Alternative Ecological Risk Assessment - Lawrence V. Tannenbaum - E-Book

Alternative Ecological Risk Assessment E-Book

Lawrence V. Tannenbaum

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Beschreibung

In Alternative Ecological Risk Assessment the author, Lawrence V. Tannenbaum, provides a critical review of current practices in the ecological risk assessment field and proposes alternatives that are supported by established science and keen observation. It is hoped that this approach will pave the way to a greater understanding of what appropriate and useful ecological assessment for contaminated sites should entail. He demonstrates that in most cases current practices do not provide for an assessment of ecological risk, and moreover, that endeavoring to assess ecological risk is actually an unnecessary undertaking at conventional hazardous waste sites. (He states, for example, that the concept of scale is often ignored by practitioners, questions why animals like deer are routinely assessed at 5-acre sites, and challenges the ecotoxicology data currently used.) The book is aimed at students and professionals in the fields of environmental science, ecology, ecotoxicology, and health risk assessment.

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Table of Contents

Series Page

Title Page

Copyright

Dedication

Preface

Acknowledgments

Chapter 1: An introduction and overview

References

Chapter 2: Facing the music: understanding what ERA is … and is not

References

Chapter 3: Alternative exposure assessment

References

Chapter 4: Toxicology and toxicity assessment in ERA revisited

References

Chapter 5: Risk characterization versus site ecological assessment: Old and new

References

Chapter 6: Case study: Problem formulation versus making problems for yourself

References

Chapter 7: Getting beyond ERA

References

Chapter 8: A new ecological assessment paradigm for historically contaminated sites: Direct health status assessment

References

Chapter 9: Is RSA the answer to ERA?

References

Index

Series Page

“Truth will sprout from earth, and righteousness will peer from heaven.”

Psalms (85: 12)

“… how many times can a man turn his head Pretending he just doesn't see?”

Bob Dylan (‘Blowin' in the Wind’)

Excerpt from “Blowin' in the Wind” by Bob Dylan.

Copyright © 1962 by Warner Bros. Inc.; renewed 1990 by Special Rider Music

This edition first published 2014 © 2014 by John Wiley & Sons Ltd

Registered office: John Wiley & Sons, Ltd, The Atrium, Southern Gate, Chichester, West Sussex, PO19 8SQ, UK

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All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, except as permitted by the UK Copyright, Designs and Patents Act 1988, without the prior permission of the publisher.

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Limit of Liability/Disclaimer of Warranty: While the publisher and author(s) have used their best efforts in preparing this book, they make no representations or warranties with respect to the accuracy or completeness of the contents of this book and specifically disclaim any implied warranties of merchantability or fitness for a particular purpose. It is sold on the understanding that the publisher is not engaged in rendering professional services and neither the publisher nor the author shall be liable for damages arising herefrom. If professional advice or other expert assistance is required, the services of a competent professional should be sought.

Library of Congress Cataloging-in-Publication Data

Tannenbaum, Lawrence V.

Alternative ecological risk assessment : an innovative approach to understanding ecological assessments for contaminated sites / Lawrence V. Tannenbaum.

pages cm

Includes bibliographical references and index.

ISBN 978-0-470-67304-1 (cloth)

1. Hazardous waste sites– Risk assessment. 2. Ecological risk assessment. I. Title.

TD1052.T36 2014

363.72′872–dc23

2013022392

A catalogue record for this book is available from the British Library.

Wiley also publishes its books in a variety of electronic formats. Some content that appears in print may not be available in electronic books.

Front and back cover design by Andrew Leitzer.

Cartoon illustration by Joyce Kopatch. Deer photo by Ryan McVay, collection: Digital Vision. Forest Image © iStockphoto. Fox photo by Jupiter Images, collection: liquidlibrary.

To my wife, my aishes chayil, Chava Esther –

I could only have met the task and succeeded with your support, constant encouragement, and advice.

Preface

There are two sides to every story (or maybe more than two sides). There are different ways to look at situations and different ways to understand phenomena going on around us. It is not only in the realm of interpersonal relationships to which the adage applies; science and its application are areas that are ripe for seeing and explaining things differently. And so this book … Its purpose is to present a different side of the story for ecological risk assessment (ERA) as applied to contaminated sites that proceed through a process intended to determine if receptors are in harm's way and to take appropriate action if they are.

Having read just this much, one might suppose that the author was looking for a still different angle of ERA on which to write, and perhaps looking to be contrary for the sake of being contrary. That's not the case, however. It's a sad commentary when one has to resort to developing a contrary opinion or understanding in order to arrive at a topic that no one has yet secured. I would most definitely not encourage others to set themselves down to the specific task of finding flaws or shortcomings for the particular scientific field in which they work, all for the purpose of honing in on a topical area that they can uniquely claim as their own. For the book you are holding (dare I say ‘kindle-ing’, because along with the reference to the trendier means of reading books today, the suggestion could be that the subject book might best be suited for trashing in the fire), the etiology is much more straightforward and genuine. There was no deliberate process of systematic review of ERA for the express purpose of uncovering faults and the like so as to have a sufficiency of material to fill the pages of a book. The material was instead assembled in a casual manner over the years as the author worked at his science.

To me, the author, the observations and analyses I set forth are incredibly obvious and unmistakable. The staunch supporter or defender of common ERA practice will feel quite differently though, and that's fine, for science grows from healthy constructive debate. Perhaps I am completely wrong about every ERA element the book touches on. A reason to think so is that I appear to be the only one giving voice to our having an ERA process that leaves so very much to be desired. Perhaps we are so ingrained in our way of thinking that we never pause to consider other possibilities, and perhaps I am the only one who did pause to so contemplate things. There is the matter too, of not wanting to hear an alternative understanding of it all, and to complete the spectrum, there is the vastly more serious matter of not allowing oneself to hear an alternative analysis, a topic certainly dealt with in the book.

