conducting
a review of literature, completing two surveys, and doing case studies on seven TMDLs (IEc,
2007). The review of literature consisted of reviewing documents related to TMDL development
and associated stakeholder involvement. One survey was directed to the U.S. EPA TMDL staff
from U.S. EPA Regions and the other survey was directed to other U.S. EPA program staff from
U.S. EPA Regions engaged in activities related to TMDLs. The surveys contained quantitative

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and qualitative questions designed to elicit insights into the nature and quality of stakeholder
participation and implementation plans during the development of the TMDLs (IEc, 2007). The
case studies on the seven TMDLs further explored how elements contributing to the
development of TMDLs impacted approaches to watershed protection (IEc, 2007). The case
studies focused on how stakeholder involvement and implementation planning drove the
outcome of the TMDL. The final report organizes the discussion of results by the six overarching
evaluation questions; qualitative and quantitative results were discussed and recommendations
were made to improve the TMDL process (IEc, 2007).
U.S. EPA’s Office of Resource Conservation and Recovery (ORCR) and the Office of
Policy’s Evaluation Support Division (ESD) conducted a program evaluation to assess the
WasteWise program. In January 1994, U.S. EPA launched WasteWise, which is an
environmental program designed to help businesses, government, and non-profit organizations
find practical methods for reducing municipal solid waste (MSW) (IEc, 2010). WasteWise
currently has over 2,000 partners representing over 50 sectors who commit to reduce and
recycle MSW and select industrial and commercial wastes (IEc, 2010). Partners include large
corporations, small- and medium-sized businesses, schools, colleges, universities, hospitals,
state and local governments, tribes, and other institutions. WasteWise uses a broad range of
approaches to encourage prevention, recycling, and reuse of waste, and the program activities
include various forms of technical assistance and recognition (IEc, 2010). The goal of the
program evaluation was to assess changes in waste management behavior at partner
organizations and explore how to improve performance measurement moving forward (IEc,
2010).

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U.S. EPA’s Office of Resource Conservation and Recovery (ORCR) and the Office of
Policy’s Evaluation Support Division (ESD) were interested in conducting an evaluation on the
WasteWise program because this program involved a variety of partners and sectors (IEc,
2010). Because of the numerous players involved, U.S. EPA contractors used a mixed methods
approach to collect information for this evaluation. Their sources of existing information
included existing data and documentation on the WasteWise program, including data and
documents related to partners’ use of WaseWise program activities and services, such as the
WasteWise website, helpline, annual conference, and awards program, peer-reviewed
literature on impacts and attribution issues associated with voluntary programs, company
websites and publications, and websites of selected U.S. EPA partnership programs (IEc, 2010).
Their new information sources included forming focus groups with representatives from a
sector participating in WasteWise and conducting surveys on select staff (IEc, 2010).
The methodology selected by the U.S. EPA contractors hired to conduct the evaluation
had its strengths and weaknesses like any study. The greatest strength was that this evaluation
included a multitude of information sources including data collection and analytical methods, a
literature review, a focus group, a survey, interviews, a best practices review, and analysis of
existing data (IEc, 2010). Using multiple sources of information to address the evaluation
questions provided the opportunity for findings from one source to validate or contradict
findings from another source (IEc, 2010). When findings are validated by more than one
information source, it results in increased confidence in the research findings. However, the
biggest limitation in this methodology was that certain sources of data could not be quantified,
such as changes in waste management attitudes and behaviors. (IEc, 2010). It was difficult for

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evaluators to determine recommendations given the complex way this program shares
information and influences behavior (IEc, 2010).
Several recommendations were provided to U.S. EPA as an outcome of this evaluation.
The evaluators recommended increasing communications from U.S. EPA to WasteWise
partners, and this recommendation came from the interviews and focus group participants (IEc,
2010). Also, in regards to communication, the evaluators recommended promoting additional
communication among the actual WasteWise partners by providing an online venue for
networking (IEc, 2010). Regarding data for the program, evaluators recommended that the
value of current tools can be bolstered by ensuring underlying data is up to date (IEc, 2010). In
summary, by using a variety of data sources in the evaluation, a variety of recommendations
could be made to encourage improvement and efficiency for this program.
Issuing Contact Advisories
Contact advisories have been historically issued to sites that have experienced egregious
contamination (www.odh.ohio.gov). A contact advisory could be issued for a variety of reasons,
but by issuing a contact advisory, the public is advised against swimming and wading in the
impacted stream (http://www.epa.ohio.gov/dsw/SurfaceWater.aspx). Typically, the area is
demarked by the presence of “No Fishing, Wading, or Swimming” signs being posed
(http://www.epa.ohio.gov/dsw/SurfaceWater.aspx). The placement of a contact advisory is
completed by ODH based on the site conditions, including exposure, and determining that
contact with the surrounding environment could harm people’s health
(http://www.epa.ohio.gov/dsw/SurfaceWater.aspx). Currently, in the State of Ohio, four

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contact advisories are currently in place on various rivers.
(http://www.epa.ohio.gov/dsw/SurfaceWater.aspx).
Completed Ohio Case Studies
A 21-year-old contact advisory on the lower five miles of the Black River was lifted by
ODH in 2004. In 1983, ODH issued a contact advisory to avoid physical contact with sediments
along a stretch of the Black River reaching from the mouth of the river in Lorain, Ohio, to a
point 6 miles upstream (Ion, 2004). The advisory was issued over concerns of PAH
contamination to the river from coking activities at the nearby USX Steel Corporation (Ion,
2004). The issuance of the advisory was further motivated by the high liver tumor rates in
brown bullhead (Icaturus nebulosus) in the stream (Ion, 2004). The coking activities at USX were
terminated in 1983 and a Consent Agreement between U.S. EPA and USS/Kobe Steel mandated
the remedial dredging of the contaminated section of river that was most grossly impacted by
the PAH discharges from the steel plant (Ion, 2004). In 1990, 50,000 cubic yards of
contaminated sediment was removed from the river bottom (Ion, 2004). Dredging of the river
occurred in 1989 and 1990 and tumor prevalence was observed in fish sampled in 1992 and
1993, possibly due to the exposure of PAHs re-suspended during dredging (Ion, 2004). Fish
were continuously monitored in the 1990s and tumor prevalence rates declined as well as PAH
concentrations found in sediments (Ion, 2004). Over time, water quality and the fish
community gradually improved. A re-evaluation of the contact advisory was requested by Ohio
EPA and the Black River Remedial Action Plan (RAP) Committee because of the improvements
in ecological health and functions of the river (Ohio EPA, 2004). A re-evaluation was completed
by ODH, which led the State to lift the contact advisory (Ion, 2004).

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The re-evaluation report examined historical data on PAH levels in the Black River
sediments, historical data on hepatic tumor presence in bullhead, and included a quantitative
risk assessment in examining the cancer risk associated with dermal exposure to carcinogenic
PAHs in sediments (Ion, 2004). ODH fully characterized the impacted region, which included a
general description of the study area, and discussed the steel facility’s operations and history of
contaminant loading (Ion, 2004). The re-evaluation also discussed a description of remedial
dredging that occurred by the U.S. Army Corps of Engineers (USACE) (Ohio EPA, 1999).
Historical sediment data was available from Ohio EPA, USACE, and the United States Geological
Service (USGS) for the years 1983, 1984, 1988, 1992, 1996, 1997, 1998, and 2001; this data was
compared and analyzed in the re-evaluation (Ion, 2004). Control sites, Ohio reference lakes
were compared against the Black River sediment data to establish a baseline for PAH
concentrations (Ion, 2004). Historical data on hepatic tumor prevalence in Black River brown
bullhead was reviewed through a review of the applicable literature (Ion, 2004). A preliminary
cancer risk assessment was calculated based on direct dermal exposure to PAH-contaminated
sediments using different exposure scenarios (Ion, 2004). Because of the nature of PAH
photoinduced toxicity, special consideration was applied when calculating dermal risk. (Ohio
EPA, 1999).
PAH concentrations in the Black River sediments declined significantly after dredging.
The first post-dredging sediment data was available in 1992 (Ohio EPA, 1999). Several locations
downstream of the steel plant’s discharge point continue to have elevated PAH sediment levels,
which could be attributed to residual contamination or continuing inputs of PAHs from the steel
plant (Ion, 2004). Even though the re-evaluation supports that PAH sediment levels in the Black

