c/EPA
            United States
            Environmental Protection
            Agency
            Office of Emergency and
            Remedial Response
            Washington DC 20460
EPA/540/1-89/003
November 1989
            Superfund
OSWER Comparative Risk
Project
            Executive Summary and
            Overview

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                                             EPA/540/1-89/003
                                              November 1989
OSWER Comparative Risk Project

      Executive Summary and Overview
                       Superfund
                         Sites
Industrial
Facilities
           Oil and gas
           Operations
                 Municipal
                  Waste
                Combustion
                   Underground
                    Injection of
                    Hazardous
                     Waste
       Office of Solid Waste and Emergency Response
           U.S. Environmental Protection Agency
                Washington, DC 20460
                                  U.S. Environmental Protection Agency
                                  Region 5, Library (PL-12J)
                                  77 West Jackson Boulevard, 12th Floor
                                  Chicago, IL  60604-3590

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TABLE OF CONTENTS
EXECUTIVE SUMMARY 	    v
      SCOPE AND ORGANIZATION OF THE STUDY	    v
      FINDINGS	'	vi
      PROGRAM RECOMMENDATIONS 	vii

CHAPTER 1.  INTRODUCTION  	    1
      1.1   ORGANIZATION  	    1
      1.2   RELATIONSHIP OF STUDY TO AGENCY COMPARATIVE RISK EFFORTS   .  .    2
      1.3   RELATIONSHIP OF STUDY TO STRATEGIC PLANNING 	    3

CHAPTER 2.  STUDY APPROACH  	    4
      2.1   OVERALL APPROACH  	    4
      2.2   OSWER PROBLEM AREAS  	    5
            2.2.1  Problem Area Definitions 	    5
            2.2.2 Problem Areas Addressed 	    6

CHAPTER 3.  STUDY RESULTS 	    7
      3.1   GENERAL RESULTS 	    7
            3.1.1  Acute Events  	    7
            3.1.2  Other Health Effects  	    7
            3.1.3  Ecological Effects  	    8
            3.1.4  Welfare Effects   	    9
            3.1.5  Ground Water Valuation 	    9
      3.2   KEY FINDINGS	    9
            3.2.1  Final Rankings 	    9
            3.2.2  Data Quality and Confidence Levels	   13
            3.2.3  Overall Confidence  in Rankings  	   14
      3.3   METHODOLOGICAL   AND   DATA   FACTORS  AFFECTING   WORKGROUP
            RANKINGS	   14
            3.3.1  Acute Events	   14
            3.3.2  Other Health Effects  	   15
            3.3.3  Ecological Effects  	   15
            3.3.4  Welfare Effects	   16
            3.3.5  Ground Water Valuation 	   16
      3.4   RANKINGS AND PUBLIC PERCEPTION OF RISKS  	   16

CHAPTER 4.  INFORMATION NEEDS 	   24
      4.1   GENERAL INFORMATION NEEDS  	   24
            4.1.1  Program Recommendations  	   24
            4.1.2  Information Needs   	   25
            4.1.3  Ongoing Information Collection  Efforts  	   25
      4.2   ACUTE EVENTS	   27
      4.3   OTHER HEALTH EFFECTS  	   27
      4.4   ECOLOGICAL EFFECTS   	   27
      4.5   WELFARE EFFECTS	   27
      4.6   GROUND WATER VALUATION   	   27
      4.7   PUBLIC PERCEPTION OF RISK	   28
                                      111

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APPENDIX A  GLOSSARY




APPENDIX B  DEFINITION OF OSWER PROBLEM AREAS




APPENDIX C INDIVIDUAL WORKGROUP SUMMARIES
                                       IV

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                               EXECUTIVE SUMMARY

      The Office of Solid Waste and Emergency Response (OSWER)  Comparative Risk
Project  was  initiated to  serve  strategic  planning  needs  by  exploring  the
comparative  risks  posed  by various  waste  management practices  regulated by
and/or under  OSWER purview.   The study was also undertaken to gain experience
in performing comparative analysis,  identifying information needs,  and  assisting
in establishing research priorities.

      In  evaluating  study goals,  a  number of  objectives became   apparent,
including:

  •   Identifying Data Needs:   provide for more  consistent evaluations of
      relative  and absolute  risks  across different  program  areas that
      OSWER addresses;

  •   Improve on Explicit  Use of Data:   allow for reevaluating rankings
      as new information becomes available  (algorithms are made explicit
      where possible);

  •   Public Perception and Risk:  address the apparent disparity between
      the public's perception  of risks  and  the  actual risks  that   may
      require priority OSWER  attention  in the future;  and

  •   Type of Decision:  provide  a  clearer separation  of risk assessment
      from risk management.

      The outputs/products of  this study are expected to serve to rank  important
waste management problems facing OSWER; identify public health and environmental
problems for  future investigation; and identify data needs  and uncertainties
associated with information gaps.   The findings of this study are not intended
as an  assessment of  the  effectiveness  of existing regulatory controls  or as
justification for more or less regulatory involvement.
SCOPE AND ORGANIZATION OF THE STUDY

      This study was organized with a study chair and five Workgroups.  The five
Workgroups are:   (1) Acute  Events,  (2)  Other Health  Effects,  (3)  Ecological
Effects, (4) Welfare Effects1, and (5)  Ground Water Valuation.  Each workgroup
produced a  separate report.     The  Workgroups divided the  universe  of public.
health and environmental problems into different problem areas.   These problem
areas generally reflected organizational  structure  and  program priorities.  The
      The Welfare  Effects  Workgroup examined  impacts  on welfare  (which were
defined as damages to  economic resources that result in  a  reduction in the value
of commercial activities or  in  the  value  of human well-being).   This approach
was chosen because of the lack of studies associating economic  impacts with OSWER
problem areas.  While the supporting workgroup report is  titled "Report of the
Economic Effects  Workgroup", the Workgroup  recommended that  "Welfare Effects"
be used for purposes of the overview report.
                                      v

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Workgroups believe that  the  list of problem areas accounts  for  the principal
risks associated with OSWER's programs.
FINDINGS

      Table ES-1 summarizes both the  relative rankings (e.g., high, medium, and
low) and the level of confidence of the rankings.   The workgroup rankings were
developed  through  a  process  that  involved  the  evaluation  of  available
information and judgments  to  estimate  the  relative  risks  associated with each
problem area.

      The problem areas in Table ES-1 are ordered by decreasing severity--that
is, those judged to represent the highest risks are  at the top and those judged
to  pose  the least risks are  at the bottom.  Because  it provides  a  range of
results associated with the individual workgroup rankings, Table ES-1 can only
be used to stratify problem areas into broad groups.

      For purposes  of  this overview report, the workgroup  rankings have been
stratified into three bands:

   •   High:  Those problem areas that have at least two rankings of high
      and were assessed by at least four workgroups.  This band includes
      Municipal Landfills;  Industrial Facilities; Hazardous Waste Storage
      Treatment  Tanks,  Drums  and  Containers;  and  Land  Disposal  of
      Hazardous Waste.

   •   Medium:  Those problem areas not grouped as  "high" or "low" relative
      risk for purposes of this overview report.

   •   Low:  Those problem areas that  did not receive any "high" rankings.
      Problem areas  grouped  into as   "low"  were  ranked  by no more than
      four workgroups and  had a minimum of at  least two  low rankings by
      the Workgroups.   (While Ocean Dumping was  ranked as high (with high
      confidence) within the Ecological Effects Workgroup, the definition
      of Ocean Dumping included activities  OSWER programs do not address.
      As such,  the  ranking of Ocean  Dumping within this  matrix has been
      adjusted downward.)

      Had Superfund activities been grouped into one single category, it appears
that the ranking would have been:  medium by the Acute  Events workgroup and high
for the  other four workgroups.  Given this  combination,  Superfund activities
would be moved from  the "medium" risk  grouping to "high".

      Because  risk is a continuum,  these  three  broad bands  of problem areas
reflect professional judgment,  not risk thresholds.   Table ES-1 suggests that
those problem areas  with better  supporting information tended to be associated
with higher  confidence  and also were actually  ranked (as opposed to not being
ranked or being combined with other problem areas).

      The underlying information used to support  rankings shown in Table ES-1
differs  significantly  both  within  and across Workgroups.   The differences

                                       vi

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include such  factors  as  measures of risk used for ranking  and the quality of
information  needed  for  ranking.    These  rankings  provide  risk  estimates
associated with current  emissions  that  reflect  in-place controls.   Obviously,
rankings would differ without controls.   Selected highlights that may assist in
interpreting Table ES-1  include:

  •   Industrial  Facilities:    All Workgroups except  the  Ground  Water
      Valuation Workgroup  stated that  they believed that  risks may  be
      substantially higher than the data suggest and that more data should
      be collected.

  •   Superfund Sites:   The  Other Health Effects Workgroup  considered
      current National Priorities List  [NPL] sites  (currently about 1,200
      sites) and sites that are to be evaluated for  NPL listing (currently
      over  30,000 sites).   The Welfare  Effects  and  the  Other  Health
      Effects Workgroups combined remedial and removal actions at both NPL
      and non-NPL sites.   The other workgroups considered  only removal
      actions at NPL or potential NPL sites.

  •   Chemical and Industrial Manufacturing Facilities:  The Other Health
      Effects Workgroup called this problem area "Chemical and Industrial
      Manufacturing  Facilities"  or  "Accidental  Releases  at  Chemical
      Facilities."  The Welfare Effects Workgroup called  this problem area
      "Accidental  Releases  at Chemical Facilities."   The  Acute  Events
      Workgroup addressed  only risks posed to  workers  at  chemical  and
      industrial facilities.

  •   Underground Storage Tanks:   This  problem area  was only  considered
      by the Ground Water Valuation Workgroup.  It includes:   hazardous
      substance product storage  tanks,  petroleum underground  storage
      tanks, and exempt underground storage  tanks.

  •   Underground Injection of Hazardous Waste:  The Other Health Effects
      Workgroup considered  injection of  hazardous waste  into Class  I
      injection wells.   The  other  workgroups  considered all underground
      injection of hazardous waste regulated under 40  CFR Part 267 Subpart
      G and 40 CFR Part 146.

      Table ES-1  suggests that  the relative  rankings  of  problem areas  are
generally consistent with program priorities,  and  that  some problem areas  not
necessarily perceived  as high  program  priorities  could be ranked high  even
though they are supported by relatively uncertain  information.


PROGRAM RECOMMENDATIONS

      The following  long-term recommendations  for the  continued  support  of
strategic planning are:

  •    Risk Rankings: should be reviewed periodically to  incorporate new
      information  gathered.
                                     Vll

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  •   Centralized Repository: should be established  for  the  maintenance
      of information used to perform the rankings.

      To provide  a  more consistent  basis to  support  decisions  on  program
direction,   the Workgroups  recommend  developing better information  in  the
following areas:

  •   Broader Range of Information Collection:  Information was especially
      limited and of low quality for ecological effects, welfare effects,
      and  ground  water  valuation.    Consideration  should be given  to
      enhanced data collection and methodological work in these areas.

