Background: LWBR has been mildly polluted by PCBs for several decades. Recently, the ATSDR has, in an exposure investigation, measured PCB serum levels in a high-side biased (116/540) sample of LWBR fish consumers. The results were not significantly different from the general non-fish eating population.

For my part on this panel, I would like to relate the LWBR experience to my morning presentation on the effect of conservative biases under the condition of limited remediation resources for multiple remediation sites. Under these circumstances, it was shown that an optimal resource allocation must exist that results in the maximal risk reduction. All other allocations are counter-productive including those determined by conservative biases, a euphemism for error. Thus, there is no such thing as a conservative or always safe error. Accurate risk assessment must be based on accurate, unbiased data.

LWBR competes with the Oak Ridge Reservation and the Lower East Fork Poplar Creek for resources. Its low-cost remediation efforts has much higher hidden economic and societal costs. Given the recently imposed DOE ORO shortfall of $150 million, LWBR qualifies as one of multiple sites drawing from the same remediation pot.

LEFPC, a prelude to LWBR: Due to a large number of extremely conservative assumptions and estimates, the safety factor was estimated to be 5,000,000. The costs of the LEFPC mercury site remediation were estimated at $1.6 billion. The assumptions ignored all available site-specific data and direct toxicity measurements on the human species. Fortunately, under constant and long-term, technical opposition by the public, some measure of reality returned, and the costs of LEFPC remediation dropped to about $10 million. The study costs were still over $30 million. This is risk assessment gone bad.

Now to LWBR, the risk assessment was based on the standard EPA approach using the customary, conservative data values. There were no measurements of allegedly exposed humans. This resulted in a coldly stated fish advisory, which had a high societal cost, reduced tourist fishing.

The Local Oversight Committee under took to interpret fish advisories to the LWBR residents. In trying to explain the PCB hazards to the residents, it became increasingly clear that to claim that a B2 carcinogen (carcinogenic to animals [rats] but not to humans) was a significant cause of human cancer risk, was difficult and not too logical. Especially when one compared the PCB information to the saccharin found on the dining tables. Why does our government impose such unnecessary hardship on its citizens.

Fortunately at this time, ATSDR stepped in and obtained data on the heaviest fish eating population (114 individuals) which showed no significant PCB blood levels above the general population. It showed that some assumption in the EPA risk assessment must be wrong. While this has not yet changed the fish advisory, it is, to my way of thinking, the approach that should be followed at all sites whenever possible:

This seems obvious to an old experimentalist like myself but it apparently is not the way of the new "science policy". These are sad times for old experimentalists - we are asked to measure the wrong things.

I would like to commend the ATSDR for the return to reality and urge that others do likewise. Perhaps if there are enough cases where the EPA risk assessments are shown to be wrong, we can start the process of doing it right.

The best thing to come out of all of this was the finest fried fish dinner I believe I have ever eaten. Those LWBR fisherpersons know how to fry fish including PCBs.