Concerns Regarding Onondaga Lake Bottom Sediments

in Areas Under Consideration for a Beach

on Onondaga Lake

Prepared for the Onondaga Nation

August 2018
Background:
On June 5, 2018 the Onondaga County Legislature voted to spend $440,000.00 for a
study to decide if and where a beach might be built on Onondaga Lake. $330,000.00 of
this is from a state grant and the remaining $110,000.00 will be county money; but all of
this is taxpayer money.
From the limited information that was presented to the legislature, the evaluation of
the relative safety of such a beach will be focused only on water quality and bacterial
levels. There is no mention of sediment testing or toxic chemicals.
As early as 2005, the Onondaga Nation hired dredging experts (Stratus Consulting)1
to submit comments documenting that the dredging and capping plans for the
Onondaga Lake bottom would not sufficiently protect human health or the
environment. In particular, the method of averaging contaminant risk factors to
determine where dredging would be done produced these inadequacies. Averaging the
toxicity of many chemical pollutants meant that dangerous levels of one contaminant
could be overwhelmed or hidden by particularly low levels of other contaminants at that
location. As a result, dredging was not required for all toxic and carcinogenic hot spots.
The Stratus critiques can be read online:

 http://bit.ly/StratusOnondagaLakeCritique1
 http://bit.ly/StratusOnondagaLakeCritique2
It is important to remember that the sediments throughout the lake contain varying
levels of pollution, with mercury and 26 other toxic chemicals present. Although the
remediation is described as a “Dredge and Cap” system, most of the active dredging and
cap construction was limited to the southwest basin. The bulk [at least 80%] of the
toxins were left in place under the Superfund settlement, either to be covered with the
constructed cap or, in most of the lake, to be buried over time by sediment carried into
Onondaga Lake by its tributaries. Most of this sediment comes from Onondaga Creek
and the mudboils and is deposited at the south end of the Lake. The area under
consideration for the beach is along the northeastern shore, which was not part of the
dredging and capping operation. However, throughout most of this area, one or more
contaminant was found at levels that could be toxic to animals living in the sediments
(Figure 3).

1
Stratus Consulting was the same expert retained by the EPA in its enforcement work against GE for PCB
contamination of the Hudson River, advising on the amount of dredging necessary there.

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 This document reviews what we know about sediment testing and remediation in
the area under consideration for a beach.

Key Points:
A. Inadequate sediment sampling has occurred along the northeastern shores of
Onondaga Lake. Any feasibility study for a beach on Onondaga Lake needs to
include thorough sediment sampling both onshore and offshore to allow an
accurate assessment of any contamination present.

B. All potential beach sites along the Northern shore of the lake were found to have
elevated levels of toxic chemicals in 1992 testing. Sites located near Hiawatha
Point and Bloody Brook showed elevated levels of Mercury, Cadmium and
Chromium. All locations had elevated carcinogens (SVOCs/PAHs).

C. Capping only occurred on an extremely small part of the Northern shore lakebed
(less than one acre), noted as Remediation Area F in Attachment “B”. No
dredging or capping of any nature or volume was done anywhere else along the
Northern shore.

D. Many of the potential beach areas were at risk of additional contamination after
the initial 1992 and 2000 samplings. Bloody Brook, which discharges into the
northeastern end of Onondaga Lake, was contaminated with Chromium and
Cadmium from the GE brownfield site and was only fully remediated in 2016.
Sawmill Creek, which discharges into the northwestern end of Onondaga Lake,
runs along I-90, CSX railroad tracks, and various distribution warehouses, bringing
an unknown quantity of petroleum / combustion byproducts into the Lake.

E. The Onondaga Lake Monitoring and Maintenance Plan does not include any
sediment sampling in the near-shore areas where the potential beach might be
built. Monitoring focuses on the areas that were dredged and capped in the
southeastern portions of the Lake and the deep-water areas in the middle of the
Lake. Additional, up-to-date and site-specific information about sediment
contaminant levels will only be discovered if the County conducts its own testing.

F. Willow Bay, at the Northern end of Onondaga Lake Park, is extremely close to the
Thruway. Any beach here will experience significant noise pollution.

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Figure 1: Onondaga Lake Park2, the northeast shore area of Onondaga Lake

2
Onondaga County GIS

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Technical data and previous testing near the northeast shore:
The pages that follow are Attachments which document the history of mercury
and other toxic chemical contamination on the northeast shore of Onondaga Lake.
Attachment “A” shows the most recent comprehensive human health risk
assessment data, from sampling done in 1992.
Attachment “B” documents that almost no remediation [dredging and capping]
was done in the northeast shore area.
Attachment “C” shows the levels of toxic chemicals found at sampling sites that
are shown on Attachment “B”.
Attachment “D” lists the NYS DEC’s “cleanup objectives” for these toxins, listed in
Attachment “C”.