  •   Cross Media Analysis:   It  is recommended that efforts  be  made  to
      better  assess  major  risks  from all  pathways  as opposed to  those
      pathways easiest to evaluate.

  •   Low Confidence Areas:   The  Workgroups  expressed particularly low
      confidence  in  their  findings in  four  problem areas (i.e.,  Mixed
      Wastes,  Other   Treatment,   Storage,  and  Disposal   Facilities,
      Industrial Facilities, and Solid Waste Management  Units).   Future
      analyses should benefit from more and better data in these  areas.

  •   Ground  Water  Valuation:   The  Ground  Water  Valuation Workgroup
      eliminated 13 problem areas from consideration, partly  due  to lack
      of information.  The Ecological Effects Workgroup did not consider
      Removal  Actions  at Non-NPL  Sites  due to  insufficient data.   To
      improve future studies, EPA should benefit from obtaining new data
      sources for these problem areas.

      Finally, to improve confidence of the findings  of this and future studies,
sensitivity   analyses   of   the  use   of   alternative  methodologies  and  the
corresponding impacts on final rankings would be useful.
                                     Vlll

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                        ES-1
COMPARISON OF WORKGROUP RANKINGS OF OSWER PROBLEM AREAS
Workgroup Ranking

Municipal Landfills
Industrial Facilities
Hazardous Waste Storage Treatment Tanks.
Drums, and Containers
Petroleum Underground Storage Tanks
Land Disposal of Hazardous Waste
Superfund Sites
Remedial Activities
Transportation of Hazardous Materials
Chemical and Industrial
Manufacturing Facilities
Underground Storage Tanks
Oil Spill Response
Oil and Gas Operations
Solid Waste Management Units
Exempt Storage Tanks
Mining Wastes
Other Treatment. Storage.
and Disposal Facilities
Removal Activities
Combustion of Hazardous Waste
Municipal Waste Combustion
Hazardous Substance/Product
Underground Storage Tanks
PCS Wastes
Land Treatment of Hazardous Wastes
Underground Injection of Hazardous Waste
Mixed Wastes
Ocean Dumping
Ocean Incineration
Acute
Events
L
H
M
H
M
-
£
H
X
-
H
H
M
M
L
M
M
M.
£
M
M
£
M
L
L
L
Other
Health
Effects
M
H
H
M
M
H
-
£
L
-
L
M.
X
M
M
M
-
M
M.
M
L
M
L
L
L
-
Ecological
Effects
X
M
M.
M£
X
-
H
JA£
M£
-
M£
M
ML
M£
MM
M
-
M
MH
M,
MH
M
ML
M
H
M£
Welfare Ground-Water
Effects Valuation
H H
H
H
H
H M
11 TT
—
L
L
H
L
M £
M. M,
M.
M, M.
M £
-
L L
L L
L
L
L
L
L
L
L


1









1
3









5"


                        IX

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        Notes  on the Comparison  Table

 Letters reflect relative risk rankings judged for problem areas:

 ft       High or higher relative risk potential
           Moderately high relative risk potential

           Medium or moderate relative risk potential
           Moderately tow relative risk potential
           Low or tower relative risk potential
           The workgroup dd not consider this problem area.
Uncertainty is reflected in lettering as:
 H     Low uncertainty (high confidence)

 3{     Medium uncertainty (medium confidence)

 H     High uncertainty (tow confidence)
No attempt was made to 'add* risks across Workgroups or compare the importance
of one Workgroup as more significant than another.  Note that differences in
problem areas addressed is due to a combination of available data and scope.
                                X

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                           CHAPTER 1.  INTRODUCTION

      The Office of Solid Waste  and Emergency Response (OSWER) Comparative Risk
Project  was  initiated  to serve  strategic planning  needs  by exploring  the
comparative  risks  posed by  various  waste  management  practices  regulated by
and/or under OSWER purview.  The  study was  also  undertaken to gain experience
in performing comparative analysis, identifying information needs, and assisting
in establishing research priorities.

      The  statutory  goals for  the  solid waste  program  direct the Agency to
promote protection of health and the environment.  The statutory language varies
among  the different  programs,   the  emphasis  is  consistently on  developing
standards to protect the health  and the environment or by adopting standards of
other Agency programs.

      In  evaluating study  goals, a number  of objectives  became  apparent,
including:

  •   Identifying Data  Needs:  provide for more consistent evaluations of
      relative  and  absolute  risks across  different  program  areas  that
      OSWER addresses;

  •   Improve on Explicit Use of  Data:   allow  for  reevaluating rankings
      as new information becomes available   (algorithms are made explicit
      where possible);

  •   Public Perception and Risk:  address the apparent disparity between
      the  public's  perception  of risks  and the actual  risks that  may
      require priority  OSWER attention in the  future;  and

  *   Type of Decision:   provide a clearer separation  of  risk assessment
      from risk management.


1.1  ORGANIZATION

      This report is organized  as  follows:

  •   Chapter 1:   Introduction -- addresses the  goal of  this  study,  its
      relationship to strategic  planning,  and  its relationship to  Agency
      comparative risk  efforts.

  •   Chapter 2:   Study  Approach -- addresses  specific problem  areas
      covered and the overall approach used.

  •   Chapter 3:   Study Results -- addresses the confidence  in the  data
      sources and  methodology  used,  differences  among  the  Workgroups
      (including  problem areas addressed  and methodologies  used),  future
      data needs,  and the comparison  of risks.

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  •    Chapter  4:    Information Needs  --  addresses  the  links  between
      information needs based upon the  rankings  of problem areas  and the
      type and quality of information available  to support rankings.

  •    Appendix A:   Glossary -- defines  key terms.

      Appendix B:   Definition of OSWER Problem Areas --  defines the areas
      addressed by the Workgroups.

  •    Appendix C:   Individual Workgroup  Methodologies  --  addresses  the
      different methodologies  used by  the  Workgroups  to  determine  the
      relative risk of the OSWER problem  areas.

      These materials constitute the project overview.   The original workgroup
reports that  provide the  foundation for this  overall  report should also  be
reviewed  for  detailed  evaluations  of  information  bases,  assumptions,  and
references.
1.2  RELATIONSHIP OF STUDY TO AGENCY COMPARATIVE RISK EFFORTS

      The OSWER Comparative Risk  Project  is  a follow on to  an  earlier  Agency
effort.  In 1986,  the Administrator commissioned a special task force of senior
EPA managers and technical experts to compare the risks  associated with major
environmental problems.   In  February 1987,  the  task force  issued  its report,
Unfinished Business:  A Comparative Assessment of Environmental  Problems.   The
report was an Agency-wide effort that examined all environmental problems facing
the nation and estimated the  relative risk to public health and the environment
posed by each problem area, assuming existing levels of regulatory control.

      In many instances, the  rankings in Unfinished Business did not correspond
closely  with  EPA's  current program  priorities.    For  example,  areas  of
substantial  Agency  effort identified as posing  relatively low  risk  included
hazardous waste and Superfund sites, underground  storage  tanks,  and municipal
non-hazardous waste sites.  The report,  however,  suggested that  this seemingly
anomalous result was not necessarily  inappropriate.  Rather, some problem areas
appeared to  pose relatively low risks precisely because  of  the  high levels  of
Agency  resources  were  devoted to  controlling them.   Furthermore,  Unfinished
Business noted higher  levels  of  effort  may remain necessary  to  hold  risks  at
current levels.   In reviewing Unfinished Business,  the  Workgroups determined
that at least one  reason that OSWER problem areas did not  rank high was the lack
of information to support  development of  national chemical-specific rankings.
Solid  waste programs   often  focus on waste  streams  and may lack pollutant-
specific  information on risks.   Moreover,  information on Superfund risks may
exist but is sometimes  difficult to obtain. As such,  the OSWER Comparative Risk
Project was viewed as an opportunity to make fuller use of newer program-related
information including  information under development when Unfinished Business was
being prepared.

      Unfinished  Business relied upon  professional  judgment   (supported  by
background materials)   to develop rankings.  Thus,  it is not possible to modify
the rankings in Unfinished Business based on  additional information.  The OSWER

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Comparative Risk  Project  was designed to generate  rankings  through a process
that better documented  the  algorithm  and rationale  used to generate rankings.
If  the  rationale for  the algorithms and  rankings  could be  documented,  both
algorithms  and  the  rankings  could  be  updated  as  new information  becomes
available.
1.3  RELATIONSHIP OF STUDY TO STRATEGIC PLANNING

      In June 1985,  the  Administrator  initiated a strategic planning process.
The  process  was   intended   to   assist   in  developing  a  consensus  around
environmental goals across all media and help establish program priorities.  The
resulting  OSWER strategic planning  initiative  was  based  on  the  concept  of
preventing  waste  transfers  from  one  location  to another  and  one  medium  to
another.   Given the absence  of a cross-media perspective  on waste management
issues, it is possible that a specific regulation in one media may shift waste
to other media without reducing risks  to human health or the environment.  This
study supports this larger planning process.

      Comparing risks from releases to  different media  allows OSWER to begin to
assess the consequences  of regulation  in  different media.    In  the long-term,
this study will support OSWER strategic planning by:  identifying public health
and environmental problems for future investigation;  and identifying data gaps
and associated uncertainties.

      This study should be seen only as an  early step  in the larger strategic
planning  process.     It   was undertaken  to  gain  experience  in  performing
comparative analysis, as  much as for  the results of the analysis itself.  This
study is an opportunity to make fuller use  of available  information and to build
upon the experience of Unfinished Business.   While the results  are expected to
assist in  the identification of information gaps and in establishing research
priorities, no other applications of the  results have  been determined at this
time.   Thus,  the  findings  are not  intended to  assess  the effectiveness  of
existing regulatory controls  or justify more or less  regulation.

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                          CHAPTER 2.   STUDY APPROACH

      This  chapter  addresses  the  general  study  approach.     The  overall
methodology (Section 2.1)  and the  OSWER problem areas  (Section  2.2)  are also
discussed.
2.1   OVERALL APPROACH

      This study was  organized  with a study chair and  five  workgroup chairs.
The  five  Workgroups  are:    Acute  Events;  Other  Health Effects;  Ecological
Effects; Welfare Effects; and Ground Water Valuation.  Each workgroup produced
separate reports (which are summarized in Appendix C).   Workgroup assumptions,
references employed and other useful information is available in the individual
reports.

      To  promote  consistency,  the  Workgroups began  with  the  same set  of
environmental problem areas.   A  centralized  effort  was  initiated  to collect
information  and seek review  for  completeness and  technical accuracy.   This
information was used as a baseline for ranking the problem areas.

      The evaluation relied primarily upon readily available information, where
possible.   However,  in  discussing possible approaches  they might  take,  the
Workgroups  decided to modify the  approach  employed in  Unfinished Business.
Recognizing  that direct comparisons  across  problem  areas are  difficult,  the
following steps were undertaken  to improve the plausibility of such comparisons:

  •   promoted  the consistent use of information across Workgroups,

  •   requested assumptions be explicitly stated and

  •   characterized uncertainties associated with the rankings.

