Let's Assume We Have A Can Opener

A physicist, a chemist and an economist are stranded on an island, with nothing to eat. A can of soup washes ashore. The physicist says, "Lets smash the can open with a rock." The chemist says, "Let’s build a fire and heat the can first." The economist says, "Lets assume that we have a can opener..."

Unfortunately, that famous joke about economists has a great deal of relevance to our CAOs because the State and County CAO "experts" just want to assume that we have "pollution." That is no laughing matter.

What is "pollution" anyway? The notion of pollution is inherently linked to the concept of ecological or human health risk. Pollution occurs when a constituent of potential concern (COPC) is evaluated and found to be present in the environment at concentrations sufficient to cause a quantifiable increase in the likelihood of harm above background levels (i.e., excess risk). When a COPC has been confirmed to be present at concentrations presenting unacceptable excess risk, it is re-titled a constituent of concern (COC).

If you have COCs or if you have constituents exceeding a defined regulatory limit, you have "pollution," and as I hope you can see, that concept is inherently linked to concentrations.  The mere presence of a substance alone does not constitute "pollution." It has to be present at concentrations exceeding de minimis risk.

Where do you find published concentration limits that might be useful in evaluating whether COPCs are above de minimis? You find the regulatory limits for surface water here.  You find the regulatory limits for groundwater here.  You find the regulatory limits for drinking water here.

What about ecological screening levels? Those must be really hard to find ... and expensive too, right?  Actually, they are quite easy to find. Ecological screening levels for soils are part of MTCA, sediment management standards can be found in the WAC, and EPA provides recommended criteria for aquatic life here.

Despite all the available information on potential contaminants, how is it that after years of working on our CAOs, none of our "experts" have come up with a list of constituents that might need a remedy here? They have identified no COPCs. None. Instead, "they" simply want us to assume that pollution of unimaginable variety is present in San Juan County, and all of it can be miraculously treated by buffers. In one conversation, Dr. Adamus even referred to the potential list of contaminants here as, "so soluble and so toxic, and there are hundreds if not thousands that have not been studied in terms of their toxicological effects." And he referred to them as, "contaminants that are the inevitable results of having people around."

Okay, why don't you name a few of them?

Nothing doing apparently.  Instead, "they" seem to want us to live with the notion that "pollution" here is mysterious, present at dangerous concentrations, ubiquitous, but nevertheless, impossible to list much less test for ... so just trust us, it's here. It's all around us, and buffers will take care of all of it, provided they're gigantic.

As for me, I don't trust them, and I don't know how anyone could, because they are proposing buffer orthodoxy, not science. They have assumed a buffer (can opener) and think the problem solved, regardless whether one existed in the first place.