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Attachment “A”, site toxicity of the northeastern shore area:
2002 Human Health Risk Assessment / Baseline Ecological Risk Assessment (from 1992
sampling data) show elevated levels of toxins at sampling sites (P113, S110, S105,
P93/S93). Mercury, Chromium and Cadmium are elevated at S110 and S105 to levels
above Commercial Use SCOs as well as Human Health sediment guidelines.
Sawmill Creek runs along I-90, CSX railroad tracks, and various distribution warehouses,
bringing an unknown quantity of petroleum / combustion byproducts into the lake.
Bloody Brook (not pictured, just to the South), links to the former General Electric
brownfield site that Lockheed Martin finished remediating in 2016. This site had
elevated levels of Chromium and Cadmium, which have been carried by Bloody Brook
into the lake.
Combined Sewer Overflows are all on the South end of Onondaga Lake (Onondaga
Creek / Ley Creek), though overall bacteria levels in the lake following sewage
discharges remains a concern.

Figure 2: Sediment sampling locations, North Onondaga Lake3

3
2002 Onondaga Lake Human Health Risk Assessment, TAMS Consulting

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Figure 3: Chemical Parameter of Interest (CPOI) Exceedances4

Figure 3: Red shaded areas indicate that more than one chemical exceeds the ER-L
(low effects range). Orange shaded areas indicate that one chemical exceeds the ER-L.
This map is included to illustrate the widespread presence of contaminants.

4
Onondaga Lake Proposed Plan, NYS DEC 2004

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Attachment “B”, remediation history
Remediation Area F: Only a small area of the lakebed near the proposed beach sites
was ever remediated, with a thin cap (1’ of sand). Most of the area was never touched
during the remediation process. Additional sampling in 2004-2009 only tested for
mercury concentrations.

Figure 4: Dredging and Capping Areas, North Onondaga Lake

Figure 4 indicates the area on the northern end of the lake capped as part of the
remediation process. Only a very small portion (outlined in purple just below Sawmill
Creek, Remediation Area F) of the northeastern shore was capped. No dredging
occurred at this site. Additionally, no dredging or capping of any nature or volume was
done anywhere else along the Northern shore.

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Figure 5: Mercury “Hot Spot” Levels, North Onondaga Lake5

Figure 5 is a zoomed in look at mercury contamination in the northern part of

Remediation Area F (see Figure 4). This area was flagged by 1992 sampling as being a
“hot spot” for mercury, with levels up to 15.6 mg/kg found in 2002-2009 testing. None
of this mercury was removed or dredged but the area bounded by the polygon (less
than one acre) was capped with 1’ of sand.

5
Onondaga Lake Capping, Dredging, Habitat, and Profundal Zone (SMU8) Final Design, Parsons 2012

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Attachment “C”, site toxicity data [P113/S113/S110/S105 locations in Figure 2]:
Heavy metal levels in sampling data (1992, 0-2 cm), (converted from mg/kg to ppm)
Bolded samples Exceed Residential Use Soil Cleanup Objectives.
Not Tested: “n/t” Not Detected: “n/d”
P113/S113:
Aluminum 635 ppm Antimony 3.7 ppm Arsenic 1.1 ppm
Barium 72.4 ppm Beryllium n/d Cadmium 0.35 ppm
Calcium 234,000 ppm Chromium 16.7 ppm Cobalt 1.3 ppm
Copper n/d Cyanide n/d Iron 2,520 ppm
Lead 15.7 ppm Magnesium 2,950 ppm Manganese 284 ppm
Mercury 0.17 ppm Nickel 4.8 ppm Potassium 110 ppm
Selenium n/d Silver n/d Sodium 457 ppm
Thallium 0.19 ppm Vanadium 1.8 ppm Zinc 38.9 ppm
S110:
Aluminum n/t Antimony n/t Arsenic n/t
Barium n/t Beryllium n/t Cadmium 4.0 ppm
Calcium 261,000 ppm Chromium 73.9 ppm Cobalt n/t
Copper 30.8 ppm Cyanide n/t Iron n/t
Lead 6.8 ppm Magnesium 2,640 ppm Manganese n/t
Mercury 2.2 ppm Nickel 8.6 ppm Potassium n/t
Selenium n/t Silver n/t Sodium n/t
Thallium n/t Vanadium n/t Zinc 74.5 ppm
S105:
Aluminum n/t Antimony n/t Arsenic n/t
Barium n/t Beryllium n/t Cadmium 4.6 ppm
Calcium 330,000 ppm Chromium 76.9 ppm Cobalt n/t
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 Copper 27.8 ppm Cyanide n/t Iron n/t
Lead 19.5 ppm Magnesium 2,630 ppm Manganese n/t
Mercury 1.6 ppm Nickel 7.6 ppm Potassium n/t
Selenium n/t Silver n/t Sodium n/t
Thallium n/t Vanadium n/t Zinc 77 ppm