      Assessing health risks is  generally easier than  assessing risks associated
with other measures of environmental damage  (e.g., ecological risks) because of
availability  of information and acceptance of consistent methods to evaluate
risks.   The assessment process is  further  complicated  by the  difficulties in
relating  risks  to the types  of activities.   For example, it  is  difficult to
relate  specific health  risks  (typically  assessed  by  a single  chemical)  to
different types of heterogenous hazardous waste.

      Another  difficulty  in  comparing health  risks with  other measures  of
environmental  damage is the  difficulty  in  comparing  endpoints  that must be
associated  with  differing   levels  of   confidence  (or  uncertainty).    The
uncertainty  of  a  specific endpoint  (economic  impact)   is  a function  of the
uncertainties  associated with  both the  inputs  and algorithm employed.   As
previously  stated, measures of  environmental risk such as economic  impacts may
be  the most relevant  measures for  some  audiences,  but are  also  the most
uncertain  and  the  most limited  in the  support  of comparisons.    Thus,  the
strength  of conclusions  in this report reflects consideration of the relative
uncertainties of the input  parameters and  the algorithm employed to rank problem
areas.

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2.2   OSWER PROBLEM AREAS

      OSWER  problem areas  generally  reflected  organizational  structure and
program  priorities.    The  24  problem areas  represent  the principal  risks
associated with  OSWER's  programs  (as  defined  in Appendix B) .   These problem
areas are not mutually  exclusive; the same release may be addressed in more than
one  problem  area  (e.g.,  disposal  of  PCB wastes  at a  site on  the  National
Priorities List  may be  reflected  in  both  the  problem  areas PCB  Wastes and
Remedial  Actions).   This  potential for  "double counting"  is  noted  wherever
possible.

      2.2.1  Problem Area Definitions

      Differences in the Workgroups' definitions  for  some problem areas created
difficulty in comparing  relative  risk rankings.    These  differences  can  be
divided into two categories:

  •   those  related  to  different  types of  wastes or  waste management
      practices and

  •   those related to different types of events.

      A number of  the  workgroups included different  types of waste and waste
management practices in  the same problem  area.   For  the Underground Injection
of Hazardous Waste problem area, the Other Health Effects Workgroup considered
injection of  hazardous waste  into  Class  I  injection wells, while the other
workgroups considered  all  underground injection of  hazardous waste regulated
under 40  CFR Part 267 Subpart  G and 40 CFR Part  146.   In  the  Ocean Dumping
problem area,  Workgroups  diverged in their definitions of what constituted ocean
dumping.  The  Other  Health Effects and Welfare  Effects  Workgroups considered
risks from ocean  dumping of municipal waste, dredge  spoil,  and discharges  of
industrial waste  into  the ocean, the  Ecological Effects  Workgroup considered
risks from ocean  dumping of municipal  waste and dredge spoil,  and the Acute
Events Workgroup only considered risks from ocean dumping of municipal waste.

      As  to  the  types of  events and  associated risks considered, the Acute
Events Workgroup took  a  different  approach.   For example, in the  Oil  and Gas
Operations problem area,  the Acute  Events Workgroup considered only the effects
of blow-outs  at  oil  wells, while  other workgroups considered the  effects  of
releases from wastes resulting from oil and gas activities.

      In the  Chemical and Industrial Manufacturing Facilities problem area, the
Acute Events Workgroup addressed only  risks  posed to workers at  chemical and
industrial facilities,  whereas  other   workgroups  considered the  impacts  of
releases  both  within  and  outside  chemical   and  industrial   manufacturing
facilities.

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      2.2.2 Problem Areas Addressed

      Every workgroup did  not  address all of  the  24 OSWER problem  areas.  In
fact, only five problem areas were addressed by all the Workgroups (Combustion
of Municipal Waste,  Land Disposal of  Hazardous  Wastes, Mining Wastes,  Other
Treatment, Storage,  and  Disposal  Facilities,  and Municipal Landfills).   Four
other problem areas  (Remedial Activities, Hazardous  Substance  Product Storage
Tanks, Petroleum Underground Storage Tanks, and Exempt Storage Tanks) also were
addressed by all Workgroups, but were  merged with  existing/new problem areas.
For  the  Remedial Activities, the Other  Health Effects Workgroup  and Welfare
Effects Workgroup combined this problem area with Removal Activities to create
a new problem area called Superfund Removal and Remedial Activities.  Similarly,
the  Ground Water  Valuation Workgroup combined Hazardous  Substance  Product
Storage Tanks,  Petroleum Underground Storage Tanks,  and Exempt Storage Tanks,
into a single problem area called Underground Storage Tanks.

      Workgroups excluded problem areas from consideration for two reasons:

  •   insufficient data  were available to properly  assess the relative
      potential risk posed by a problem area or

  •   the relative risks were too small to merit analysis.

Based on these criteria, the  Ground  Water  Valuation Workgroup eliminated  13
problem  areas:  Land  Treatment of  Hazardous Waste;  Hazardous Waste  Storage
Treatment Tanks, Drums,  and  Containers;  PCB  Wastes;  Mixed Wastes; Underground
Injection  of Hazardous  Waste;  Transportation of Hazardous Materials;  Removal
Activities;  Industrial  Facilities;   Municipal  Waste   Combustion;  Oil  Spill
Response; Chemical and Industrial Manufacturing Facilities; Ocean Incineration;
and  Ocean Dumping.     The  other four  workgroups  evaluated most  of  the other
problem  areas.

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                           CHAPTER 3. STUDY RESULTS

      This  chapter  addresses  general  results  reported  from  each  of  the
Workgroups; specific rankings of the Workgroups; methodological and data factors
affecting the rankings; and data quality and confidence.

3.1  GENERAL RESULTS

      This  section  draws  upon  the highlights  of the results  reported in the
individual  reports.    While  Appendix  C summarizes  approaches,  data  use  and
results, the individual reports contain additional information.

      3.1.1  Acute Events

      The Acute  Events Workgroup provided  recommendations in three key areas:
new data collection  efforts; revisiting risk rankings/estimates of relative risk
over time; and greater data centralization.

  •   New  Data  Collection:   Two  criteria were  employed  to  formulate
      recommendations:

        •   data were especially poor and

        •   the relative risks may be greater than the numeric score may
            reflect.

      With few exceptions, data needs  are  greatest  for  problem areas in
      the low relative risk ranking group.   The Workgroups stressed that
      the following  problem  areas  appeared to  warrant  additional work:
      Ocean  Dumping,  Combustion   of Municipal Wastes,  Mining  Waste,
      Municipal Landfills, and Mixed Wastes.

  •   Revisiting risk rankings/estimates of relative risks over time:  The
      Workgroup  recommended   that  all  the  problem  areas  be  assessed
      periodically to  determine if regulatory  or technological changes
      have affected the relative risks posed by acute events.

      Greater  Data  Centralization:     The  Workgroups   concluded  that
      considerable  information is   available   through  State  agencies,
      Regional EPA  offices,   different offices within  EPA,   and  other
      federal agencies.  While  many  problems are  involved in developing
      an accurate, reliable centralized reporting system,  such a system
      should make a  significant difference  through  improving confidence
      in  rankings,   providing  a basis  for re-visiting  rankings,  and
      providing for  more  reliable priority  setting.

      3.1.2  Other Health  Effects

      The Other Health Effects Workgroup provided both substantive and general
recommendations.   The substantive recommendations are:

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  •   Risks  associated  with  Mixed  Wastes,   Ocean  Incineration,   and
      Underground Injection,  appear to be very low.  Additional work based
      on  health  risks,  in  the  absence  of new  information,  is  not
      recommended.

  •   Improve on cross media analysis,  especially  the  evaluation of air
      risks.   In particular, air risks  associated  with Land Disposal of
      Hazardous Wastes and Municipal  Landfills  are substantially higher
      than anticipated.

Other  recommendations  that  addressed  general  risk  assessment  activities
included:

  •   Continue  efforts  to   model  risk associated  with  waste-related
      problems.   Such  modeling offers valuable  insights  into  health
      problems and is critical  to informed regulatory decision-making and
      priority-setting.

  •   Develop consistent assumptions  for use in assessing  exposure and
      characterizing the quality of the information.

  •   Evaluate all pathways  for their potential risks  to public health.
      Air or direct  contact  risks could be  larger  than risks associated
      with the drinking of contaminated ground water.

  •   Address risks  associated with noncarcinogenic  health  effects more
      critically  (there appears to be a bias towards cancer risks).

  •   Use modeling results,  not just monitoring  data, to assess exposure,
      especially for air and drinking water.

      3.1.3  Ecological Effects

      The  Ecological Effects Workgroup  stressed that  the  absolute numerical
rankings  in  its report  should  not  be taken as  absolute  because   of  the
assumptions employed to develop rankings and the data limitations.  In general,
data  were limiting  for  many problem  areas.   The Workgroup  provided  several
recommendations,  including:

  •   In   presenting   data  on   ecological   risks,    the   associated
      uncertainties,  limited meaningful  measures of  pollutant-related
      stress, and the  lack  of  quantitative ecological risk information,
      all make the assessment of ecological risks difficult.  As such, it
      is  recommended that the  uncertainties of this  analysis be carried
      forward in  subsequent presentations of the data.

   •   Conduct  a  comprehensive  review  to  identify situations  with the
      greatest potential for significantly damaging to  important bird and
      mammal  populations.    In addition  to the  scientific literature,
      information generated  by  the  Fish and Wildlife Service, NOAA, EPA
      Regional  Offices,  and State  environmental  and  natural  resources
      agencies will  enable EPA to better focus  its efforts.

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  •   Form a task force to examine inter- and intra-Agency projects that
      have  incorporated  ecological  effects  data  and risk  assessment
      methodologies.   The task  force should:   (1)  coordinate Federal
      efforts both within EPA  (e.g.,  the  Office  of Pesticides and Toxic
      Substances) and other departments  (e.g., Department of Agriculture,
      Department of  the  Interior);  (2)  assess available data bases and
      evaluate international  efforts  to  obtain data  specific to ecosystem
      impacts; (3) coordinate  with the  Agency-wide groups  (specifically
      the eco-risk  planning  group on Reducing  the Uncertainty in Risk
      Assessments  (RURA);    and  (4)  following completion  of  the  above
      steps, organize an international conference.

      3.1.4  Welfare Effects

      The  Welfare,  Effects   Workgroup   recommended that  welfare  damages  be
investigated carefully for these  high risk problem  areas if any new comparative
risk analysis is  initiated.  The Workgroup further recommended  that if assessing
welfare  impacts  is  a priority  for  future  regulatory  activities,  then  the
uncertainties associated with rankings and data should  be explicitly considered.

      3.1.5  Ground Water Valuation

      The Ground Water Valuation  Workgroup focused  on  the approach and analysis
employed to assess resource  damage to drinking water  supplies on the basis of
replacement costs.
3.2  KEY FINDINGS

      This section addresses  the key findings of each workgroup analyses.  Final
rankings, data quality and confidence levels, and overall confidence in rankings
are discussed.