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River are the lowest measured, they are still significantly higher than the sediment PAH levels
recorded in the Ohio reference lakes (Ion, 2004). Most of the PAHs measured in the re-
evaluation were above the threshold effect level (TEL) in 2001 but below the probable effects
level (PEL) (Ion, 2004). Individual PAHs and total PAHs recorded near the steel plant’s discharge
point were recorded at levels 2 to 4 times higher than the probable effects level (PEL) (Ion,
2004).
The re-evaluation report did not discuss in detail the steel plant’s discharge or whether
the outfalls were still in use. According to the re-evaluation report, the outfalls for the steel
plant are located throughout the remediated site (Ion, 2004). Currently, there is a permit issued
to United States Steel Corporation Tubular Products Division (Permit Number 3ID00074*ED)
that uses the outfalls previous under USS/Kobe Steel
(http://www.epa.ohio.gov/dsw/permits/index.aspx). Under the permit, the permittee is
required to sample for specific PAHs and the facility is currently in compliance with these
parameters (http://www.epa.ohio.gov/dsw/permits/index.aspx).
The last year of available data for this re-evaluation was 2001, and total PAH
concentrations ranged from 0.67 to 16.4 mg/kg (Ion, 2004). Even though no PAHs were
detected at 10 of the 26 sites sampled by Ohio EPA at the time, concentrations were the
highest at RM 3.43 at 17.0 mg/kg, which is the site just downstream of the historical coking
operation discharge point at the steel plant (Ion, 2004). USACE also sampled in 2011, and the
highest concentration of PAHs was at RM 2.77, which had a concentration of 16.4 mg/kg; this
site is also immediately downstream of the same discharge point (Ion, 2004).

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The prevalence of hepatic tumors in bullhead was studied in the re-evaluation support
the removal of the contact advisory (Ion, 2004). In 1982, the data suggests that 38% of the
bullhead population had hepatic cancer and by 1987, the percentage of cancer fell to 10% (Ion,
2004). The remedial dredging began in the late 1980s and concluded in 1991, and cancer levels
were shown to increase in 1992 (Ion, 2004). This was likely due to the fish becoming exposed to
re-suspended levels of contaminants (Ion, 2004). In 1994, the fish were resampled and cancer
levels fell to the levels recorded in 1987 (Ion, 2004). The results of the last sampling campaign
in 1999 demonstrated that cancer prevalence rates were continuing to decline and were
approaching levels seen in reference populations (Ion, 2004).
Calculated cancer risks were conducted for both wading and swimming scenarios and
most risks were within the bounds of acceptable risk (Ion, 2004). Cancer risks were calculated
using several different methods: oral toxicity slope factors (IRIS method and PRG method),
dermal slope factors, and reasonable maximum exposure (RME) calculations for both wading
and swimming (Ion, 2004). Cancer risks calculated using the dermal slope factor were
approximately 5 times higher than those calculated for the oral slope factors (Ion, 2004). All
cancer risks were within the bounds of acceptable risk (range: 1.13*10-5 to 8.72*10-6) with the
exception of the RME wading scenario (risk level of 1.92*10-4) (Ion, 2004). The risk was higher
for wading than for swimming due to the higher likelihood of contact with contaminated
sediments (Ion, 2004). There was a considerable amount of uncertainty when conducting the
risk assessment due to assumptions made when calculating the dermal absorbed dose,
assumptions made underlying the use of toxicity equivalency factors, and the use of oral slope
factors for calculating risk from dermal exposures (Ion, 2004). Carcinogenic risks associated

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with dermal exposure to PAH-contaminated sediments were assessed using U.S. EPA’s risk
assessment guidance (Ion, 2004). The baseline human risk assessment process involves the
following steps: site characterization, exposure assessment, toxicity assessment, risk
characterization, and uncertainties (U.S. EPA, 2001). At the time of the re-evaluation, there
were no approved toxicity factors for cancer risks associated from dermal exposure to PAHs;
when this occurs, U.S. EPA guidance recommends the use of toxicity estimates, such as oral
slope factors, as a replacement (U.S. EPA, 2001).
To justify the removal of the contact advisory, ODH made several conclusions to prove
that PAH concentrations in Black River sediments declined considerably relative to recorded
samples in the 1980s (Ohio EPA, 2004). Routine sampling and monitoring of PAH concentrations
were recommended to support the removal of the contact advisory (Ohio EPA, 2004).
Continuous sampling was recommended to document PAH concentration trends to help
identify any new input if they should arise (Ion, 2004). The re-evaluation documents
inconsistency in the choice of sampling sites and sample collection methods when reviewing
data from all previous methods (Ion, 2004). The re-evaluation recommends that sampling
locations should be chosen in a more consistent fashion and the same sites should be sampled
for every survey (Ion, 2004). This would capture more accurate temporal comparisons of PAH
concentrations on the impacted stretch of river. The re-evaluation also recommended routine
sampling of bullhead populations to ensure the decline of hepatic cancer prevalence continues
(Ion, 2004). The re-evaluation also recommended further sampling of shoreline and near shore
sediments at likely river access points to study more in depth dermal exposure risks (Ion, 2004).
The calculated dermal absorbed dose in the re-evaluation assumes a 24 hour exposure period

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and the cancer risk can be greatly minimized by washing off sediments after being exposed
(U.S. EPA, 2001). ODH suggested that appropriate risk reduction information should be
communicated through signs and written material to express this risk reduction preventative
measure (Ion, 2004). U.S. EPA was in the process of revising its approach to risk assessment of
PAHs at the time the Black River re-evaluation was completed (Ion, 2004). Additional risk
characterizations would need to be revised when the new risk assessment information became
available. Overall declining PAH concentrations, dramatically reduced tumor prevalence in
bullhead, and acceptable risk estimates from a quantitative risk assessment suggest that a ban
on contact with Black River water and sediments was no longer required (Ion, 2004).
Another contact advisory has been recently removed on the Middle Fork of Little Beaver
Creek (MFLBC). The contact advisory was placed on the MFLBC in March 1988 by ODH due to
concerns with exposure to mirex contamination in the stream (T. Wymyslo, Director’s Journal
Entry, February 11, 2011). Mirex is a man-made compound that was used as a pesticide and the
mirex in the impacted areas of the MFLBC originated from releases from the former Nease
Chemical manufacturing facility, which is located upstream of the original advisory zone (T.
Wymyslo, Director’s Journal Entry, February 11, 2011). A series of sampling events conducted
by the Ohio EPA and consultants detected mirex in fish, sediments, and flood plain soils in the
1980s (T. Wymyslo, Director’s Journal Entry, February 11, 2011). The contact advisory was
issued due to the physical presence of the compound in a variety of media and the
uncertainties with regards to its’ ability to affect the health of people who might come into
contact with the creek (T. Wymyslo, Director’s Journal Entry, February 11, 2011). The
Endangerment Assessment used standardized risk assessment methodologies and the direct

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contact risks were shown to be below the U.S. EPA threshold (T. Wymyslo, Director’s Journal
Entry, February 11, 2011). As a result, U.S. EPA and Ohio EPA petitioned to ODH to lift the
contact advisory from the MFLBC. On the basis of U.S. EPA’s and Ohio EPA’s petition, the
contact advisory was rescinded in 2011 (T. Wymyslo, Director’s Journal Entry, February 11,
2011).
Mirex in the MFLBC is postulated to originate from the former Nease Chemical
manufacturing site in Salem, which was located at the upstream extent of the advisory zone.
The former Nease Chemical manufacturing site is a Superfund site consisting of 44 acres along
State Route 14, two and a half miles northwest of Salem on the Columbiana-Mahoning county
line. Between 1961 and 1973, Nease Chemical produced various household cleaning
compounds, fire retardants, and pesticides, some of which included mirex. The company used
ponds to treat waste water from the manufacturing process. Surface water runoff from the
ponds previously flowed into Feeder Creek, which is a tributary of the MFLBC. The ponds were
decommissioned by placement of backfill in the 1970s. Extensive and continuing investigations
of the extent of mirex in the MFLBC and surrounding areas have been undertaken under the
direction of U.S. EPA and Ohio EPA over the past several decades. These investigations have
shown that mirex can be transported in the environment with fine grained sediment material,
but consistent with its lack of solubility, mirex is not present in surface water at concentrations
that would be of concern to human health. The investigation fieldwork included sediment,
floodplain soil, surface water, and fish sampling events in 1982, 1983, 1985, 1987, 1990, 1997,
1999, and 2001. The highest detection of mirex in sediment was 2,820 ug/l at Station 12 near
the western crossing of the MFLBC by Middletown Road. A total of 21 surface water samples in

