It will generally be possible (for the purposes of a Human Health Environmental Indicator) to address concerns over possible contaminated fish consumption or direct human exposure to contaminated sediments through some combination of source control and exposure controls. For example, some RCRA facilities have been found to directly discharge contaminants into relatively small water bodies, leading to potential fish contamination. At some of these facilities, human health EIs were achieved through control of the discharges (e.g., water outflows and runoff), combined with access restrictions and signs warning against fishing. Other facilities may have contributed to broader water quality or sediment problems, which may have led to bioaccumulation of contaminants in fish.
Again, we expect that measures to achieve the human health EI would focus on cutting off significant releases from the RCRA facility, perhaps combined with fish advisories or similar methods to reduce exposure where it is a concern.
Again, it should be emphasized that achieving EIs does not necessarily mean that a facility has completed its corrective action obligations. In the situations described here, the final remedy is likely to require substantially more aggressive remedies, perhaps including direct cleanup of the contaminated sediment. In some cases, the remedy will likely take place as part of a broader area-wide cleanup.
For more information, see http://www.epa.gov/epawaste/hazard/correctiveaction/eis/index.htm.
In making a human health EI determination, how do I deal with releases to surface water that may be associated with contamination of fish above safe levels? How about contaminated sediment from runoff, direct discharges, etc., to which people may be expos
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