Exclusion of fish consumption from HHRA

[tokey@thecity.sfsu.edu]

From: Thomas Okey <tokey@thecity.sfsu.edu>
Subject: Exclusion of fish consumption from HHRA

The Navy has decided to exclude the ingestion of fish and
shellfish from the Human Health Risk Assessment for Naval
Air Station, Alameda to the dismay of natural resource
trustees, regulators, representatives from minority populations
who rely on subsistence fishing, and other community
members. Exclusion of this exposure pathway appears to be a
matter of policy rather than well informed realism
or logic. It is reasonable that the Navy does not wish to be
saddled with full responsibility for impacts to which they
contributed less than 100% of the related contaminants (eg.
contaminant levels in mobile SF Bay fishes). Nevertheless, the
Navy appears to be overlooking some of their responsibilities
to provide an adequate assessment of human health risk and
ecological risk related to base closure. A reasonable person might
consider the following three points to be within their realm of 
responsibility: 

1. The human health risk related to the consumption seafood
should be estimated at closing bases where public access to the
shoreline will become less restricted. These estimates should
be made by the Navy regardless of who is responsible for the
contamination of that seafood.

2. Tissue concentrations of sedentary or resident fish species
surrounding bases should be directly measured, or at least
modeled, in the exposure assessment portion of the related
ecological assessment (apparently the Navy is including
resident fishes in their ecological models, but verbal requests
by Alameda RAB members for disclosure of the algorithm
and citations in written form have been postponed). This
information should then be folded into the Human Health Risk
Assessment.

3. The contribution of contaminants from sediment
surrounding bay area bases to bay-wide biological resources,
like mobile fishes, should be estimated using empirically-based
models. The contaminated sediment adjacent to shoreline
military bases undoubtedly contributes to tissue contamination
of these bay-wide biological resources. The assessment and
management process should include, and take into account,
such estimates.

In the spirit of assisting the Navy in developing reliable
approaches to making these estimates, Conservation Science
Institute is conducting a modeling study of food web transport
of sediment-associated contaminants with the support of the
Rose Foundation for Communities and the Environment. The
goal of this project is to identify and develop verifiable site
specific food web transport models using the best available
information from two locations at Naval Air Station,
Alameda. This model will then be ready for application at
other bases and other locations in San Francisco Bay.

Conservation Science Institute is seeking additional
independent support for phase two of this project in which an
interagency regional strategy will be developed to construct
more comprehensive bay-wide models for the purpose of
estimating the relative contributions of contaminants from
particular source sediment to organisms with home ranges that
include larger portions of the San Francisco Bay. Several
regulators, community members, and natural resource trustees
have expressed enthusiasm for such a regional approach to
estimating source contributions. 

This approach is viewed as refreshing in light of recent
evisceration of some successful regional monitoring programs
as the result of influence by a group of bay area dischargers.
Conservation Science Institute seeks collaboration with, and
cooperation of, all related agencies and entities both public and
private. We expect that a publication on our site-specific food
web models will be available at the end of February in
addition to our proposal for development of this regional
modeling strategy.

Please respond if you have questions, and please feel free to
clarify any of the statements made herein.

Thomas A. Okey, MS.
Executive Director / Marine Ecologist
Conservation Science Institute
Chair, Natural Resource Focus Group, RAB, NAS Alameda