      3.2.1  Final Rankings

      Table 1  summarizes both the relative rankings  (e.g., high,  medium,  and
low), and  the level of confidence  (indicated  by text face) of  the  rankings.
The  workgroup rankings were developed through  a  process  that  involved  the
evaluation of available  information and judgments to estimate the relative risks
associated with each problem area.

      The problem areas  in  Table 1 are ordered by decreasing severity--that is,
those judged to represent the highest risks are at the top and those  judged to
pose the least risks are at the bottom.  Because it provides a range of results
associated with the individual workgroup rankings,  Table  1 can only be used to
stratify problem areas into broad groups.

      For purposes  of this overview report, the workgroup rankings  have  been
stratified into three bands:

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  •   High:   Those problem areas that have at least two rankings  of high
      and were assessed by at least four workgroups.   This  band includes
      Municipal Landfills;  Industrial Facilities; Hazardous Waste Storage
      Treatment  Tanks,   Drums   and Containers;  and  Land  Disposal  of
      Hazardous Waste.

  •   Medium:   Those problem areas not grouped as "high" or "low" relative
      risk for purposes of this overview report.

  •   Low:  Those problem areas  that did not receive any "high" rankings.
      Problem  areas  grouped as    "low"   ranked  by no  more than  four
      workgroups and had a minimum of at least two low  rankings  by the
      Workgroups.   (While  Ocean Dumping was  ranked as high  (with  high
      confidence) within the  Ecological Effects Workgroup, the definition
      of Ocean Dumping  included  activities OSWER programs do not address.
      As such, the ranking of Ocean Dumping  within this  matrix has  been
      adjusted downward.)

      Had Superfund activities  had been grouped into one  single  category,  it
appears that the ranking would have been:  medium by the Acute Events workgroup
and high  for  the  other  four workgroups.   Given  this combination,  Superfund
activities would be moved from the "medium"  risk grouping to "high".

      Given that the ordering of problem areas shown in Table  1 has been derived
from the ranking efforts of the individual workgroups,  the  ordering of problem
areas shown in Table  1  reflects  the assumptions associated with the rankings of
each workgroup, and then some additional assumptions.  For this reason, rankings
within a workgroup  (e.g., high, medium  high, medium,  etc.)   are  more certain
than the compilation of rankings across workgroups.  Due to the limitations of
the data and methods used to develop the rankings, minor differences in rankings
among problem areas should not be construed to represent genuine differences in
aggregate, national risks.  Moreover,  these three  broad bands of problem areas
reflect professional judgment,  not risk thresholds.

      The underlying  information used  to  support rankings  shown in  Table  1
differ significantly both within and across workgroups.  The differences include
such factors as measures  of risk used for ranking and the quality of information
needed  for  ranking.    These  rankings provide  risk estimates associated  with
current emissions  that  reflect  in place controls.  Obviously,  rankings would
differ without controls.   Selected highlights  that may  assist in interpreting
Table 1 include:

   •   Industrial  Facilities:    All workgroups except  the  Ground Water
      Valuation  Workgroup  stated that they  believed  that  risks  may be
      substantially higher than the data suggest and that more data should
      be collected.

   •   Superfund  Sites:   The Other Health Effects  Workgroup considered
      current National Priorities List [NPL]  sites  (currently about 1,200
      sites) and sites  that are to be evaluated for  NPL listing (currently
      over  30,000 sites).   The Welfare Effects   and  the  Other  Health
      Effects Workgroups combined remedial and removal actions at both NPL

                                      10

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      and  non-NPL sites.   The  other  workgroups  considered only removal
      actions at  NPL or potential NPL sites.

   •   Chemical and Industrial Manufacturing Facilities:   The Other Health
      Effects Workgroup called this problem area  "Chemical  and Industrial
      Manufacturing  Facilities"  or  "Accidental  Releases at  Chemical
      Facilities."  The Welfare  Effects Workgroup called this problem area
      "Accidental Releases at  Chemical  Facilities."    The Acute Events
      Workgroup  addressed only risks posed to workers  at chemical and
      industrial  facilities.

   •   Underground Storage  Tanks:   This  problem area was only considered
      by the Ground Water  Valuation Workgroup.   It includes:   hazardous
      substance  product  storage  tanks,  petroleum underground  storage
      tanks, and  exempt underground storage tanks.

   •   Underground Injection of Hazardous Waste:   The Other  Health Effects
      Workgroup  considered injection of hazardous waste  into  Class  I
      injection wells.  The  other workgroups  considered all underground
      injection of hazardous waste regulated under 40 CFR Part 267 Subpart
      G and 40 CFR Part 146.

      Table 1 suggests  that the  relative rankings of problem areas are generally
consistent with program priorities,  and  that some problem areas not necessarily
perceived as high program priorities could be ranked high even though they are
supported by relatively uncertain  information.  Table 1 also suggests that those
problem areas with better  supporting  information tended to be  associated with
higher confidence and also were actually ranked (as  opposed to not being ranked
or being combined with other problem areas).

      The Acute Events Workgroup ranked Transportation of Hazardous Materials,
Oil & Gas Operations Waste, Oil Spill Response,  Accidental  Releases at Chemical
Facilities,  Petroleum Underground Storage Tanks, and Industrial Non-Hazardous
Waste Facilities  highest;  and  ranked Ocean Dumping,  Remedial Actions  at NPL
Sites, Municipal  Waste  Combustion,  Land Treatment of Hazardous  Waste,  Mining
Waste, Ocean Incineration, Mixed Waste,  and Municipal Landfills lowest.

      The Other Health Effects Workgroup ranked  Superfund Activities, Industrial
Non-Hazardous Waste Management  Facilities,  Solid Waste  Management  Units,  and
Hazardous Waste Storage and Treatment Tanks, Drums, and Containers  at  the top
of their list.  In contrast to  the  Acute Events  Workgroup,  Oil  Spill Response
was among  the  lower  risk problem areas.   It  is worthwhile noting  that Solid
Waste Management Units  received a  high ranking  in this workgroup,  but there was
a  lack  of  data to  support this  ranking at the  time  that the  rankings  were
developed.   However,  the Regulatory  Impact Analysis (released after drafting of
this report)  for  the Corrective Action  rule  generally  supports the  rankings
assigned by this workgroup.

      In  contrast to  the  Acute  Events Workgroup,  the  Ecological  Effects
Workgroup  ranked Ocean  Dumping as  the highest.  This ranking assumed that Ocean
Dumping includes  practices that  are  not and are not expected to be addressed by
OSWER because  they are  addressed  by other programs   (e.g.,   air  or  water).

                                      11

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However,  like the  Other  Health Effects  Workgroup,   the  Ecological  Effects
Workgroup ranked Remedial Actions at NPL Sites  in  the  high  risk group.   Other
problem  areas that  were ranked  as  posing  relatively high  risk were:  Land
Disposal of Hazardous Waste, Municipal Landfills, PCB Wastes, and Mining Wastes.
Problem  areas that  particularly  low  included:    Underground  Injection  of
Hazardous   Waste,   Oil   Spill   Response,    Solid   Waste  Management   Units,
Transportation of Hazardous  Materials,  Exempt Underground Storage  Tanks,  and
Accidental Releases at Chemical Manufacturing Facilities.

      The  Welfare  Effects Workgroup  placed  problem  areas  into three  broad
relative risk categories.  The Workgroup concluded that comparisons beyond this
level of detail were not justified,  considering the quality of data supporting
individual  scores.    At  this   level  of  comparison,   however,  the  Workgroup
expressed reasonable  confidence  in its conclusions.   Superfund Activities, Solid
Waste  Management  Units,  Land  Disposal  of  Hazardous  Waste,   Industrial
Non-Hazardous Waste Facilities,  Petroleum Underground Storage Tanks (Including
Used Oil),   Municipal  Landfills,  Hazardous Waste Storage and Treatment  Tanks
were all ranked relatively high by the Welfare  Effects Workgroup.   Combustion
of Hazardous  Waste,  Transportation,   Hazardous Substance Underground  Storage
Tanks,  Land Treatment of  Hazardous  Waste, Oil  Spill  Response,   Underground
Injection,  Ocean  Dumping,  PCB  Wastes,  Accidental   Releases   at  Chemical
Manufacturing  Facilities,  Mixed  Waste,  Ocean  Incineration  were  all  ranked
relatively low.

      The Ground Water Valuation Workgroup report estimated aggregate national
costs of releases  or  potential releases  to  ground water  from  OSWER  problem
areas.   The principal findings were:

  •   Ground Water resource  damage is extremely variable across problem
      areas.  It is also extremely variable across facilities in problem
      areas due to site-specific  differences  in use patterns, pollutant
      releases,  hydrogeological  characteristics,   and  availability  of
      substitute water sources.

  •   Nationwide, underground  storage  tanks  produce  the highest  total
      resource damage  ($15 billion)  in present value terms.

  •   NPL sites have the  highest  mean resource  damage  (present value of
      $9.7 million per site).

  •   The size of the  facilities is highly correlated with  high resource
      damage.

Other highly  ranked problem  areas  were:  Municipal   Landfills,  Solid  Waste
Management Units, Land Disposal of Hazardous  Waste, Mining Waste,  Oil  and Gas
Operations  Waste,  Industrial (Subtitle  D) Landfills,  and  Land Treatment  of
Hazardous Waste.
                                      12

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      3.2.2  Data Quality and Confidence Levels

      The level of confidence that Workgroups expressed in their rankings varied
greatly.  While they may have had confidence in broad groupings of problem areas
(e.g., high vs. low),  they  reported  considerable  uncertainty in relative risk
rankings for most problem areas.   Thus, while  it is possible to derive rankings
for problem areas that subdivide  the problem  areas  presented,  the differences
in the rankings would not be as robust.

      The Other Health Effects  Workgroup,  the  Ecological Effects Workgroup, and
the  Acute  Events  Workgroup   all developed   separate  scales  for  assigning
confidence levels to problem areas.   The  Other Health Effects  Workgroup scale
represents  the confidence  the Workgroup  expressed  in   the accuracy  of  its
assessment  of the  relative risk  posed  by  a  problem area.   The  rankings,
therefore, reflect staff judgments, based upon available data,  of the relative
risk posed by a problem area.   It  should be stressed that  the confidence levels
are not  simply data  quality  indicators.    In many  problem areas,  data were
lacking or of extremely poor quality,  but  the Workgroup expressed a high degree
of confidence in its assessment of the relative potential risk  posed.

      The Acute Events Workgroup and  the Ecological Effects Workgroup developed
a confidence  level  scale based  on  the quality of  the  data used  to develop
relative  risk assessments.    Both used a similar  method for   assessing data
quality.  The Workgroups assigned  a  score  to  each parameter used to calculate
relative potential risk.  Factors such as the degree of documentation supporting
reported effects,  the  generalization  of data,  and  the degree to which data were
based  on professional  judgment  were  used   to  assess  the quality of  data
supporting  each parameter.    The number  of  parameters  supported  by  good,
moderate, or poor quality data then  determined the  overall data quality score
a problem area received.

