Progress report summarizing the reef fish sampling, PCB - Earthjustice
Progress report summarizing the reef fish sampling, PCB - Earthjustice
Progress report summarizing the reef fish sampling, PCB - Earthjustice
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concentrations in edible portions of such <strong>fish</strong> exceed a specified screening value”. In<br />
paragraph 15 of <strong>the</strong> EPA risk-based <strong>PCB</strong> bulk waste disposal approval document,<br />
<strong>the</strong> EPA screening level value was given as 0.020 parts per million (20 ppb) total<br />
<strong>PCB</strong>s, wet weight. This was defined as a mean value evaluated total <strong>PCB</strong> value for<br />
a minimum of 15 legal size specimens of <strong>the</strong> same targeted <strong>reef</strong> <strong>fish</strong> species caught<br />
during any given <strong>sampling</strong> round. In <strong>the</strong> same paragraph <strong>the</strong> EPA fur<strong>the</strong>r stated:<br />
“If <strong>the</strong> mean <strong>PCB</strong> concentration in any targeted <strong>fish</strong> species exceeds a screening<br />
value of 0.02 parts per million (20 ppb) total <strong>PCB</strong>s, <strong>the</strong> FWC shall initiate a Tier 2,<br />
intensive monitoring program and/or assess <strong>the</strong> need for establishing advisories as<br />
determined by EPA”. A <strong>fish</strong> consumption advisory, if warranted, would be for <strong>the</strong><br />
purpose of protecting <strong>the</strong> human health of anglers and <strong>the</strong>ir families from any<br />
unreasonable increased cancer risk due to <strong>PCB</strong> ingestion and bio-accumulation as a<br />
result of consuming <strong>fish</strong>es caught on <strong>the</strong> Oriskany Reef.<br />
The excess cancer risk from 30 years of consumption of Oriskany Reef caught <strong>fish</strong><br />
would be averaged over a 70 year period of an adult’s life. In <strong>the</strong>ir risk-based <strong>PCB</strong><br />
bulk waste approval document <strong>the</strong> EPA considered an excess cancer risk of one in<br />
1,000,000 persons to be justifiable for a risk-based disposal project. However,<br />
slightly greater excess cancer risks would be considered as acceptable when<br />
evaluating o<strong>the</strong>r positive benefits of a project as a whole. The EPA considered <strong>the</strong><br />
excess cancer risk presented by <strong>PCB</strong>s on board <strong>the</strong> Oriskany Reef to represent a<br />
risk sufficiently acceptable to approve <strong>the</strong> Oriskany Reef Project.<br />
The EPA’s <strong>PCB</strong> risk-based <strong>PCB</strong> bulk waste disposal approval document defined a<br />
Tier 2 intensive monitoring program as “a focused effort to collect and analyze<br />
samples of commonly consumed <strong>fish</strong>, o<strong>the</strong>r biota, or o<strong>the</strong>r media from <strong>the</strong> Oriskany<br />
Reef site for purposes of determining if <strong>PCB</strong> concentrations in <strong>fish</strong> or shell <strong>fish</strong> are<br />
at levels which warrant issuance of a health advisory, determining <strong>the</strong> critical <strong>PCB</strong><br />
fate and transport pathways and assessing <strong>the</strong> extent of <strong>PCB</strong> impact to <strong>the</strong> local<br />
marine environment.”<br />
In contrast to Tier 2 monitoring, <strong>the</strong> Tier 1 <strong>PCB</strong> screening level monitoring<br />
implemented by this project in compliance with <strong>the</strong> risk-based <strong>PCB</strong> bulk product<br />
waste disposal approval was narrowly focused and limited in ecological scope. FWC<br />
and ECMRD funding resources were not allocated for, nor did <strong>the</strong> disposal approval<br />
mandate sustained multi-year <strong>sampling</strong> of an array of multiple artificial <strong>reef</strong><br />
reference sites, monitoring and measuring <strong>PCB</strong> related ecological impacts to nontarget<br />
<strong>reef</strong> <strong>fish</strong> community residents, examining complex <strong>PCB</strong> fate and transport<br />
interactions across trophic levels nor conducting additional <strong>PCB</strong> <strong>sampling</strong> of <strong>the</strong><br />
water column, sediments, and invertebrate fauna on or in benthic habitat adjacent<br />
to <strong>the</strong> Oriskany Reef. The Tier 1 screening monitoring effort was not intended to<br />
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