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2001 have been collected from the MFLBC and tributaries, all of which were non-detect for
mirex.
Since the contact advisory was issued in 1988, various measures have been taken at the
Site, under the direction of U.S. EPA and Ohio EPA, to mitigate potential releases of
contaminants to the MFLBC. Structures installed on-site at Nease Chemical provide for surface
water detention with sediment control outlet structures, including berms, aggregate and fabric
filters, and elevated outlet control pipes, and surface water diversions to route runoff around
the Site so that runoff does not become contaminated. Multiple fabric barriers were also
placed in Feeder Creek so that any sediment escaping the on-Site outlet control structures is
captured by this secondary mechanism (RNC, 1996). These structures have been maintained
and enhanced since 1990, including periodic inspections and sediment cleanout with
appropriate off-site disposal.
The potential risk to human health associated with mirex in the MFLBC was assessed via
a formal Endangerment Assessment (EA) that was extensively reviewed and approved by U.S.
EPA and Ohio EPA in August 2004. The EA used health-protective assumptions in assessing
potential risks associatedwithexposure to the MFLBC (Environ, 2004). Considering the fulllength
of the MFLBC within the advisory area and beyond, the risks associated with reasonable
maximum exposures (RMEs) were assessed using U.S. EPA methodologies (Environ, 2004). This
assessment concluded that possible risks from direct contact exposure to mirex in MFLBC were
acceptable, for both adults and children (Environ, 2004). The calculated risks are based on
children, whereas they would be higher than those for adults. For example, non-cancer risks due
to ingestion are based on children alone, whereas cancer risks due to ingestion are based on

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combined lifetime exposures of children and adults (Environ, 2004). Portions of the EA relevant
to the contact advisory are summarized below.
The EA included assessment of risks to both residents and recreational visitors who may
contact the creek assuming that an advisory was not in place. Direct contact exposure routes
that were evaluated included ingestion of surface water, dermal contact with surface water,
ingestion of sediment, and dermal contact with sediment (Environ, 2004). Becausemirex was not
detected in surface water, no mirex risk was calculated associated with ingestion or dermal
contact with surface water (Environ, 2004). The risk calculations, for ingestion and dermal
contact respectively, were prepared based upon U.S. EPA toxicity data, and a reasonable
maximum exposure concentration of 519 ug/kg of mirex in sediment was determined (Environ,
2004). Combining the risks from the dermal and ingestion pathways, a non-cancer hazard
quotient of 0.00354 and a cancer risk of 5.33x10-8 were calculated for mirex exposure (Environ,
2004). U.S. EPA identifies hazard quotients less than or equal to 1.0 and cancer risks not
exceeding a range of 1x10-4 to 1x10-6 as acceptable (U.S. EPA, 2001).
Extensive sampling of the sediment and surfacewater of the MFLBC has been undertaken
since the contact advisory for mirex was first issued in 1988 (Environ, 2004). Controls have also
been put in place at the Nease site to mitigate further releases to the MFLBC (RNC, 1996). These
activities, together with a formal EA, have been undertaken under the direction of U.S. EPA and
Ohio EPA. Using the risk assessmentmethodologies contained in the Agency-approved EA, which
assume that an advisory is not in place, direct contact risks within the advisory area have been
shown to be acceptable and well below U.S. EPA threshold criteria (Environ, 2004). As a result,

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it was considered that a contact advisory is no longer necessary for the MFLBC (T. Wymyslo,
Director’s Journal Entry, February 11, 2011).
Remaining Contact Advisories
In the past few decades, remediation efforts have aided the cleanup and remediation of
the four remaining sites, and ODH has been assessing the sites to determine at what level of
remediation the contact advisories can be rescinded. Remediation efforts often occur in phases,
as it is not uncommon for site investigation and cleanup to exceed tens of millions of dollars
(Bridges et al., 2006). The four sites that currently have contact advisories are the following:
Little Scioto River, Ottawa River, Dicks Creek, and Mahoning River (Table 1). All these sites are
in different stages of remediation, recovery, and re-evaluation, and eventually the goal for
these sites is to lift the contact advisories, as was done at the Black River and Middle Fork Little
Beaver Creek sites.
Table 1: Current contact advisories in the State of Ohio
Body of Water Area Under Advisory Contaminant
Dicks Creek River mile 4.1 (1 mile
downstream from North
Branch Dicks Creek),
Middletown to the Great
Miami River (Butler County)
PCBs
Little Scioto River State Route 739, near Marion
to Holland Road, near Marion
(Marion County)
PAHs
Mahoning River NW Bridge Road (Warren) to
Pennsylvania State Line
(Mahoning and Trumbull
Counties)
PAHs and PCBs
Ottawa River, Toledo Eastern Interstate 475 bridge
to Lake Erie (Lucas County)
PCBs
PAHs=polycyclic aromatic hydrocarbons
PCBs=polychlorinated biphenyls

23. 23
Source: http://www.epa.ohio.gov/dsw/fishadvisory/index.aspx#145214736-do-not-wade-or-
swim
Contaminants of Concern
As displayed in Table 1, the remaining contaminants of concern are PAHs and PCBs.
PAHs have been extensively studied in waterways. PAHs consist of hundreds of separate
chemicals and they have a variety of sources including tire particles, motor oil, vehicle exhaust,
asphalt, coal gasification, sealants, and other sources (Bridges et al., 2006). Various scientific
studies have documented detrimental impacts from PAHs on aquatic organisms. Studies in
Texas determined that loss of species and decreases in the number of streams occur when
PAHs are present (Metre et al., 2010). Crustaceans and fish metabolize PAH compounds
efficiently, whereas bivalve species, such as mussels, clams, and oysters, readily accumulate
PAHs (Garrett, 2004). However, some sensitive fish species, such as brown bull head catfish,
have been documented to display carcinogenic effects due to exposure to PAHs (Garrett, 2004).
Like most chemical interactions in the aquatic environment, interactions between aquatic
organisms and PAHs are complex. There are many factors to consider including sensitivity of
species, bioavailability of PAHs, and exposure to sunlight (Garrett, 2004). In regards to human
exposure to PAHs, the most significant effect of PAHs toxicity is cancer. There are documented
increased incidences of lung, skin, and bladder cancers associated with occupational exposure
to PAHs (USDHHS, 1996). Mammals absorb PAHs through inhalation, contact with skin, and
ingestion (USDHHS, 1996). PAHs have a low degree of acute toxicity to humans; therefore,
concerns for short term exposure are minimal (Gitipour et al., 2011).

24. 24
PAHs are classified differently according to different agencies. The International Agency
for Research on Cancer (IARC) classifies two PAHs as probable human carcinogens and three as
possible human carcinogens (USDHHS, 1996). U.S. EPA classifies seven PAHs as probable human
carcinogens, and the State of California classifies 25 PAHs as carcinogenic PAHs (U.S. EPA, n.d.).
For environmental studies, benzo(a)pyrene is often used as an environmental indicator for
PAHs (U.S. EPA, n.d.).
The other chemical of concern is PCBs, and PCBs belong to a broad family of organic
chemicals. PCBs were manufactured in the United States from 1929 until 1979, when their
manufacture was banned (PCB TMDL, 2011). PCBs were used in capacitors and transformers,
but they had a wide variety of applications such as paints, sealants, and building materials. PCBs
are highly stable and persistent in the environment, and they tend to bioaccumulate in living
organisms (PCB TMDL, 2011). PCBs are classified by U.S. EPA as probable human carcinogens
and are listed as one of U.S. EPA’s most toxic chemicals (PCB TMDL, 2011). Fish consumption is
the major pathway of exposure for humans. PCBs do not break down in the environment easily,
and they can bioaccumulate in the fatty tissues of fish and mammals (Drouillard et al., 2006).
Also, people living near hazardous waste sites may be exposed to PCBs by consuming PCB
contaminated sport fish and game animals, breathing in PCBs in the air, or by drinking PCB
contaminated well water (PCBs, n.d.).
There have been many studies regarding the effects of PCBs on human health. Some of
these exposures have investigated people exposed in the workplace and others have examined
members of the general population (PCB TMDL, 2011). There are documented cancer and non-
cancer effects regarding exposure to PCBs in humans. U.S. EPA has done extensive literature

25. 25
reviews on the carcinogenicity of PCBs in animals as part of their toxicity assessment (PCB
TMDL, 2011). The literature presents overwhelming conclusions that PCBs cause cancer in
animals. PCBs have been documented to cause non-cancer effects such as effects on the
immune system, reproductive system, nervous system, and endocrine system (PCB TMDL,
2011). In summary, PCBs have consistently shown that exposure in the human population can
lead to serious health effects (PCB TMDL, 2011).
Ongoing Remediation and Re-evaluation Case Study
Of the remaining sites with a contact advisory posted, the Little Scioto River site has
been extensively studied by various organizations and agencies. The Little Scioto River is
located in Marion County and the Little Scioto River site encompasses approximately 8.5 river
miles of the Little Scioto River, 1.5 miles of North Rockswale Ditch (NRD), and 2.2 miles of
Rockswale Ditch (HAS, 2012). The section of the Little Scioto River site begins at the State Route
309 bridge and extends to the confluence with the Scioto River at Green Camp, Ohio (HAS,
2012). The Little Scioto River is unrestricted and can be accessed from farm fields, bridges,
recreation areas, and wildlife areas (HAS, 2012).
Sediments are contaminated as a result of historic discharges to NRD and the Little
Scioto River from the former Baker Wood Preserving/Creosoting (BWC) site. The BWC site is
located at the northwest corner of Holland Road and Kenton Street (State Route 309) Marion,
Ohio (HAS, 2012). The BWC site is approximately ½ mile northwest of downtown Marion. The
former BWC site operated as a preserver of lumber products in Marion from approximately
1890 through the late 1960s (HAS, 2012). ODH, acting as Ohio EPA’s predecessor, first cited