This book's purpose of presenting an alternative understanding of ERA is set forth with the hope that it will pique the minds of those who, in one fashion or another, are involved with ERA as an outgrowth of ecological science. The book is expressly targeted for the serious (college or graduate) student of health risk assessment, environmental science, or ecology, those who work in the ERA field, and those who publish on ERA topics. It should be required reading for regulators who craft and dispense ERA guidance and policy, and who need to hear among other things, why an ERA process isn't needed, not that we have one anyway—alas, not an avant-garde concept to summarily dismiss, but merely an alternative concept to professionally consider.

Lawrence V. TannenbaumSeptember, 2012

Acknowledgments

I offer my great thanks to the US Army Institute of Public Health (AIPH; formerly the US Army Center for Health Promotion and Preventive Medicine, and before that still, the US Army Environmental Hygiene Agency) for allowing me, where they could, to test the waters—to conduct studies critical to a bettered understanding of the potential for chemicals in the environment to impact ecological receptors. Special thanks to Dennis Druck for guiding my career especially through turbulent times, and for nurturing my passion to unleash a different perspective so clearly borne out by the studies. I am indebted to the US Army Environmental Command (formerly the US Army Environmental Center) and to Jim Daniels in particular, for funding one-of-a-kind studies that bear up to scrutiny and that are secured in the peer-reviewed literature. Several Army installations provided the necessary funds to carry out work I so badly wanted to have done. I send my appreciation therefore to Picatinny Arsenal (and Ted Gabel), Badger Army Ammunition Plant (and Joan Kenney), and Joint Base Langley Eustis (formerly Fort Eustis; and Joanna Bateman). The list of individuals to thank for allowing RSA (see Chapter 9) to be birthed, cultured, and firmly established, is extensive. There were thinkers, those who supplied the grunt work, and more. The short list runs to: Keith Williams, Brandolyn Thran, Adam Deck, Jeff Leach, Sue Fox, Barrett Borry, John Buck, and the techs from AIPH's Soils Lab.

Chapter 1

An introduction and overview

At the time of writing, I have over 20 years of experience working in the health risk assessment field as it relates to chemically contaminated properties, with a special emphasis placed on ecological risk assessment (ERA). At the beginning of my career in environmental work while with the United States Environmental Protection Agency (USEPA), I was involved with the pre-remedial element of the legendary Superfund program. My duties there largely amounted to verifying the conclusions recorded in preliminary assessments (PA) and site inspections (SI) for the contaminated sites. Most of the documents recommended that the sites advance to more refined tiers of analysis that would permit non-threatening sites to be shifted away from those that seemingly had the potential to truly pose substantial health threats to the human and ecological receptors that contacted them. I'm not certain but it may be that already back then, I pondered if we were ever encountering instances of harm in the ecological receptors that inhabited the sites which were producing substantial scores with the Superfund program's Hazard Ranking System (HRS). In my reviews I had never come across a single PA or SI that had reported tell-tale signs of injury to birds or mammals, the two groups of terrestrial ecological receptors that are routinely evaluated in ERA work. None of the PAs or SIs had described the unsettling discovery of a site devoid of biota, and at no site or anywhere nearby to one, had anyone observed something bizarre and clearly out of the ordinary, such as an accumulation of carcasses or evident signs of rampant disease in an ecological (i.e., non-human) species. To a certain extent, I shelved for a while the need to have my query resolved. If there really were health concerns for site ecological receptors, unaware of these as any of us might be, I reasoned that such would be indirectly captured and later addressed courtesy of the HRS scores. Sites that would advance through the process (and perhaps all the way to the National Priorities List; NPL) due to their high scores, would be there via a ranking scheme that was heavily weighted to human health concerns. Once on the NPL though, the sites would come under greater scrutiny not only for their potential human health concerns, but for any ecological concerns they might bear as well.

About 10 years into my risk assessment craft, having already logged in a number of years with the Army pursuant to my EPA years, and having moved well beyond attending to pre-remedial tasks only, the nagging thoughts returned. For all that I knew of contaminated terrestrial and aquatic sites managed under the related Superfund and Resource Conservation and Recovery Act programs (i.e., valuable and relevant knowledge gleaned from hands-on involvement with the sites, and not just information assimilated through reading work plans and remedial investigations and the like), I could not point to single site that had anything ecologically wrong with it (e.g., vanished populations or species or a lacking detritivore compartment). Site visits didn't suggest anything amiss, and through negotiations with stakeholders of all walks, many insistent that their sites submit to extensive eco-based site cleanups, never once was it suggested that there had been observations of ecological health compromise occurring in the field. [A clarification is in order here. Site visits can very well detect (gross) habitat loss or elimination, as in the “slickens” of toxic waste sediments (i.e., the highly compromised riparian areas) of the Upper Clark Fork River Superfund Site in western Montana, that are directly traceable to the mining, milling and smelting activities that have occurred over many decades (Brumbaugh et al. 1994). Where such massive physical destruction has occurred though, it's understood that the lack of habitat is responsible for the removal of the resident biota of yesteryear. Importantly then, construction projects to restore habitat are the order of the day, and moreover, riparian species aren't at risk. With the habitat they require missing, riparian species are not expected to be present and thus at risk from chemical exposure. It bears mention here too, that while individuals might be quick to cite the Upper Clark Fork River Superfund Site as one having been ecologically wronged, the example is a poor one. This site, the largest geographic Superfund site in the United States, does not typify in the least the sites that are the subject of this book. The overwhelming majority of sites, Superfund or otherwise, are just a handful of acres in size, if that much.

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