SVOC levels in sampling data (1992, 0-2 cm) [compounds with positive results listed]:
Converted from ug/kg to ppm (1000 ug/kg = 1 ppm)
P113/S113:
Acenaphthene .041 ppm
Anthracene .230 ppm
Benzopyrene .480 ppm
Benzoperylene .130 ppm
Carbazole .020 ppm
Dibenzanthracene .062 ppm
Fluoranthene .600 ppm
Idenopyrene .150 ppm
Pyrene .750 ppm
S110:
Acenaphthene n/d
Anthracene .076 ppm
Benzopyrene .130 ppm
Benzoperylene .290 ppm
Carbazole n/t
Dibenzanthracene .071 ppm
Fluoranthene .590 ppm
Acenaphthylene .482 ppm
Benzoanthracene .490 ppm
Benzofluoranthene .550 ppm
Bis(2-ethylhexyl)phthalate .026 ppm
Chrysene .500 ppm
Dibenzofuran .018 ppm
Fluorene .082 ppm
Phenanthrene .370 ppm
Acenaphthylene n/d
Benzoanthracene .120 ppm
Benzofluoranthene .200 ppm
Bis(2-ethylhexyl)phthalate n/t
Chrysene .170 ppm
Dibenzofuran n/t
Fluorene .083 ppm

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 Idenopyrene .082 ppm
Pyrene .430 ppm
S105
Acenaphthene .630 ppm
Anthracene n/d
Benzopyrene .021 ppm
Benzoperylene .210 ppm
Carbazole n/t
Dibenzanthracene n/d
Fluoranthene .590 ppm
Idenopyrene n/d
Pyrene n/d
Phenanthrene .0260 ppm
Acenaphthylene n/d
Benzoanthracene n/d
Benzofluoranthene .041 ppm
Bis(2-ethylhexyl)phthalate n/t
Chrysene n/d
Dibenzofuran n/t
Fluorene n/d
Phenanthrene n/d

VOC levels in sampling data (1992, 0-2 cm) [compounds with positive results listed]:
Converted from ug/kg to ppm (1000 ug/kg = 1 ppm)
P113/S113:
Acetone .071 ppm
S110, S105:
Acetone n/t
Pesticide levels in sampling data (1992, 0-2 cm):
No detections of pesticides at P113/S113/S110
PCB levels in sampling data (1992, 0-2 cm):
No detections of PCBs at P113/S113/S110/S105
Above sampling data source from 1992 samples referenced in the 2002 Human Health
Risk Assessment and Ecological Risk Assessment prepared by TAMS Consulting.

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Attachment “D”, New York DEC Guidelines:
The Human Health Risk Assessment for the Onondaga Lake Bottom Subsite used
Residential Soil Cleanup Objectives (SCO) as criteria for evaluating lake and wetland
sediment contamination, “as a conservative means to evaluate direct contact with these
media.” (HHRA, p 3-3)

New York DEC Commercial Use Soil Cleanup Objectives (SCO) 6:

Arsenic 16 ppm Barium 400 ppm Beryllium 590 ppm
Cadmium 9.3 ppm Chromium 1,500 ppm Copper 270 ppm
Cyanide 27 ppm Lead 1,000 ppm Manganese 10,000 ppm
Mercury 2.8 ppm Nickel 310 ppm Selenium 1,500 ppm
Silver 1,500 ppm Zinc 10,000 ppm Acetone 500 ppm
Dibenzofuran 350 ppm Acenaphthene 500 ppm
Acenapthylene 500 ppm Anthracene 500 ppm
Benzanthracine 5.6 ppm Benzopyrene 1 ppm
Benzofluoranthene 5.6 ppm Benzoperylene 500 ppm
Chrysene 56 ppm Dibenzoanthracene 0.56 ppm
Fluoranthene 500 ppm Fluorene 500 ppm
Indenopyrene 5.6 ppm Phenanthrene 500 ppm
Pyrene 500 ppm

6
“Development of Soil Cleanup Objectives – Technical Support Document”, New York
DEC and New York Department of Health, September 2006
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New York DEC Residential Soil Cleanup Objectives (SCO) 7:
Arsenic 16 ppm Barium 350 ppm Beryllium 14 ppm
Cadmium 2.5 ppm Chromium 36 ppm Copper 270 ppm
Cyanide 27 ppm Lead 400 ppm Manganese 2000 ppm
Mercury 0.81 ppm Nickel 140 ppm Selenium 36 ppm
Silver 35 ppm Zinc 2200 ppm Acetone 100 ppm
Dibenzofuran 14 ppm Acenaphthene 100 ppm
Acenapthylene 100 ppm Anthracene 100 ppm
Benzanthracine 1 ppm Benzopyrene 1 ppm
Benzofluoranthene 1 ppm Benzoperylene 100 ppm
Chrysene 1 ppm Dibenzoanthracene 0.33 ppm
Fluoranthene 100 ppm Fluorene 100 ppm
Indenopyrene 0.5 ppm Phenanthrene 100 ppm
Pyrene 100 ppm

7
“Development of Soil Cleanup Objectives – Technical Support Document”, New York
DEC and New York Department of Health, September 2006
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