26. 26
BWC as a contributor of contamination to surface water on September 4, 1946 (HAS, 2012).
ODH indicated in a letter on December 4, 1946 that coal-tar creosote was being discharged
from the BWC site directly to the combined sewers that drain into NRD and the Little Scioto
River (HAS, 2012). BWC was ordered to install a waste treatment system, but the treatment
system was not put in place until 1953 (HAS, 2012). BWC ceased operations sometime in the
late 1960s (HAS, 2012).
Sediment samples were collected from the Little Scioto River and Scioto River by Ohio
EPA in 1988 (Ohio EPA, 2008a). These samples were collected to assess levels of contaminants
present in stream sediments around the area of study (Ohio EPA, 2008a). In October 1991, Ohio
EPA conducted an investigation of the BWC site to determine whether hazardous substances
existed on the property and if they were migrating off the site (Ohio EPA, 2008a). The
investigation revealed that polycyclic aromatic hydrocarbons (PAHs) were present on the
property, yet it was undetermined at the time whether PAHs were migrating off the property
(Ohio EPA, 2008a). From August 1992 to February 1993, Ohio EPA conducted a biological
community, fish tissue, biomarker, sediment, and surface water sampling survey of the Little
Scioto River (Ohio EPA, 2008a). Conclusions from this investigation determined severe
degradation was present in a four mile stretch of the Little Scioto River, a ½ mile portion of
NRD, Rockswale Ditch, and a smaller portion on Columbia Ditch (Ohio EPA, 2008a). On March
20, 1992, ODH issued a contact advisory against swimming, wading, and eating fish caught in a
four mile length of the Little Scioto River, west of the city of Marion from Holland Road south to
the State Route 739 bridge (HAS, 2012).

27. 27
Ohio EPA Division of Surface Water issued a second investigation report in 1998, in
which sediment sampling results collected during the 1998 event for the Little Scioto River
confirmed the previous 1992 results (Ohio EPA, 2008a). The comparison of the 1992 and 1998
data results demonstrated no improvement in the sediment quality of the lower section of the
Little Scioto River (Ohio EPA, 2008a). In 1999, U.S. EPA initiated removal activities at BWC site
(Ohio EPA, 2008a). A total of 3,565 tons of creosote contaminated soil was excavated from the
site and disposed; an additional 3,000 tons of contaminated soil was excavated from areas east
and northeast of the direct site (Ohio EPA, 2008a). U.S. EPA installed five shallow groundwater
monitoring wells, and in September 2002, an additional four wells were installed deeper in the
limestone bedrock (Ohio EPA, 2008a). In 2003, an Expanded Site Inspection was completed and
it concluded that the direct BWC site was no longer posing as a threat to the Little Scioto River
(Ohio EPA, 2008a). The groundwater analysis from the monitoring wells demonstrated that the
creosote contaminants were present in very low concentrations in the shallow ground water at
the site (Ohio EPA, 2008a).
From 1999 to 2000, U.S. EPA focused its efforts on conducting a removal site
assessment for the Little Scioto River and NRD for the removal of creosote contaminants
suspected to be from the BWC site (Ohio EPA, 2008a). Their study indicated that four miles of
the Little Scioto River and ½ mile of NRD were contaminated with creosote (Ohio EPA, 2008a). A
project funded by the Coast Guard Inland Spill Fund initiated removal of contaminated
sediments, approximately 48,565 tons, from the BWC site, 2,800 linear feet of the NRD, and
2,900 linear feet of the Little Scioto River from June to December 2002 (Ohio EPA, 2008a). In

28. 28
2006, a project funded by Ohio EPA and U.S. EPA removed an additional 36,115 tons (2,800
linear feet) of contaminated sediments from the Little Scioto River (Ohio EPA, 2008a).
In 2007, a Site Inspection (SI) for the Little Scioto River was finalized by Ohio EPA under
cooperative agreement with U.S. EPA Region V (Ohio EPA, 2008a). This work was performed to
determine if the remainder of the contaminated area could be added to the National Priorities
List (NPL) (Ohio EPA, 2008a). It was determined that un-remediated portions of the Little Scioto
River still pose a substantial threat to human health and the environment (U.S. EPA, 2009). The
Little Scioto River site was listed as final on the NPL in September 2009 (U.S. EPA, 2009).
In February 2012, U.S. EPA completed follow-up data collection at the site. The results of
these sampling events were compiled into a remedial investigation (RI) report (HAS, 2012). The
2012 results confirmed that PAHs from the former Baker Wood Creosoting site on Holland Road
are still present in the river (Meier et al., 2013). As part of the RI report, U.S. EPA returned to
the Baker Wood property to update information regarding soil and groundwater samples (HAS,
2012). Results from these samples show that further cleanup will be needed because
contaminated soil, groundwater, and source materials remain onsite (Meier et al., 2013). U.S.
EPA is currently working on a feasibility study that will be completed in the near future (HAS,
2012). The results from this study will present a recommended cleanup plan that will be
reviewed for public comment and review (HAS, 2012). In conclusion, U.S. EPA postulates that
previous cleanup attempts removed the immediate Challenges of damage to the environment
and public health, but additional information should be collected to determine the extent of
contamination and its’ effect on the river systems (HAS, 2012).

29. 29
U.S. EPA is currently working to determine if there are human exposures to
contaminants at this site (HAS, 2012). Currently, the Little Scioto River site is considered to have
“insufficient data to determine human exposure control status” because U.S. EPA is still
reviewing validated data from the recent sampling events to complete a baseline risk
assessment (HAS, 2012). Currently, potentially unacceptable human exposures may result due
to recreational use near the site (HAS, 2012). ODNR recently created a bike trail, the Marion
Tallgrass Trail, adjacent to the contaminated portion of the river at RM 6.5, and the trail has
areas for people to dismount their bikes and wade into the river (HAS, 2012). The trail is under
construction, with approximately 2 miles of trail already completed (HAS, 2012). The trail will
eventually stretch 12 miles, from the trailhead site at 2093 Holland Road, just west of Marion,
to the Hardin County line (HAS, 2012).
Remediation Standards
Remediation consists of a series of objectives: development of remediation objectives,
characterization of the potential challenges of a pollutant to human health, identification of the
potential remediation alternatives that may be applied to the site, evaluation of identified
remediation alternatives, and establishing cleanup actions (Miller et al., 2007). For every
contaminated site where some action is necessary, a concentration must be defined above a
specified standard for the risks to be considered unacceptable (Miller et al., 2007). The nature
and magnitude of risks in regards to soil contamination are dependent on the site specific
conditions (Bridges et al., 2006).

30. 30
Selecting a remediation standard is usually based on one or more criteria. The most
frequently used criteria include geochemical background levels, health or risk based standards,
site specific human or ecosystem risk assessments, levels achievable by best available
technologies, and soil extraction and leaching tests (Miller et al., 2007). The use of background
standards cleans sites up where contaminate concentrations are being returned to conditions
that existed prior to the release of the substance in the river system(Miller et al., 2007). Many
favor a conservative approach to remediate a site, in which all the contaminants released into
the river are extracted; however, this is impractical in many cases (Miller et al., 2007). It pushes
the limits of current technology, and it adds significantly to the time and costs of cleanup while
only providing minimal additional benefits for human health (Miller et al., 2007). Using health
or risk based methods represent a single value that may be applied from one site to another
(Miller et al., 2007). A site would be cleaned up to this value, but established standards often
vary between regulatory bodies (Miller et al., 2007). This method does not consider the unique
aspects of the site which may be important when assessing the effects of the contaminant on
human health (Miller et al., 2007). Site specific risk assessments looks at a site more specifically
to determine the extent to which a contaminant threatens human or ecological health (Miller
et al., 2007). This method often involves a toxicity assessment and an exposure assessment,
and it tends to be very cost effective (Miller et al., 2007). Soil extraction and leaching tests were
originally designed for waste disposed in landfills, and these tests assess the potential mobility
of contaminants (Miller et al., 2007). This analysis is very costly and may only apply to very
specific sites and parameters (Miller et al., 2007). Establishing a standard based on contaminant
levels that are achievable by using the best technologies is rarely done due to its limited