      Confidence levels for the Welfare Effects Workgroup report  were derived
from two sources:   problem area summary sheets and the text of  the workgroup's
report.  These sources were reviewed by the Workgroup  to determine the degree
to which findings were based on comprehensive  historical data,  modeling data,
or professional judgment.   The problem area summary  sheets and  the text of the
report then were reviewed for any  indications  of  the  degree of confidence the
Workgroup expressed in the data used to estimate problem area rankings.

  •    Historical data  existed and/or the Workgroup  expressed a high degree
      of confidence: high.

  •    When little historical data existed or the Workgroup  used model data
      and/or the Workgroup expressed  only  medium confidence: medium.

  •    When the Workgroup  findings were based  primarily  on professional
      judgment (i.e.,  no  data  existed): low.

      Confidence levels for the Ground Water  Valuation Workgroup  report were
derived from Exhibit 13 of its  report.  This  exhibit lists the  sources of data
for  each problem area  and provides a  relative  assessment  of data quality.   As


                                      13

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such,  the  characterizations of  good,  fair,  or  poor were  used because  they
corresponded directly with rankings of confidence.

      3.2.3  Overall Confidence in Rankings

      Workgroups expressed particularly low confidence in four problem areas:

  •   Mixed Wastes;

  •   Other Treatment, Storage, and Disposal Facilities;

  •   Industrial Facilities; and

  •   Solid Waste Management Units.

With the exception of  Other Treatment, Storage, and Disposal Facilities, all the
Workgroups  stated  that they either  had low  confidence  in their  estimate  of
relative risk  or did  not  have enough  data  to assess the  risk posed by the
problem area.  For the Other Treatment,  Storage, and Disposal Facilities problem
area,  all  stated that they had  low  confidence in their estimate  of relative
potential risk, except the Acute Events Workgroup,  which that its estimate was
based on moderate quality data only.

      All Workgroups expressed  a high/moderate level of confidence that they had
accurately  identified  the risks  associated with Oil  and  Gas  Operations Waste.
Workgroups also generally reported a high to moderate level of confidence in the
findings for the problem  areas Petroleum Underground Storage  Tanks and Exempt
Storage Tanks.


3.3   METHODOLOGICAL AND DATA FACTORS AFFECTING WORKGROUP RANKINGS

      The type and quality of  information affect the type of method that might
be appropriate for supporting  the rankings of problem areas.

      The methodology each workgroup  ultimately used  had considerable impact on
the final  ranking.   In some cases, differences in one or  two  parameters in a
workgroup's methodology had a  substantial  impact on  the  relative risk score a
problem area received.  Below,  these  critical  parameters, or "driving factors",
are identified for  each workgroup.  Refer to Appendix C for  a more detailed
summary of  each workgroup methodology.

      3.3.1  Acute Events

      The  Acute  Events Workgroup's  method assumed  the overall relative risk
posed by a  problem area is  comprised of four  effects:
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  •   acute exposure health risks;

  •   chronic health risks from acute events;

  •   welfare effects; and

  •   ecological risks.

For  each effect,  relative risks  were assessed  by  summing  measures  of  the
observed  frequency of occurrence  of each  event,  the  population potentially
exposed, and the inherent hazard (based on the effect type).

      3.3.2  Other Health Effects

      The main driving force in the Other Health Effects Workgroup's methodology
was cancer  risks.   Two scales (i.e., individual and  population)  were used to
estimate cancer risk  scores while  only  one  scale  was  used to assess noncancer
scores.   As a result, cancer risks tended  to drive  the  final  relative risk
rankings.  Thus,  scores used to determine ranking were  primarily formulated from
the application of an algorithm that used information from reports.

      The potential biases associated with combining high  and low estimates was
mitigated by  the workgroup's use  of professional judgment.  If  relative risk
scores were thought to be disproportionately influenced by a single parameter,
the Workgroup  would  review  the  input  parameters to ensure that reasonable
factors had been considered.   For example, the Workgroup acknowledged that for
several  problem  areas (i.e.,  Mixed Wastes,  PCB  Wastes,  Hazardous  Materials
Transportation,  and Underground  Injection),  the  relative  risk  scores  were
initially  heavily  influenced by  the  toxicities  and  volumes  of  chemicals
released.  The Workgroup  thought  this gave an inflated estimate of the relative
risk associated with these problem areas and revised risk estimates downward.

      3.3.3  Ecological Effects

      The Ecological Effects  Workgroup  estimated relative  risk as a function of
four composite parameters:

  •   number of sources and releases in a problem area;

  •   contaminant concentration;

  •   receptors;  and

  •   toxicity.

Each composite parameter  was  derived by taking the mean  score of  a  series of
data elements.   The  first three  composites  were then added  together,  and the
result  was  multiplied by the toxicity  composite.   This  approach made  the
relative  risk  score  heavily dependent  on  the  toxicity  composite  score.
Furthermore, as the approach used for developing the toxicity composite scores
was based on selecting  the highest ranked contaminant in each toxicity category,

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the effect of the toxicity composite on  the  relative  risk score may have been
multiplied even further.
      3.3.4  Welfare Effects

      The Welfare Effects Workgroup's methodology was,  in many ways,  the most
flexible and  least  prone to  being overly  influenced  by a  single  parameter.
However, the methodology  does seem to weight natural  resource damages higher
than other parameters, at least in the problem areas ranked low.

      The  Workgroup considered  welfare effects  for  three  general  resource
categories:

  •   residential and commercial property (four types);

  •   natural resources (two types);  and

  •   surface water (two types).

Within  each category,  potential  types of  damage  were identified  and  the
Workgroup assigned a welfare damage score to each type.  As a result, the total
welfare score  received  by a problem  area  could be heavily  influenced  by the
welfare  damage score  for natural resources  (because  of  its  four types  of
damage).

      3.3.5  Ground Water Valuation

      The number,  distribution, and location of facilities within a problem area
were three key factors that affected final relative  risk rankings for the Ground
Water Valuation Workgroup.  The value users placed  on  ground water  located in
different areas was not considered, however.  Thus,  a  problem  area  was likely
to be highly ranked if it affected a  large  number of aquifers,  irrespective of
what value users placed on  the individual  aquifers.  Therefore, problem areas
where facilities or sources were distributed over many  aquifers were much more
likely to receive higher rankings  than those that had a narrower distribution.


3.4  RANKINGS AND PUBLIC PERCEPTION OF RISKS

      The  importance  of public  perception and  effective  communication  is  a
priority for successful program management.  Program history suggests that the
public  wants  to  know that a site  is  "safe" before  EPA or a State  leaves the
site.   Moreover,  it is likely that  the judgment as to  what constitutes safe
varies with the site and the people surrounding that site.  Given this premise,
there is an increasing concern for better  understanding the  public, improving
communication  with  the public,  and  improving  methods for  addressing  public
concerns.
                                      16

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      During the preparation of Unfinished Business,  EPA -reviewed puMi<* polling
data conducted over a two-years by the Roper Organization.   The survey focused
on perceptions of 15 environmental problems.  Because surveys did not directly
match the 31 EPA problem areas;  they did, however, match several problem areas.
As  a result,  Unfinished  Business employed  professional   judgment  to  allow
comparison of Roper's results with EPA's ranking of problem areas.

      As with Unfinished Business, the OSWER Comparative Risk Study found some
difference between its rankings of problem areas and public opinion (Table 2).
Discrepancies can be  accounted for by a number  of  factors.  One  of  the most
obvious is that the public's perception of the risk a problem area poses seems
to be closely linked  to  the visibility  and  number and density of sites within
a  problem area.   The degree  to which  a  release  is noticeable  or  produces
dramatic effects is likely to  affect public perceptions of risk.  This probably
accounts for the fact  that many problem areas that were ranked high by the Acute
Events  Workgroup often  tended to be ranked  high  in  the  Roper  poll.    The
comparison of the overall results of the OSWER Comparative Risk Project with the
results of the Roper study suggest that  the public may not place a lesser value
on risks  posed  by  a number of  problem  areas  where  the damage caused  is less
obvious or more long-term.  This would suggest that future attempts to increase
public understanding  of  the risks  posed  by  various  problem areas should focus
on explaining the less visible risks and  the mitigation of long-term or chronic
effects.   The more  effective that EPA  is  in  characterizing risks and what
actions have been taken  to reduce  them,  the more likely  it is that the public
and  EPA  can come into a common alignment  that supports the rationale behind
Agency decisions.
                                      17

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                                                           TABLE 1
                              COMPARISON OF WORKGROUP RANKINGS OF OSWER PROBLEM AREAS
                                                        Workgroup Ranking
                                          Acute
                                          Events
           Other
           Health
          Effects
         Ecological    Welfare  Ground-water
          Effects     Effects    Valuation
 Municipal Landfills
            M
                       H
            H
 Industrial Facilities
H
H
H
oo
 Hazardous Waste Storage and Treatment       //
 Tanks, Drums, and Containers
 Petroleum Underground Storage Tanks
 H
            H
 M
           M,
  H
 H
All workgroups except the Ground-Water
Valuation Workgroup  stated that they
believed  that risks may be substantially
higher than the data suggests and that
further data collection activities should
be undertaken.  The  Other Health Effects
Workgroup called this problem area
"Industrial Non-Hazardous Waste
Facilities."  The other workgroups called
this problem area "Industrial Facilities
(RCRA Subtitle D)."
 The Economic Effects Workgroup called this
 problem area "Hazardous Waste Storage and

 Treatment Tanks".
 The Other Health Effects Workgroup called
 this problem area "Petroleum Underground

 Storage  Tanks."  The other workgroups
 called this problem area "Petroleum
 Underground Storage Tanks (RCRA Subtitle
 I)."
 Land Disposal of Hazardous Waste
           M,
                       H

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                                                         TABLE 1
                       COMPARISON OF WORKGROUP RANKINGS OF OSWER PROBLEM AREAS (CONTINUED)

                                                       Workgroup Ranking
                                        Acute
                                        Events
         Other
         Health
         Effects
       Ecological    Welfare  Ground-water
        Effects    Effects    Valuation
Superfund Sites
          H
H
Remedal Activities
                                   The Other Health Effects Workgroup
                                   considered current NPL and potential NPL
                                   sites (over 30,000  sites).  The Economic
                                   Impacts and Other Health Effects
                                   Workgroups combined remedial  and removal
                                   actions at both  NPL and non-NPL sites.  The
                                   other workgroups  considered only removal
                                   actions at NPL or  potential NPL sites.

