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Human and Ecological Risk Assessment - Earthjustice

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Section 4.0<strong>Risk</strong> Characterizationin this analysis does not include impoundment water samples, <strong>and</strong> the direct exposure pathwaycould not be addressed for ecological risk. However, the CCW risk assessment conducted in1998 (U.S. EPA, 1998a,b) did consider direct exposure of ecological receptors to surfaceimpoundment waters. The approach in the 1998 study restricted the analysis to terrestrialreceptors that obtain food <strong>and</strong> prey from the surface impoundments <strong>and</strong> excluded aquaticreceptors living in the water column because surface impoundments are not intended to be ahabitat for aquatic species. For the terrestrial <strong>and</strong> aquatic receptors considered, the 1998 analysisused the same CSCLs <strong>and</strong> a similar methodology to that used in the CCW screening analysis(e.g., comparison of 90th percentile waste concentrations with CSCLs).The 1998 direct exposure results are provided in Figure 4-1 <strong>and</strong> show HQs greater than100 for boron, selenium, lead, barium, <strong>and</strong> cadmium. This, along with the damage case resultspresented in Section 4.2.4, show a clear likelihood of risks to terrestrial organisms that obtainfood <strong>and</strong> prey from CCW surface impoundments. It is probable that ecological receptors eat <strong>and</strong>drink from CCW surface impoundments in some settings. In addition, ecological receptors,particularly amphibians who may lay their eggs in surface impoundments, are probably exposedthrough chronic contact with wastewater. Because amphibians are prey to a large variety ofanimals (e.g., raptors; wading birds; mammalian omnivores, such as foxes, raccoons, <strong>and</strong>weasels), this exposure is transferred up the food chain. Aquatic plants, although not often afocus of this ecological risk assessment, are directly exposed in surface impoundments. Plants, inturn, may be ingested by vertebrates <strong>and</strong> invertebrates at higher trophic levels.April 2010–Draft EPA document. 4-27

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