31. 31
applicability (Miller et al., 2007). Establishing an effective clean up level often uses a blend of
these techniques and it is established by the goal of the remediation (Miller et al., 2007).
The goal of completing a risk assessment on a contaminated site should be to inform
decision makers about the pathways of exposure, identify human and animal populations at
risk, and determine the risks with implementing different engineering practices to remedy the
contamination (Bridges et al., 2006). One study suggests that the use of adaptive management
would be the best alternative to calculate formally risk and remediate at a site. This author
suggests that adaptive management emphasizes the role of performance monitoring and uses
the results of monitoring to make adjustments in management and remediation actions over
time (Bridges et al., 2006). This method helps account for some of the uncertainty of a
traditional risk assessment process where data is collected and analyzed, and a site is
remediated from that process (Bridges et al., 2006). Adaptive management practices allow for
more flexibility in remediation and may be a good tool for sites that take decades to recover
(Bridges et al., 2006).
When examining soil and groundwater contamination at the Tehran Oil Refinery site in
Iran, researchers evaluated a cleanup level based on U.S. EPA guidelines for PAHs (Gitipour et
al., 2011). The cleanup level was established from accidental ingestion of contaminated soils.
When completing the site assessment, areas chosen for remediation were selected based on
the soil analysis results and whether the area had a PAHs concentration higher than the
cleanup standards (Gitipour et al., 2011). In accordance to the U.S. EPA guidelines, the cleanup
level was determined by an equation that included target cancer risk level, weight of the

32. 32
average person, average time, exposure frequency, exposure duration, contact rate, and cancer
slope factor (U.S. EPA, 1998). Human cancer risks related to PAHs tend to be evaluated
internationally by the use of benzo(a)pyrene relative potencies because the carcinogenicity of
benzo(a)pyrene is well understood (Crane, 2013). Even though there are consistent procedures
for calculating benzo(a)pyrene equivalents, public health and environmental health agencies
from different jurisdictions develop their own guidelines based on different exposure scenarios
(Crane, 2013).
Agency/Organization Description
ODH, through the Bureau of Environmental Health, has the final decision making
authority for removing contact advisories. However, many other agencies and organizations are
involved with the whole process. Below is a very basic schematic describing the roles of the
various organizations and how they are relevant to ODH’s assessment of the contact advisory
removal process.

33. 33
Figure 1. Schematic depicting the relationship between several state and federal agencies.
Contact advisory removals involve a coordinated response from multiple agencies and
organizations. ODH Bureau of Environmental Health is the final decision maker, and ODH works
closely with ASTDR, U.S. EPA, and Ohio EPA to obtain information and funding necessary to
complete assessments and evaluate the contact advisory. The mission of the section at ODH
that completes the assessments and evaluations for the contact advisories is to serve the public
through responsive public health actions and prevent harmful exposures.
Ohio EPA provides technical information to ODH including water quality information,
biological information, and remediation information. This information could include sampling,
results and analysis, and conclusions and recommendations. Ohio EPA may have consultants
that also acquire information related to the contact advisory. U.S. EPA provides technical
information as well as funding and enforcement to support the remediation efforts required to
Ohio
Department
of Health
(decision
maker)
Ohio EPAU.S. EPA
Funding
ASTDR
DSW
DERR
Consultants
WQ/Biological
info
Remediation
info
Enforcement
Consent
Order for
cleanup
Superfund
NPL
Funding

34. 34
clean up contaminated sites. The areas that currently have contact advisories posted are either
involved in the Superfund program, in enforcement, or both.
Research/Evaluation Design
Non-experimental designs are best suited for answering evaluation questions for
formative and process evaluations (NECI et al., 2009). This evaluation was designed to be a
formative evaluation to aid in the development and design of a program. Non-experimental
designs do not typically include comparison groups. Instead, this design focuses on measuring
various elements of a logic model and describing these elements, rather than correlating them
to other elements in the logic model. This type of design can yield qualitative or quantitative
data, and both types of data were used for this evaluation.
This formative evaluation involves a mixed methods approach to collect information for
the evaluation. The sources of existing information include existing data and reports, peer-
reviewed literature on impacts of contamination and remediation efforts, risk assessment
documents, and agency website and publications. New information sources include in-depth
interviews and a broader survey on selected staff pertinent to this program. The results from
this evaluation will be an asset to ODH to consistently review criteria to make a decision
whether or not to remove a contact advisory after a contaminated site has been cleaned up
and remediated.
The purpose for this evaluation is to suggest recommendations to ODH to aid in the
development of a formal program. This will help ODH identify the items throughout the contact
advisory process that should be considered when making a final decision regarding the contact

35. 35
advisory. The principle audience for the project results will be an internal audience composed
of Ohio EPA and ODH staff.
The following evaluation questions and designs were studied:
1. What elements of information are the most important for effective review and
recommendation of removal of a contact advisory? (program objectives question)
Method to Answer Question: A semi-structured interview with ODH staff was completed to aid
ranking the utility of various elements of information needed to make a determination. Data
collection was qualitative and the focus of the interview was to identify and interpret common
and recurrent themes. The purpose of the interview was to fully understand the decision
makers’ experiences and impressions of the process. A broader survey was administered to the
additional staff involved with aspects of decision making in this process for other Region V
states.
Threats to Validity: Interviews produce results that may be hard to compare against other
types of data or additional interviews that may be completed in the future. Interviews can also
produce bias responses based on the interviewer’s technique. Another issue is that the
interviewee may have difficultly recalling information or the interviewee may recall inaccurate
information. This is a valid issue for this evaluation since the timeframe for reviewing,
remediating, evaluating, and removing contact advisories may take decades. In addition, there
are very few people involved with this process, so the sample size for the broader survey is
small. Self-selection bias is a concern because the survey participants have a choice as to
whether they would like to participate.

36. 36
Solutions for Future Studies: The best solution to address these biases would be to increase
the number of people included in the survey and the interview process. Once the program is
developed, more people may be involved with various aspects of the program. A follow up
survey could be beneficial to capture more data to improve the program in the future.
2. How does variation in the availability, quality, and analysis of data influence the ODH
evaluation process for removal of past advisories? (program organization question)
Method to Answer Question: The two case studies have been compared to examine what
factors were used to remove contact advisories in the past. The overall processes for the
completed case studies (Middle Fork Little Beaver Creek and the Black River) have been
compared against each other in a case study comparison table. Specifically, the sources of data
collected, sampling methods, risk assessment determinations, timelines for remediation and re-
evaluation, and time/resource constraints for each case study were compared against each
other. A document objectives table has been prepared to compare the two case studies. The
purpose of this exercise was to provide a comprehensive look at the elements of the entire
program and to provide a full depiction of the program operation.
Threats to Validity: Case studies are very time consuming and they have difficulty capturing a
broader view of the elements fundamental to a program. These particular case studies also
dealt solely with existing data; no new data was generated. The existing data in itself may have
separate biases, but the evaluator has no control on these biases.
Solutions for Future Studies: As more contact advisories are removed and more cases are
complete, future case studies can focus on one or two elements in more detail, rather than try
to capture the whole picture through a broad view. This practice will aid in analyzing specific

37. 37
processes to adjust and improve them. This practice will also reduce the amount of time
needed to analyze each case study.
3. What is the most effective way for Ohio EPA and other partners to provide sufficient
environmental data related to sediments for remediation measurement and evaluation
purposes? (program effectiveness question)
Method to Answer Question: ODH has expressed interest in dermal exposure to sediments.
This was determined through a study plan meeting to design the evaluation. Sediment data was
collected and analyzed in the past for all the sites that had or currently have contact advisories
in place. The data used was from the Black River case study and the Little Scioto River case
study since these cases concern the same contaminant (PAHs). The last data set before the re-
evaluation was used to determine if similar metrics were evaluated to lift the advisory. The
purpose of the data analysis was to yield information useful for accountability purposes.
Threats to Validity: The largest threat of validity is the assumption that the quality of data is
ensured. The quality of data collected is not under the control of the evaluator since it was
collected in the past. The sizes of samples, methods, and sampling locations are not in the
evaluator’s control. However, this threat is also something the evaluator would like to know for
future recommendations. There may be a threat where the variable was measured differently
between the two groups.
Solutions for Future Studies: Gathering a larger sample size will enable the evaluator to control
instrumentation bias through the developing subgroups of data. In addition, a larger sample
may enable the evaluator to draw a random sample from groups of data to further analyze the
data.