                                   The Ground-water Valuation Workgroup
                                   called this problem area "NPL Sites".
Transportation of Hazardous Materials
Chemical and Industrial
Manufacturing Facilities
K

H
                     L

                     L
                                          -   The Other Health Effects Workgroup called
                                              this problem area "Chemical and Industrial
                                              Manufacturing Facilities" or "Accidental
                                              Releases at Chemical Facilities."  The
                                              Economic Effects Workgroup called this
                                              problem area "Accidental Releases at
                                             Chemical  Facilities."  The Acute Events
                                             Workgroup addressed only risks posed to
                                             workers at chemical and industrial
                                             facilities.
Underground Storage Tanks
                                          TT  This problem area was only considered by
                                              the Ground-water Valuation Workgroup.  It
                                              includes:  hazardous substance product
                                              storage tanks, petroleum underground
                                              storage tanks, and exempt, underground
                                              storage tanks.
09 Spin Response
 H
L

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                                                            TABLE 1
                         COMPARISON OF WORKGROUP RANKINGS OF OSWER PROBLEM AREAS (CONTNUED)

                                                         Workgroup Ranking
                                          Acute
                                          Events
          Other
          Health
         Effects
       Ecological    Welfare  Ground-water
         Effects     Effects   Valuation
  Oil and Gas Operations
 H
           M
           M
                                    The Acute Events Workgroup only addressed
                                    the  effects of blow-outs at oil wells.
                                    Other workgroups considered the effects of
                                    releases from wastes produced as a result
                                    of oil and gas activities.
  Solid Waste Management Units
  Exempt Storage Tanks
 M

 M
H

M
          ML
          M.
K)
O
 Mining Wastes
                              M,
  Other Treatment Storage,
  and Disposal Facilities

  Removal Activities

  Combustion of Hazardous Waste
M
M
          M
M
                     M
                                   The Other Health Effects Workgroup called
                                   this problem area "Exempt Tanks."  The
                                   Economic Workgroup called this problem
                                   area "Exempt Storage Tanks."  The other
                                   workgroups called this problem area
                                   "Unregulated (Agricultural and
                                   Residential)  Underground Storage Tanks."

                                   The Acute Effects Workgroup excluded
                                   mining wastes located at NPL sites; other
                                   workgroups  did not explicitly exclude
                                   mining wastes at NPL sites.
                                   In addition to wastes considered by other
                                   workgroups,  the Other Health Effects
                                   Workgroup included wastes from smelting
                                   and refining along with other types of
                                   mining waste considered by the other
                                   workgroups.

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                                                            TABLE 1
                          COMPARISON OF WORKGROUP RANKINGS OF OSWER PROBLEM AREAS (CONTNUED)

                                                          Workgroup Ranking
Acute
Events
Other
Health
Effects
Ecological
Effects
Welfare Ground-Water
Effects Valuation
Municipal Waste Combustion

Hazardous Substance/Product
Underground Storage Tanks
PCB Wastes

Land Treatment of Hazardous Wastes

Underground Injection of Hazardous Waste
£

M
M

£
          MH
 M
 L

M.

 L
MH

 M

ML
            L

            L
L

L

L
Mixed Wastes

Ocean Dumping
 L

 L
 L

 L
 M

 H
L

L
              The Other Health Effects Workgroup called
              this problem area "Hazardous Substance
              Tanks."  The other workgroups called this
              problem area "Hazardous Product
              Underground Storage Tanks (RCRA Subtitle
              I)-"
                                             The Other Health Effects Workgroup con-
                                             sidered injection of hazardous waste into
                                             class I injection wells.  The other
                                             workgroups considered all underground
                                             injection of hazardous waste  regulated
                                             under  40 CFR Part 267 Subpart G and 40
                                             CFR Part 146.
The Other Health Effects and Economic
Effects Workgroups considered risks from
ocean dumping of municipal waste, dredge
spoil, and discharges of industrial waste
into  the ocean.  The Ecological Effects
Workgroup considered risks from ocean
dumping of municipal waste and dredge
spoil. The Acute Events Workgroup
considered risks from ocean dumping of
municipal waste only.  The Other Health
Effects Workgroup called this problem, area
"Ocean Disposal." The  other workgroups
called this problem area "Ocean Dumping."

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                                                             TABLE 1

                        COMPARISON OF WORKGROUP RANKINGS OF OSWER PROBLEM AREAS (CONTNUED)


                                                          Workgroup Ranking
                                           Acute
                                           Events
                                                     Other
                                                     Health
                                                    Effects
    Ecological   Welfare  Ground-Water
     Effects     Effects    Valuation
Ocean Incineration
                  Notes on the Comparison Table
Letters reflect relative risk rankings judged for problem areas:


3t        High or higher relative risk potential


          Moderately high relative risk potential


          Medkjm or moderate relative risk potential


          Moderately tow relative risk potential


          Low or tower relative risk potential


          The workgroup did not consider this problem area .
 •AL
Uncertainty is reflected in lettering as:


 H     Low uncertainty (high confidence)


 ${,     Medum uncertainty (medium confidence)


 H     High uncertainty (tow confidence)


No attempt was made to "add" risks across Workgroups or compare the importance

of one Workgroup as more significant than another.  Note that differences in

problem areas addressed is due to a combination of available data and scope.

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             TABLE 2.  ROPER SURVEY AREAS AND OSWER PROBLEM AREAS
    Public
 Perception of
Risk and Ranking

      High
          Roper
       Survey Area

Chemical Waste
Disposal
                   Chemical Plant
                   Accidents
                   Combustion
Moderate
Lower
Oil Tanker
Spillage


Effects

Strip Mining
        Corresponding Problem Area
        	(and Workgroup)	

Land Disposal of Hazardous
Waste (all Workgroups)

Hazardous Waste Storage and Treatment
Tanks, Drums, and Containers (all but
Ground Water Valuation)

Other Treatment, Storage, and Disposal
Facilities  (all)

Chemical and Industrial Manufacturing
Facilities (Acute Events and
Ecological Effects)

Accidental Releases at Chemical and
Industrial Manufacturing Facilities
(Other Health Effects and Welfare
Effects)

Air Pollution Combustion of Non-
Hazardous Waste including Non-
Hazardous Municipal Waste (all but
Ground Water Valuation)

Ocean Incineration (all but Ground
Water Valuation)

Oil Spill Prevention and Response
(Acute Events and Ecological Effects)

Oil Spill Response (Other Health
and Welfare Effects)

Mining Wastes (all but Ground Water
Valuation)

Mining Waste Sites (Ground Water
Valuation)
                                      23

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                         CHAPTER 4.   INFORMATION  NEEDS

      In general, the composition of data often guides analysis and affects its
results, just as data deficiency limits analysis.  Also, the Workgroups reported
that they felt  that  limitations  in  the  data precluded  estimating the absolute
risks posed by problem areas.


4.1  GENERAL INFORMATION NEEDS

      For this study, information needs have been  prioritized by considering the
types of  information needed to support  program activities  and the  cost  of
obtaining the  information.   , The  rankings in Table  1  have been  developed  by
averaging the  workgroup rankings.   Thus,  uncertainties  associated with the
rankings are  reflected  in the  text face but were  not  used  to  array  problem
areas.

      Table  1  suggests   that OSWER  has  generally  obtained higher  confidence
information in the highest ranking problem areas.  The rankings of problem areas
make it clear that there are significant information gaps  exist.

      In terms of future data needs,  the Workgroups expressed  low confidence in
rankings for:  Mixed Wastes,  Other Treatment, Storage, and Disposal Facilities,
Industrial Facilities,  and Solid Waste Management Units.   Thus,  future  work is
recommended to improve understanding of  the  risks these problem areas pose.  In
addition,  several workgroups  expressed many data needs related  to the individual
effects they had  studied.  The  Ground Water Valuation Workgroup  eliminated 13
problem areas from consideration since adequate .data were  not available.

      The relatively high risk rankings of problem  areas  that were ranked high
for reasons other than  risks to human health suggest that protection of human
health may not be the most sensitive indicator of  concern.   This supports the
position that OSWER programs are taking  in  assuming  that  ecological  and other
welfare impacts  may be more sensitive  to  environmental  stress than  public
health.  This assumption  has resulted  in  shifts  in program activities  and
development of guidance  materials for program assessment  efforts.

      As discussed later in this Chapter, OSWER has  initiated efforts to collect
and refine information  in a  number  of areas  to assist  in  better  understanding
risks to public health  and the  environment.  Nevertheless, there are a number
of areas where additional information is important  to the  development of sound
strategic planning.   For example,  given that uncertainty  is high  for  mixed
waste,  it is  possible that  risk estimates associated with mixed wastes  could
change significantly with additional information.


      4.1.1  Program Recommendations

      The following  long-term  recommendations  for  the  continued support  of
strategic planning are:
                                      24

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  •   risk rankings be reviewed periodically based on information gathered
      and

  •   a centralized repository should be established for the maintenance
      of information used to perform the rankings.
      4.1.2  Information Needs

      In order to provide  for  a  more  consistent  basis to support decisions on
program direction, it is recommended that options for improving information in
the following areas be developed:

  •   Information was especially limited and of low quality in the areas
      supporting  workgroup  efforts  for  Ecological  Effects,  Welfare
      Effects, and Ground Water Valuation.  Consideration should be given
      to enhanced data collection/methodological work in these areas.

  •   Accepting  the  finding that  some pathways  for exposure have  not
      consistently been assessed, it is recommended that efforts be made
      to better assess major risks from all pathways.

  •   For  four  problem  areas   (i.e.,  Mixed Wastes,  Other  Treatment,
      Storage, and Disposal Facilities, Industrial Facilities, and Solid
      Waste  Management  Units),  the  Workgroups  seem to have expressed
      particularly low confidence in their findings.   The  extent of future
      analyses might  improve if  the Agency acquired  more  data in these
      areas.

  •   The Ground  Water  Valuation Workgroup eliminated 13  problem areas
      from  consideration,   partly due  to  lack  of  information.    The
      Ecological  Effects Workgroup  did not consider  Removal  Actions at
      Non-NPL Sites since insufficient data were available to estimate the
      ecological effects of releases during removal actions.   To improve
      future studies,  EPA may want to address  the  problem  of obtaining new
      data sources for these problem areas.

      Finally, in order to improve upon the confidence of the findings of this
and future studies, sensitivity analyses of the use of alternative methodologies
and the corresponding impacts on final rankings would be useful.

      4.1.3  Ongoing Information Collection Efforts

      The need  for much of this  information  was recognized  even  before this
effort was initiated;  OSWER has embarked on efforts to fill some of these needs.
More specifically, information  on chemical-specific concentrations in hazardous
waste streams is  being addressed through  the  following information collection
efforts:   the  Treatment,  Storage,  Disposal and  Recycling  Survey;  and  the
Generator Survey.  There has also been an increasing awareness of the need for
consideration of  the risks associated with exposure  to different media.   This
issue is being addressed though improved guidance  in the review of the Superfund
Public Health Evaluation Manual  and the RCRA  Facility Investigation  Guidance.

                                      25

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Moreover,  OSWER is  piloting an  effort  to  determine  the reasonableness  of
combining  information  from  different  surveys  that  the Agency has  collected
(including the  air and water programs)  in order to better  characterize both
hazardous and non-hazardous waste  streams through the OSWER Waste System Model.
The development of this model requires extensive coordination across different
Agency groups and should aid in presenting information in a consistent form.

      Recognizing the importance of public health risk information in supporting
decisions  for  all  OSWER  programs,  we  are  undertaking studies  to  better
understand metals movement  in the environment, development of probabilistic risk
estimates (along with associated uncertainties), and improvement, of guidance for
the implementation of existing OSWER programs.

