2003 CPEO Brownfields List Archive

From: Emery Graham <egraham@ci.wilmington.de.us>
Date: 8 Jul 2003 15:25:59 -0000
Reply: cpeo-brownfields
Subject: RE: [CPEO-BIF] Another Perspective On AAI's Potential Impact
 
How does one responsibly distinguish between "immediate imposition of risk" and "perception of contamination?" Is it possible that the perception of contamination may pose some immediate risk to the perceiver? Is it possible that perceiving oneself to be at risk causes some type of harm?
 
It's commonly thought that our sense of the immediacy and the nature of risk is informed by our awareness and our experiences. I suspect this is why there's an emerging emphasis being placed on "risk communications." Risk oriented thinking suggests a conception of risk as graduated or metered along some type of continuum. Until we test for contaminants, we tend to make this gradation a literary artifact. When the technicians bring their meters and tools we change the nature of our sense of risk and tend to focus on its "measured" reality; our sense of "realness" of risk changes. Is there another transition point for our "sense" of risk that occurs prior to the time the technicians arrive and measure the conditions at the site? 

I suggest that there is the transition point that is defined by the considerations related to entering a site into consideration for designation as a brownfield, i.e., the point where there is suspicion or perception that the site "may be" a brownfield. This is the perceptual point defined in the Brownfields program that constitutes the criteria for including or excluding a site.   

I suspect the people living near waste sites have a higher regard for information characterizing their risk than those who are in close proximity to a waste site and that their perceptions about sites are real in their consequences, i.e., the local folks react to those perceptions; rightly or wrongly. The point where waste site residents come to understand their status as such defines the beginning of a new stream of risk considerations for those residents.

The harm associated with living near a site that's perceived to be contaminated is defined in the human, automatic, mental and physiologic reactions to perceptions of risk and potential harm from danger, e.g., stress and anxiety. ATSDR's and the Mental Health Association's research on waste sites and mental health are beginning to demarginalize the residents of waste site areas by including them in the group of people who deserve protection and relief from psychological harm. 

Human beings have no choice in matters of automatic behaviors that occur outside of their consciousness and rationality. Anxiety and stress reactions to adversity, or perceived adversity, help define us as humans and tend to be automatic. 

Hopefully this dialog about AAI will help clarify the full impact of brownfields and increase the validity of cost and benefit calculations deemed so important in the calculus of remediation. Hopefully our community will develop an understanding of the role of risk communication as a means to reduce the costs of brownfields by insuring that harm prevention messages are included in the all risk communications. 

-----Original Message-----
From: LSchnapf@aol.com [mailto:LSchnapf@aol.com] 
Sent: Monday, July 07, 2003 1:41 PM
To: cpeo-brownfields
Subject: Re: [CPEO-BIF] Another Perspective On AAI's Potential Impact

In response to Emery's comment, many brownfield sites do not pose an immediate risk to residents but are brownfields because of the "perception" of contamination. Of those that do, the redevelopment often mitigates the risks posed by the site. For example, if the risk is dust-borne contaminants, the construction will establish a cap or cover that will mitigate that risk. Obviously, it is important that the actual construction does not make the airborne exposure worse. In my experience in NY and NJ, state regulators have been aware of this issue and make sure that the HSP addresses this issue. 

In most cases, groundwater is not being used so there is no direct exposure pathway for drinking groundwater. However, there probably needs to better attention on vapor control from off-gassing of contaminants either in the soil or from the groundwater.  I think the MEW experience and the recent revisions to the vapor intrusion model clearly show that regulators need to pay more attention to this issue when a brownfield is being redeveloped and where the contaminants of concern are VOCs. 

Larry Schnapf
55 E.87th Street #8B/8C
New York, NY 10128
212-996-5395 phone
212-593-5955 fax
www.environmental-law.net website

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