38. 38
A logic model was developed to capture the relationship between the program’s
activities and the desired result (NECI e al., 2009). A logic model is a diagramand text that has
seven basic elements: resources/inputs, activities, outputs, target decision makers, short term
outcomes, intermediate term outcomes, and long term outcomes (NECI e al., 2009). Resources
and inputs include what is needed to run the program (NECI e al., 2009). Activities include what
the program does and outputs focus more specifically on what products and services the
program produces (NECI e al., 2009). The target decision makers include groups or individuals
that the program aims to affect (NECI e al., 2009). The three tiers of outcomes have different
meanings: short term outcomes depict changes in decision makers’ knowledge, attitudes, or
skills, intermediate term outcomes depict changes in target decision makers’ behavior,
practices, or decisions, and long term outcomes depict changes in public health and/or the
environment as a result of the program (NECI e al., 2009). Also included in this logic model are
external influences beyond the program’s control that can affect how the program operates.
This logic model is essential to capture the clear picture of the current contact advisory
removal program. The logic model was used to determine which aspects of the program to
evaluate and which questions would be most useful to ask in order to improve the program.
The logic model also helps describe the logical relationship among all the program elements.
Information from the logic model was used to make recommendations to streamline process
for efficiency and consistency through the development of a flowchart tool.

39. 39
Methods
Evaluation Questions
The methods included asking specific evaluation questions aligned with the specific aims for
the project.
1. What elements of information are the most important for effective review and
recommendation of removal of a contact advisory? (program objectives question)
2. How does variation in the availability, quality, and analysis of data influence the ODH
evaluation process for removal of past advisories? (program organization question)
3. What is the most effective way for Ohio EPA and other partners to provide sufficient
environmental data related to sediments for remediation measurement and evaluation
purposes? (program effectiveness question)
Analysis of Case Studies
The two case studies were analyzed for the literature review portion of the project. In
addition, the methods involved review of all reports and papers available for each case. This
includes both published and internal literature. The substantive findings as well as the
methodological contributions of each paper were recorded. During the literature review
process, key elements were identified and recorded to capture the whole process of
establishing a no-contact advisory to removing a no-contact advisory. The purpose of this
portion of the project was to look at these key elements of the entire process. The dependent
variables are aspects of this case comparison portion that are subject to performance
measurement; these are defined as “Items” in the case comparison table. The measured
aspects that caused an observed change are recorded in each column for the separate cases

40. 40
and these have been coded as qualitative data. The purpose of creating this table was to make
comparisons between the two completed cases and to identify any patterns that require
further investigation.
Interviews
Two separate interviews were conducted with ODH staff. The first interview was
conducted April 15, 2015, and this interview had specific questions to be answered, but was
structured in a more informal manner. A semi-structured interview with ODH staff was
completed July 8, 2015. The interview questions for this interview were categorized to capture
information for the whole contact advisory process. The variables of interest were to capture
the experiences and impressions of the current process from the perspective of the ODH staff
decision maker. Hard copies of the questions were brought to both interviews and answers to
the questions were recorded via note taking. Once the two interviews were complete, the data
was processed and recorded immediately via typed detailed notes. These notes can be found in
the appendix of this report.
Upon initial review of the data, the data was reviewed for themes and patterns that
were exhibited. For the qualitative data to be analyzable, it was grouped into meaningful
categories based on the themes of the questions. Once the questions were categorized, a
content analysis was conducted for the answers of each question. During the content analysis,
the data was coded for certain content pieces, patterns in the answers were identified, and
meanings to the patterns were determined. This type of coding was done by going through all
the text and labeling works and phrases that related to the questions of interest. After

41. 41
identifying content patterns, the data was compressed into a table display that aids in
identifying patterns and relationships within the groups of data.
Survey
A two question survey was prepared and emailed to correspondents in Minnesota,
Illinois, Indiana, Michigan, and Wisconsin. These states are the other Region V states that are
under the same federal jurisdiction as Ohio. These states also have similar hydrological features
in streams that are similar to the streams in Ohio, and therefore may be evaluated for similar
characteristics. The survey targeted the decision maker equivalent for the other states. The
survey consisted of a series of yes or no questions as well as an open ended subset of questions
if they applied to the state. The respondents were given two weeks to respond to the survey.
The purpose of the survey was to document common themes in establishing and removing
contact advisories. The data was compressed into a table display to identify patterns between
the states.
Sediment Data Analysis
Data from sediment samples was collected through past reports for the following cases:
Little Scioto River and the Black River. The last data set before the re-evaluation was used to
determine if similar metrics were evaluated to support removing the contact advisory. The data
set from the Little Scioto River was collected in 2007 and the data set from the Black River was
collected in 2004. The data was collected from the sites at each study area that historically had
the most egregious contamination as defined by Ohio EPA. Both sites had been remediated at
these locations and the data sets are post-remediation data. The data sets all concern the same

42. 42
contaminant, PAHs, and the data is paired by parameter, specifically the chemical compound
measured. Both data sets included collecting sediment samples via surficial samples; these
samples are collected from 0-4 inches from the surface of the stream bed. The raw data is
attached to the appendix of this report. Our measurement variable is the sediment
concentration, measured in ug/kg. Our nominal values are the sites, Little Scioto River and Black
River. The purpose was to compare the two different measurements that have been applied to
the same subjects, chemical compounds of PAHs. This evaluation is concerned with the
differences in the two sets of measurements.
Ethics
Verbal consent was received from the ODH interviewee to conduct the interviews and
create this document. This document created is intended for internal and interagency
distribution and will not be published in external publications or media. Advice regarding this
project’s need for review was obtained by Dr. Elizabeth Klein. Upon her review of the project,
she believed that the project proposal did not need to undergo review by the OSU Institutional
Review Board.
Results
Case Study
The two case studies have been compared to examine what factors were used to
remove contact advisories in the past. These cases are discussed in detail in the literature
review section of the report. The overall processes for the completed case studies (Middle Fork
Little Beaver Creek and the Black River) have been compared against each other in the case
study comparison table below. Similar themes have been identified, but there are some key

43. 43
differences when comparing how the no-contact advisories were removed. The most significant
difference between the two cases is that remediation of the contaminants occurred in one
case, Black River, but not the other case, Middle Fork Little Beaver Creek. This difference
caused a completely different rationale when reviewing information to re-evaluate to remove
the no-contact advisory. The end result of both cases was to remove the no-contact advisory
through a Director’s Journal entry.
Table 2. Case comparison table for Black River and Middle Fork Little BeaverCreek.
Item Black River Middle Fork Little Beaver Creek
Contact AdvisoryIssued?  Yes
1983
 Yes
1988
Under whatconditionswasthe
advisoryplaced?
Egregiouscontamination
throughvisual observation
inspection.
Visual observationinspection
and unknownhealtheffectsof
contaminant.
Contaminantof concern PAHs Mirex
Source of contamination
identified?
 Yes
CokingoperationsatUSX Steel
Corporation
 Yes
ReleasesfromNease Chemical
Has the source of
contaminationbe rectified?
 Yes
1983 ConsentOrderto cease
cokingoperations
 Yes
Controlsputin place at site to
preventfurtherreleasesof
mirex
Mediaof contamination
identified?
 Yes
sediments,fish
 Yes
Sediments,floodplainsoils,
surface water,fish
Ecological impactsof
contaminationidentified?
 Yes
Tumor prevalence inbullhead
No
Samplescollectedonmediaof
concern?
 Yes
Sedimentsandfish(tumor
identification)
 Yes
Sediments,floodplainsoils,
surface water(nodetect),fish
How manysamplingevents
afterthe contact advisorywas
postedbutbefore re-
evaluation?
8
1983, 1984, 1988, 1992, 1997,
1998, 2001
4
1990, 1997, 1999, 2001
Control sites forcontaminantof
concern?
 Yes
Ohioreference lakes
No
Didremediationfor
contaminationoccur?
 Yes
Dredgingactivitiestoremove
sediments
No

44. 44
Toxicitytestingpost-
remediation?
 Yes N/A
Remediationoccurredforthe
whole advisoryarea?
No
~RMs 2.5-3.7 alongthe steel
mill property
N/A
How manysamplingevents
occurredbefore remediation?
3 N/A
How manysamplingevents
occurredafter remediation?
5 N/A
Visual observationinspection
occurredas part of ODH’s re-
evaluation?
 Yes No
Reportpreparedforre-
evaluation?
 Yes
2004 JohnIon Report
 Yes
2004 Endangerment
Assessment
Who preparedit? Master’sstudentforODH Nease Chemical’sconsultants
for OhioEPA and U.S. EPA
Cause for contact advisoryre-
evaluation
RequestfromOhioEPA and
Black RiverRemedialAction
Plangroup
Pressure fromOhioEPA and
U.S. EPA due to a new toxicity
standardfor mirex
Was the contact advisory
formallyrescindedbya
Director’sJournal entry?
 Yes  Yes
Itemsconsideredforre-
evaluation
 Historical dataon PAH
levelsin sediments
 Historical dataon
hepatictumorpresence
inbullhead
 Quantitative risk
assessment:adjusted
for potential dermal
exposure
 Visual observation
inspection
 New toxicity
informationfor
chemical of concernfor
sedimentexposure
Outside influencesfordecision? Minimal
 OhioEPA and Black
RiverRAP
High
 Political pressurefrom
otheragencies
Interview
Below is table display of the categories, questions, and content patterns identified via
the two interviews conducted with the ODH decision maker. The data has been arranged to
assist in identifying systematic patterns and interrelationships across content. The goal of this