      While  the limitations  of  information that  has  been  vised to  support
economic  estimates  of  environmental  impacts  may  be  most  relevant  to some
readers, they are  also  generally  the  product of more analyses and are subject
to great uncertainties.  Decisions  for the collection  of such information are
likely  to  consider  the   need  for  such  information   to support  regulatory
activities, the likelihood that such information can be made credible, and the
resource requirements associated with the collection of the information.

      Finally,   recognizing   the   costs   associated  with   the   cleanup  of
radiologically contaminated waste  (especially soils), OSWER programs are working
with other Agency programs and other Federal agencies to assess information on
technological methods  for  cleanup of existing  sites and assessment of  risks.
These efforts may  lead  to  a unified Agency program to develop technologies for
the cleanup  of  radiologically contaminated  soils as well  as  support for both
international and  EPA  decisions  on ocean  disposal of  low  level  radioactive
wastes.

      To  better   understand  the  relationship  between  public  and   Agency
assessments  of  risks,  OSWER  has  initiated  two  studies  to examine   public
perception of risks  associated with its programs.   The first of these studies
is examining the relationship between different  types of sites associated with
chemical risk (e.g., hazardous waste treatment facilities and Superfund  sites)
and the  influence  of different socioeconomic variables on risk perception. The
second  study is  examining  public  perception  of  the  risks  associated with
alternatives  for disposal  of low-level radioactive wastes (including land and
ocean  disposal  options) is to undertake.  One  outcome of these; studies  should
address  the issue of how the Agency might improve on its  approach to addressing
the public or different segments  of the public when faced with a decision for
cleanup.

      These studies of public perception,  should  provide insight, as  to  the types
of  variables  that  affect the public  thinking  on issues  related  to OSWER
problems.   In  addition to  the above studies,  a  variety of  studies  on risk
communication  are  designed  to improve  dialogue between  the Agency  and the
public.   Taken  together,  these  studies  should provide  a basis  for  improved
communication and  support  of cleanup  options selected.
                                       26

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4.2  ACUTE EVENTS

      A key problem in  applying  the  Acute  Events  comparative risk methodology
was  that  data for  nearly every  OSWER  problem area  were incomplete  and not
focused on the event.   Very little data were available on potential population
exposure  and the  frequency  of   acute  events.    Therefore,  the accuracy  of
parameter estimates varied greatly among problem areas.

      Often  the  Acute  Events  Workgroup experienced  difficulty  in  obtaining
information on the location of a facility.   Also  it was difficult to identify
which chemicals  and what quantities were  typically released during  an acute
event.  When  possible,  this  information was obtained from  data  bases or case
study reports, but  often no  data were available.    The  Acute Events  Workgroup
expressed concern  over  the  absence  of any  discussion  concerning illegal  or
unpermitted dumping.  Very little data are  available in  this  area, and no study
methods have been developed.


4.3  OTHER HEALTH EFFECTS

      For  the Other  Health  Effects Workgroup,  comprehensive   risk  modeling
studies rarely covered all of the  potential exposure  pathways  through which
health risks might occur.  The available exposure data were very limited and of
variable quality.   There was also considerably less  information on  noncancer
risks than on cancer  risks, and  far  fewer  national  modeling studies  have been
conducted to  assess  noncancer risks.   For most problem  areas,  the  Workgroup
could only  synthesize existing  information on  non-carcinogenic  chemicals and
their potential effects.  The availability of methods  for the characterization
of risks as probabilities, fuller characterization of  the severity of effects,
and characterization  of  the uncertainties  is  desired.   Such information would
not only be useful in supporting more relevant decisions within the Agency but
should also improve our ability to communicate risks to  the public.


4.4  ECOLOGICAL EFFECTS

      Data  availability  for  the  Ecological Effects Workgroup  was  a  major
limiting factor.   For  many  problem areas,  the scores  for  concentration and
receptor composites were based largely on professional judgment.


4.5  WELFARE EFFECTS

      The Welfare Effects  Workgroup's methodology relied heavily on  its best
professional judgment.   Future analyses may also want to consider aesthetic and
potential use values,  where sufficient data were not available.
4.6  GROUND WATER VALUATION

      Data deficiencies required the Ground Water Valuation  Workgroup  to make
assumptions about the environmental settings  of various types of facilities or

                                      27

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sites, hydrological parameters,  exposed populations,  types of  waste  handled,
facility size, and water-use  patterns.   Future comparative risk  analyses may
want to consider  the effects of ground water contamination prevention programs,
which were not considered in this project.


4.7  PUBLIC PERCEPTION OF RISK

      It is clear from the differences  in  the  rankings  between  public opinion
polls and the Agency's efforts to address environmental concerns that there is
considerable work to  be  done  in improving communication with the  public.   As
part of the recently released A. Management Review of  the Superfund Program, also
known  as  the  "90 Day  Study  of  the  Superfund  Program",  the  Administrator
identified a goal of  "encourage  full participation  by  communities."   This and
other activities within the Agency signal  an increased  emphasis on efforts to
provide effective communication with the public.
                                      28

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                                  APPENDIX A

                                   GLOSSARY
Term
                                    Definition
acute event
aquifer
beneficiation
(mining)

bioconcentration
absolute risk     An estimated level of risk intended as a representation of the
                  true risk (see relative risk).

                  The sudden,  unplanned release  of hazardous substance(s)  that
                  pose a threat to public health,  welfare, and/or the environment
                  and result in either acute or  chronic  exposures.

                  The permeable rock strata or sediment  that is  saturated with
                  ground water and may allow free movement of ground water.

                  The treatment of raw materials (i.e.,  iron ore)  to improve
                  the material's inherent properties in preparation of smelting.

                  The process  by which organic  chemicals and certain  metals
                  accumulate in tissues of exposed organisms.  When the organisms
                  are  consumed by  predators,  some  of these  pollutants  can
                  increase in  concentration in the predator.

                  Any  waste,  hazardous  or  nonhazardous,   existing  in  large
                  quantities.

                  The potential  or probability   of  contracting  cancer  due  to
                  exposure to  carcinogenic  substances.   Cancer risk  often  is
                  expressed as  expected  number  of cases  (population  risk)  or
                  excess lifetime probability per person (individual risk).

ecological impact  The damage to natural components of an ecosystem resulting from
                  the contamination of environmental media, such as soil, surface
                  water, ground water, and air.
bulk  waste
cancer risk
economic effect
                  The loss in value of materials,  property,  natural resources,
                  food supplies, or recreational resources due to damages caused
                  by environmental problem areas.
                                     A-l

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                             GLOSSARY (Continued)
      Term                                      Definition
extraction        The act or process of removing natural resources.
(mining)

ground water      The contamination of subsurface waters that result in
damage            unusable  drinking  water  supplies  and  the  need  for  an
                  alternative source of drinking water.

health effect     The human  injury,  illness,  or death that are  the  result of
                  exposure to hazardous substances.

low-level (radio- Radioactive wastes that consist of radionuclides, lab
active) waste     wastes, or transuranic nuclides at concentrations of less than
                  100 nanocuries/gram.

municipal waste   Non-hazardous waste, typically household waste and waste from
                  small commercial firms,  regulated under RCRA Subtitle D.

microbial         The transformation of substances in aquatic or soil
degradation       environments by microscopic organisms.

mixed waste       Wastes that contain both  radioactive waste and RCRA hazardous
                  waste and are regulated by  EPA as hazardous waste under RCRA.

National Priority EPA's list of the most serious uncontrolled or abandoned
List  (NPL)       hazardous  waste  sites   identified  for  possible  long-term
                  remedial response.

National Response The center responsible for  collecting and maintaining reports
Center  (NRG)      of  releases  of hazardous  substances  into  the  environment.
                  Notification to the NRG  marks  the beginning of the response
                  process.

noncancer risk    The potential or probability to incur a noncancer health effect
                  (e.g.,  lead poisoning, neurological disorders, liver disease)
                  due to exposure to noncarcinogenie hazardous substances.  Often
                  indicated by comparing an estimated dose to a reference dose.

welfare  effects   Effects  upon economic resources  that affect  the value  of
                  commercial activities or in the value of human well-being.
                                     A-2

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                             GLOSSARY (Continued)
      Term
                                                Definition
non-NPL site



photooxidation


reactivity
reference dose
(RfD)

relative risk
reportable
quantity  (RQ)
RCRA Subtitle C
RCRA Subtitle D
RCRA Subtitle I
solid waste
transuranic
nuclides
An uncontrolled or abandoned hazardous waste site identified
for possible long-term remedial response, but not considered
a national priority.

The process by which materials or substances undergo oxidation
as a result of radiant energy (i.e., light).

The  characteristic  assigned  to a  material  that  is  either
explosive,  reacts violently with water,  or  generates toxic
gases  when  exposed to  water  or  other liquids  that  are
moderately acidic or alkaline.

The dose of a substance above which adverse health
effects may occur.

An estimated level  of  risk intended only for  comparison to
other  relative   risk  estimates   derived  using  the  same
methodology (see absolute risk).

A threshold quantity set by EPA for certain hazardous
substances.  RQs  serve as triggers for  notification  when a
release of that hazardous substance occurs.

Regulates any material  that may  be characterized as hazardous
waste pursuant to 40 CFR Parts 260-272.

Regulates any material that may be characterized as solid, non-
hazardous waste pursuant to 40 CFR Parts  240-257.

Regulates petroleum products and CERCLA hazardous substances
that is contained in an underground storage tank.

Any material that is  discarded, to include solids, semi-solids,
liquids, or gases.

Radioactive materials that contain alpha-emitting nuclides
with an atomic number greater than 92.
                                     A-3

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            APPENDIX B




DEFINITIONS OF OSWER PROBLEM AREAS
               B-l

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                                  TABLE B-l

                             OSWER PROBLEM AREAS
      Problem Areas
                    Definition
Combustion of Hazardous Waste
Hazardous Waste Storage and Treatment
Tanks,    Drums,    and    Containers
(Subtitle C)
Land Disposal of Hazardous Waste
Land Treatment of Hazardous Waste
Industrial Facilities
Mining Wastes
Combustion of waste material that is
hazardous, including waste burned for
energy  recovery  (e.g.,  industrial
furnaces  and  industrial and utility
boilers)  (40  CFR Part  266,  Subpart
D),  hazardous waste incinerators (40
CFR Part 264, Subpart 0 and Part 265
Subpart 0),  and open detonation.

Hazardous waste storage  and treatment
tanks,   drums  and  containers,  which
are found both  at  private  hazardous
waste  management  companies  and  at
individual   industrial   sites   are
regulated under Subtitle C of RCRA.

These land sites are hazardous waste
landfills, surface impoundments, and
waste piles  under RCRA Subtitle C (40
CFR Parts 264, Subparts M and N).

The   use    of    processes   (e.g.,
photooxidation    and    microbial
degradation)  to  reduce  the toxicity
or quantity of  waste deposited at a
site.  These land treatment sites are
subject  to  RCRA requirements  in  40
CFR Sections 264.270-.317.