45. 45
aspect of the evaluation was to determine what ODH considered most important when
evaluating information to suggest removal of a contact advisory. The results of the data analysis
are described in the table below.
Table 3. Table display of qualitative data from two interviews of Ohio Department of Health
decision maker.
Categoriesfor
Questions
Questions Contentanalysis
EstablishingNo-
Contact Advisory
 Have both contact
advisoriesthathave been
removedbeen
memorializedthrougha
journalizedactionatODH?
 Yes
 How wasa site identifiedas
not beingsafe forhuman
contact?
 OhioEPA Water Quality
Assessments
 How doesODH determine
the lengthof stream
coveredbythe no-contact
advisory?
 OhioEPA Water Quality
Assessments
Site Cleanup  How involvedisODHinthe
site assessmentand
remediationprocess
conductedbyOEPA,U.S.
EPA,and others?
 HealthConsultationsto
determine contaminantsof
concernand pathwaysof
exposure
 Supportotheragencieswhen
needed
Re-evaluation(holistic)  What documentsdoesODH
use to re-evaluate sitesto
determine if exposure is
safe for contact?
 Visual observation inspection
 Pre- and post-remediation
data
 What criteriaare usedto
assessif the contact
advisorycan be lifted?
 Observationof noegregious
contamination
 Notbasedon science
 What elementsof
informationare most
importantforeffective
review and
recommendationof
 Proof of ceasingsource of
discharge
 Proof of remediationactivity
 Pre- and post-remediation
samplingactivity
 Visual observationinspection

46. 46
removal of a contact
advisory?
 What piecesof information
are mostimportantwhen
makinga decisiontore-
evaluate andpotentially
removal a contact advisory?
 Source cleanupreports
 Visual observationinspection
notes
 How doesODH determine
whentore-evaluate a
contact advisory?
 RequestedbyOhioEPA
 From yourperspective,
whatchallengesorconcerns
do youhave withthe
currentprocess?
 Each site isunique
 Tough to standardize aprocess
 From yourperspective,
whatcan be done to
enhance thisprocessinthe
future?
 Same contaminantof
concern=same processof re-
evaluation
Re-evaluation(data
collection)
 How doesvariationinthe
availability,quality,and
analysisof datainfluence
your decisionto
remove/keepacontact
advisoryinplace?
 Same metricsthat established
for the contact advisoryshould
be usedwhenevaluatingto
remove it
 Metric= visual observation
inspection
 What isODH lookingfor
whenconductingavisual
observationinspection?
 Potential fordermal exposure
to sediments
 Smells
 Is there a formal inspection
formusedfor the visual
observationinspection?
 No
 Whencompletingavisual
observationinspection,
doesODH coverthe whole
stretchof the rivercovered
by the contact advisory?
 Yes

47. 47
 Are background(control)
sitesconsideredwhen
evaluatingsurface wateror
soil sedimentsamples?
 Notusually
 If backgroundsitesare
considered,how are they
established?
 Notsure
 OhioEPA establishedthese in
the past
 What specificpiecesof
informationare most
importantforODH to make
a decision?
 Y/N issite isgrossly
contaminated
 Determinedviavisual
inspection
 Have the same piecesof
informationbeenused
whenremovingaprevious
contact advisory?
 Yes
Site specific  DoesODH have a copyof
the Endangerment
Assessment(2004 Environ)
that wasusedfor the
MFLBC contact advisory
removal?
 Yes
 Political pressureandchanges
inacceptable toxicitylevels
causedremoval of advisory
 What happenedwiththe
OttawaRivercontact
advisory?
 Miscommunicationof what
stretchof riverthe contact
advisorycovers
 I-475 crossesthe rivertwice
 Contact advisorywasoriginally
postedbymistake forpart of
the river

48. 48
Survey
A survey was created and sent to the Region V states with a two week request for a
response. Below summarizes the results and findings of the survey.
Table 4. Survey Response to Questions from Region V states.
Question1 Has your state everhadany contact advisoriesinplace for
streams?
Answers NO: 3 YES: 2
Question2 Has your state everremovedand/orrescindedany contact
advisories?
Answers NO: 3 YES: 2
On the basis of the results of the survey, only two states have placed a contact advisory on a
stream: Michigan and Wisconsin.
Michigan has had one contact advisory and it was established after a massive million
gallon crude oil spill to Talmadge Creek and the Kalamazoo River in 2010. The contact advisory
was placed because there was an acute physical contact hazard and the oil spilled was emitting
levels of volatile organic compounds that presented an inhalation risk. There were also physical
hazards to recreational users as cleanup activities on the spill occurred. The State of Michigan
has also rescinded this contact advisory. It was rescinded when all levels of air contaminants
from the volatile organic compounds had fallen below health based screening values and all
physical hazards from the cleanup activity were mitigated. This spill was not under a court order
for cleanup and it was not considered a Superfund site.
Wisconsin has placed recommendations to not wade/swim or play in streams
contaminated with PCBs and PAHs above U.S. EPA recommended values. They do not

49. 49
necessarily call these contact advisories and they do not track these recommendations.
Wisconsin does not know exactly how many there are or how many there have been, but at
least two sites were identified in the survey. These two sites were considered to be Superfund
sites. For the re-evaluation steps after the remediation phase, Wisconsin will review any new
data to determine if the stream is safe for contact. However, these re-evaluations are not
formally tracked, so the respondent did not know how many have been removed or rescinded.
Sediment Data Analysis
In the table below are the results of the data analysis. RM6.5 is the data set from the
Little Scioto River and RM 3.43 is the data set from the Black River. The two data sets have been
compared against each other and against individual relative potency factors for the individual
PAHs. The relative potency values are estimates of the potency compared to benzo(a)pyrene,
which has a base value of 1.0.
Table 5. Comparison of sediment data for re-evaluation of contact advisory. Data sets from
the Little Scioto River and Black Rivercase studies.
Parameter RM 6.5 LSR
(ug/kg)
RM 3.43 BR
(ug/kg)
Relative Potencya,b
Total PAHs 239 17000 n/a
Anthracene 250 900 0.01 b
Benz(a)anthracene 250 1520 0.1 a
Benzo(a)pyrene 250 1710 1 a, b
Chrysene 77 1750 0.001 a
Dibenz(a,h)anthracene 250 900 1 a
Fluoranthene 250 3480 0.001 b
Fluorene 250 900 0.001 b
Naphthalene 81 1260 0.001 b
Phenanthrene 250 1380 n/a
Pyrene 250 2730 0.001 b

50. 50
a: Estimate ofpotency relativeto benzo(a)pyrenebased on mousecarcinogenesis(U.S. EPA IRIS)
b: Toxic equivalency factor relativeto benzo(a)pyrene,taken from Nisbitand Lagoy (1992).
Discussion and Recommendations
The two case studies were analyzed to determine how the variation in the availability,
quality, and analysis of data influences the ODH process for re-evaluating and removing contact
advisories. When the contact advisories were established, they followed a similar fact pattern.
The contact advisories were established after documenting egregious contamination through
visual observation inspections. Even though the contaminants of concern were different, the
source of the contamination was controlled in both cases and similar environmental media
were impacted. Numerous sampling events occurred in both cases. When it comes to a
remediation action taking place, the two cases differ drastically.
The Black River case study had a remediation action which involved removing all the
contaminated sediments in the delineated contact advisory stream section. After the
remediation occurred, sampling was completed to create a pre- and post-remediation data set
for the site. Therefore, ODH had a lot of available information to determine if the stream was
safe again for human contact. All of this information was used to support the removal of the
contact advisory for the Black River.
In the Middle Fork Little Beaver Creek (MFLBC) case study, remediation of contaminated
sediments did not occur. The company that caused the contamination argued that there was
new toxicity data available that demonstrated that the existing levels of the contaminant of
concern were truly safe for human contact. Consultants on behalf of the company were hired to
prove this through the development of a risk assessment. ODH received a lot of pressure from

51. 51
other agencies and the company to reconsider the contact advisory and remove it from the
stream. Because of outside pressure, the contact advisory was removed despite the fact that no
remediation occurred. Even though the same end result occurred in both case studies, outside
influences altered how ODH processed the re-evaluation of the MFLBC contact advisory and
this process was vastly different than the process used in the Black River contact advisory.
o Recommendation: Outside influences on the process are items that ODH cannot
control and this dynamic is captured in the logic model. These situations will
continue to exist and cannot be controlled from an evaluation perspective.
However, these types of situations are not the norm, so a process protocol can
be developed for future contact advisories that will be undergoing the re-
evaluation process. One suggestion is to create a process protocol based on the
contaminant of concern since different factors may need to be considered for
sampling, remediation, and risk assessment. The current contact advisories in
place have two separate contaminants of concern: PAHs and PCBs. A protocol for
each contaminant could be developed and used once these sites undergo
remediation and become candidates for re-evaluation. This protocol could be
captured in a process flowchart.
The purpose of the interview portion of the project was to determine what elements of
information are the most important for effective review and recommendation of removal of a
contact advisory. Information regarding what the ODH decision maker considers the most
important when evaluating information to suggest removal of a contact advisory was captured
thoroughly in the interview process. As displayed in the results section of this report, common

52. 52
content themes were identified by the decision maker. This discussion portion will be
subdivided by the categories of questions as displayed in the results table earlier.
 Establishing the Contact Advisory: ODH relies on Ohio EPA to identify a site as being not
safe for human contact, but the contact advisory program is housed at ODH and
therefore they are responsible for establishing the contact advisory. Ohio EPA Water
Quality Reports are relied on heavily to set the stream length of the contact advisory. All
contact advisories that have been removed have been memorialized and rescinded via a
journalized action at ODH.
o Recommendations: This process is very easy to follow and standardized;
therefore, no recommendations are suggested.
 Site Clean up: ODH is involved with the site cleanup if requested by other agencies, such
as Ohio EPA or U.S. EPA. Agencies have requested assistance regarding contaminants of
concern and pathways of exposures at sites. ODH conducts these studies and
memorializes the findings in a Health Consultation report. The purpose of ODH is to
evaluate the data from a public health perspective. If the data supports egregious
contamination, a recommendation from ODH and Ohio EPA will be sent to U.S. EPA for
priority cleanup. If the data supports contamination, but it is not super egregious, a
Superfund cleanup will be recommended.
o Recommendation: How ODH defines egregious contamination is not well
defined. A reference guide to categorize differing levels of contamination could
be developed to make this process more clear.

53. 53
 Re-evaluation (holistic): Even though there have been no formal tools developed to re-
evaluate contact advisories, the contact advisories that have been removed have been
done in a consistent way. The contact advisories have been established based on ODH’s
visual inspection of a contaminated site; this is based purely on observation and not
based on scientific data. Therefore, when re-evaluating the contact advisory, ODH will
conduct a visual observation inspection to support removal of the contact advisory, and
this is the primary basis to support removal of the contact advisory. There is no formal
inspection form for this process. Analysis of secondary data, if available, has been used
to support the removal of the contact advisory. The secondary data ODH reviews
included pre- and post-remediation data pertaining to sediments, and source clean up
reports. In addition, ODH wants information on the following to support the removal of
a contact advisory: proof of ceasing the source of discharge that caused the pollution,
proof of some sort of remediation activity to remove the pollution, pre- and post-
remediation sampling data to support the removal of the pollutant, and confirming the
removal of egregious contamination by conducting a visual observation inspection.
Because each site is unique, it is difficult to standardize a procedure to re-evaluate
streams to support removal of a contact advisory. However, one way to standardize a
process would be to create a process for each contaminant of concern. For example,
ODH plans to use the process in the Black River contact advisory for supporting the
removal of the Little Scioto River contact advisory since these sites have the same
contaminant of concern.

54. 54
o Recommendation: ODH relies heavily of the visual observation inspection to
establish and remove a contact advisory. The person who has been establishing
the contact advisories and then recommending removing them has relied on his
or her memory to support the removal of the contact advisory. The development
of an inspection form would aid in standardizing how the visual observation
inspections are conducted and what parameters are evaluated during the
inspections. The idea is that this form could be used when the contact advisory is
established (pre-remediation) and when the contact advisory is being re-
evaluated for removal (post-remediation). ODH has expressed interest in
standardizing the method for removal of a contact advisory by pollutant of
concern. The remaining contact advisories have two pollutants of concern: PAHs
and PCBs. Two checklist tools could be developed to standardize the information
needed to re-evaluate the contact advisories for each of these contaminants.
 Re-evaluation (data collection): Much of the data collection is done outside of ODH. This
data is collected by a variety of agencies and groups for differing reasons. However, as
discussed earlier, ODH primarily relies on the visual observation inspection to establish
and remove the contact advisory. From their perspective, this is the basis that the
contact advisory re-evaluation should be based on.
o Recommendation: As suggested earlier, a visual observation inspection form will
aid in standardizing the procedure used to conduct a visual observation
inspection. Lines of communication could be improved between ODH in regards
to how the secondary data is collected. ODH will review the secondary data

55. 55
sources to support its recommendation to remove a contact advisory, yet some
information on how the data was collected is unclear to ODH. One way to
correct this is to keep ODH involved when the sampling plans are created;
therefore, ODH will be knowledgeable on how the sampling sites were
established and why these specific sites were selected.
 Site specific: This section was to identify scenarios that were different from how contact
advisories were normally evaluated and removed in the past. The contact advisory for
the Middle Fork Little Beaver Creek was rescinded without any remediation action. ODH
claims that there was a lot of political pressure on behalf of the company that caused
the pollution to remove the contact advisory. Consultants were hired on behalf of the
company to state that the toxicity levels of the pollutant of concern were below
dangerous thresholds and therefore the contact advisory should not be in place. This is
further discussed in the literature review. Part of the Ottawa River contact advisory was
removed because it was posted in one area by mistake when I-475 was built. This was a
miscommunication error between Ohio EPA and ODH and is considered an isolated
incident.
o Recommendation: Even if the process of re-evaluating the contact advisory can
be more standardized and consistent, there will always be factors outside of
ODH’s control that will influence the removal of contact advisories. From an
evaluation perspective, there are no recommendations for this aspect of the
process.

56. 56
The results of the survey were not surprising because the ODH decision maker that was
interviewed stated that he didn’t believe that the other Region V states had established or
rescinded contact advisories. The majority of the states that replied to survey had not
established or rescinded contact advisories.
The State of Michigan established a contact advisory based on unsafe levels of
contaminants present in the river during and immediately after the spill. When rescinding the
contact advisory, the State of Michigan used health based standards to determine if the contact
advisory should be rescinded. This was only considered after a remediation activity occurred.
Therefore, they used the same metric for establishing and removing the contact advisory. This
situation from the State of Michigan differs slightly from the current contact advisories in place
for the State of Ohio. Michigan’s situation was a short term pollution event and cleanup
occurred immediately. The examples in Ohio include long term pollution events where cleanup
occurs through some sort of long term funding plan, such as Superfund. Therefore, it may be
difficult to fairly compare the contact advisories in Ohio against the one in Michigan.
The State of Wisconsin has no formal mechanism to track contact advisories, so it is
difficult to compare their cases against the cases in Ohio. However, they have used consistent
standards to establish their contact advisories, U.S EPA values. They also use these same
standards to revise their recommendations post-remediation.
o Recommendation: The piece of information that is pertinent to this evaluation is
that both states who also have contact advisories used the same measurement
metric to remove the contact advisory that was used to establish the contact

57. 57
advisory. Even though this metric is not a visual observation inspection, Ohio can use
this information to justify the need to remove a contact advisory based on how it
was established. The Ohio contact advisories were established by ODH due to
egregious contamination observed during a visual observational inspection.
Therefore, the primary metric used to justify the removal of a contact advisory
should be a follow up visual observational inspection.
The sediment data collected was from different cases, and upon a side by side
comparison, the streams were remediated a differing concentrations of PAHs. When reviewing
relative potency values, the PAHs that have been considered the most toxic relative to the
other PAHs were not removed at a lower concentration. The concentrations of PAHs at both
sites vary post remediation.
Some limitations of this analysis include the sample size of 11 pairs of data. The
evaluation used historical data and the sample size would not under control of the evaluation.
The tests requested to collect and analyze sediment samples tend to be expensive, so the
agencies responsible for collecting and analyzing these samples only collected what was
absolutely needed. Also, different laboratories were contracted and used for these data sets
and the laboratories may have slightly different methods and reporting limits for data analysis.
Limited information was available regarding the laboratory procedures for data analysis.

58. 58
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