Nonhazardous waste  landfills, surface
impoundments,  land  treatment,  and
incineration (not including municipal
incineration)    regulated    under
Subtitle   D    of    RCRA   (surface
impoundments  are regulated under  40
CFR Parts 264 and 267,  Subpart K and
Part 267 Subpart D).

Wastes  include  solid waste from the
extraction,     beneficiation,    and
processing of ores and minerals.
                                     B-2

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                            TABLE B-l (continued)
      Problem Areas
                                                            Definition
Mixed Waste
Municipal Landfills
Municipal Waste Combustion
Oil and Gas Operations Waste
Other Treatment, Storage
or Disposal Facilities
Mixed waste  consist  of  radioactive
wastes  that  are mixed  with  a  RCRA
hazardous  waste component  and  are
regulated by EPA as  hazardous waste
under RCRA.  For the most part, these
are  low-level  wastes consisting  of
naturally-occurring radionuclides and
transuranic    nuclides    at
concentrations   less   than   100
nanocuries/gram.

Landfills   used   to   dispose   of
household waste and waste from small
commercial firms.   These  sites  are
regulated under Subtitle D of RCRA.

This area  includes  the  incineration
of  municipal  waste,  which   is  not
hazardous.

Oil  and   gas   operations   generate
drilling fluids, produced waters, and
other  wastes  associated  with  the
exploration,    development,    or
production of crude oil, natural gas,
or geothermal energy as described in
RCRA  section  3001(b)(2)(A).    (Oil
spills  into  navigable waters  of the
U.S are covered by section 311 of the
Clean Water Act.)

Such facilities are involved in waste
treatment, storage,  and disposal not
included in  those  identified above.
These   include:     waste  recycling
facilities, waste transfer stations,
container  storage   areas,   or  any
subject  to  systematic  and   routine
release.
                                      B-3

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                            TABLE B-l (continued)
      Problem Areas
                  Definition
Solid Waste Management Units
Oil Spill Response
Removal Activities
Remedial Activities
SWMUs are on-site land disposal units
associated   with   permitted   RCRA
facilities.     These   classes   of
facilities    are    subject    to
requirements   as   established   by
Section 3004U and 3008H of RCRA.

Activities  linked  to  establishing
procedures   and  requirements   for
preventing   oil   discharges   from
vessels  and  offshore  and  onshore
facilities   for   containing   such
discharges,  and for  responding  to
discharges or  threats  of discharges
to  waters  of   the  U.S.,  adjoining
shorelines, waters  of the contiguous
zone,   and waters of  the high  seas
under U.S. jurisdiction CWA §311.

Activities   related  to   Superfund
removal  actions taken  pursuant  to
CERCLA §104 (40 CFR  Part 300) and CWA
§311.   Removal  actions  will include
emergency   response    actions    to
transportation  accidents  involving
releases of hazardous substances.

Activities   related  to   Superfund
remedial  actions  taken pursuant  to
CERCLA  §104 and  40  CFR Part  300.
Remedial  actions will  include RI/FS
activities  and cleanup  at NPL and
non-NPL sites.
                                     B-4

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                            TABLE B-l (continued)
      Problem Areas
                  Definition
Chemical   Industrial   Manufacturing
Facilities
Ocean Dumping
Ocean Incineration
FOB Wastes
Chemical   industrial   manufacturing
facilities  that  process/manufacture
chemicals, especially those types of
chemicals that manufacture, process,
or  store  types  of  chemicals  that
could pose  a  threat in terms  of an
accidental release that could pose a
public  health threat.     (Focus  on
accidental  releases that  would  be
addressed under SARA Title III.)

Ocean dumping  involves  the disposal
of bulk waste (usually untreated) at
sea (40 CFR 227).   Ocean  dumping is
only  allowed  for bulk  nonhazardous
wastes as no additional treatment of
the waste is permitted.

Ocean   incineration  involves   the
incineration  of  waste  materials  at
sea.     Given  that  future   risks
associated  with  ocean  incineration
are highly uncertain but appear to be
small (ocean incineration may not be
chosen as a popular mechanism to deal
with hazardous waste),  the principle
reason  for  including  this  source
category  is that  ocean  incineration
affects the capacity question.

Polychlorinated biphenyls   (PCBs) and
PCB   wastes   primarily   found   in
electrical    transformers     and
capacitors. They are regulated under
the Toxic  Substances Control Act 40
CFR Part 761.
                                     B-5

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                            TABLE B-l (continued)
      Problem Areas
                  Definition
Transportation
Trucks, railroads and barges used to
transport hazardous substances.
Most   hazardous    substances   are
transported   by   truck   and   are
regulated   by  the   Department   of
Transportation.
Underground Injection
Underground injection  is  defined as
disposal  of  liquid  waste  material
into   isolated   geologic   strata,
placing the wastes in portions of the
earth's crust that are free from the
usual effects of the hydrologic cycle
(regulated  under 40  CFR Part  267,
Subpart G and Part 146).
Exempt Storage Tanks
Heating  oil,  farm,  and residential
tanks   that   are   exempted   from
regulation under Subtitle I.
Hazardous  Substance  Storage  Tanks
(RCRA Subtitle I)
Underground  storage  of  substances
designated   as   hazardous   (under
CERCLA).
Petroleum    Storage    Tanks   (RCRA
Subtitle I)
Tanks  that  store petroleum products
in underground storage tanks such as
gasoline  stations   (includes  used
oil).
                                      B-6

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                                  APPENDIX C
                        INDIVIDUAL WORKGROUP SUMMARIES

      This appendix addresses the scope of effort,  methodology,  data sources and
uncertainty  levels,  and results of  each  of the  five Workgroups  (i.e.,  Acute
Events, Other Health Effects,  Ecological  Impacts,  Welfare Effects, and Ground
Water  Valuation).   A  short discussion on  caveats and  other issues  is  also
provided for each Workgroup.

C.I  ACUTE EVENTS

      Scope of Effort.   The Acute Events Workgroup assessed and compared risks
arising from acute events in 24 OSWER problem areas.  Acute events were defined
as sudden,  unplanned releases of hazardous  substances  that pose  a  threat to
public  health,   welfare,   and  the  environment.    These  events   represent  a
qualitatively different kind of threat  to human health  and the environment as
compared to long-term or chronic environmental contamination.  Acute events have
the potential to cause  immediate injury, long-term health problems, significant
environmental contamination, and extensive property damage.

      Methodology.   The methodology  used (see Figure C-l)  was based  on the
assumption that the overall relative risk a problem area poses is comprised of
four different effects:

                  (1)   effects associated with acute exposures;
                  (2)   effects associated with chronic exposures;
                  (3)   welfare effects; and
                  (4)   ecological effects.

      For  each  effect  type,  relative  risks  were  assessed  by combining  the
observed frequency  of  occurrence  of  an acute  event with its  inherent hazard
(based on the effect type)  and the size of the  population potentially exposed.
A series of indices were developed to represent exposure, frequency,  and severity
(inherent hazard).  The three  indices were  summed for each  effect type to get
an effect type score.  Then, the four effect type  scores  were summed to get an
overall acute events score for a problem area.

      Frequency indices are based on historical records of  the annual occurrence
of acute events.   Exposure  indices are derived from 1980 Census-based estimates
of the number of people within one mile of a facility at which acute events may
occur.  Severity indices were estimated  as a  function of  the quantity  of a
chemical released and  the  primary  criteria reportable quantity  (RQ)  for  that
chemical (i.e.,  an indicator of inherent toxicity).  The RQ provides the minimum
quantity of a chemical  spilled or released at which a report must be made to the
National Response Center  and  is based  on  five primary  criteria:   mammalian
toxicity,   chronic  toxicity,   carcinogenic  toxicity,  aquatic  toxicity,   and
ignitability or reactivity.  The severity  indices, therefore,  are based on the
typical quantity  released  during an acute  event,  and  the inherent  toxicity
(represented by the  RQ) of typical  releases  in each OSWER  problem area.

                                      C-l

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      Data Sources  and Uncertainty Levels.   The Acute Events  Workgroup used
various data sources to estimate  index  scores.   A key problem in applying the
acute events comparative  risk methodology,  however, was  that  data for nearly
every  OSWER  problem  area was  incomplete and  not focused  on  acute  events.
Therefore, the  data sources  and  the procedures  used to  calculate parameter
estimates varied from  problem area to problem area.  Where  data proved to be
unobtainable or nonexistent,  the Workgroup primarily relied on the Acute Events
Survey.  This survey was conducted specifically for the OSWER Comparative Risk
Project  on  EPA personnel  in  program offices  responsible  for  regulating or
monitoring facilities in individual OSWER problem areas.

      Population exposure estimates were  obtained primarily  from two sources:
U.S. EPA Graphic Exposure  Modeling System (GEMS)  and U.S. Bureau of the Census,
1980 County Population estimates.  If a specific facility or source location was
known, then exposure estimates were developed  from GEMS.   If only the general
distribution of facility or source locations were known, then exposure estimates
based on U.S. Bureau of  the Census data were developed  to estimate the potential
population exposure.

      Frequency estimates  were obtained, when possible, from either case studies
(such  as  Emergency Response  Division Weekly  Pollution Reports) or  data base
estimates  (such as the  Department  of  Transportation's  Hazardous  Material
Transport Incident  Reporting System).   When case  studies  were used,  it was
assumed that they accurately reflected the number of events  that occurred in each
problem  area.    Frequency estimates  derived from  case   study  data were  all
extrapolated to one year.   In most  cases,  this  was done by either dividing by
the total number of years  reported in  the  data or by extrapolating from monthly
data to one year.  Annual frequency estimates for some problem  areas were derived
from existing data bases.   In each case, annual frequency  estimates were based
on the mean multi-year data.

      Severity estimates,  such as the Human Injuries Acute Effects Index, were
also  obtained,  when possible, from either  case study reports  (such  as EPA's
Summary of State Reports  on  Releases from Underground Storage  Tanks')  or data
bases  (such as  the  Acute  Health Effects Data Base).  However,  there was less
information on human injuries and deaths associated with acute events than for
any other parameter.   In  cases  where  no information was available, no attempt
was made to estimate this  parameter  and  the Human  Injuries Acute Health Effects
Index was dropped from consideration altogether.

      A key part of the methodology was  the identification of chemicals and the
quantities of those  chemicals that were typically released during an acute event.
When  possible,  this information  was  obtained  from data  bases or  case study
reports.  However,  estimates  from  the  Acute Events  Survey were used more widely
in this part than in any other.

      Results.   The  efforts  of the  acute  events workgroup culminated in a set
of rankings that reflects the relative risks from acute events for the twenty-
four OSWER problem areas (Table C-l) .  The problem areas are divided into three
relative risk groups on the  basis  of  their  overall rank.   The high risk group
includes the OSWER  problem areas  that received  scores of  45  to 54; the medium

                                      C-2

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risk group includes OSWER problem areas that received  scores  of 36 to 43;  and
tbe low risk group includes those OSWER problem  areas  that received scores of
25 to 34.

      Discussion.   Several  assumptions  were made in determining the relative
risks of acute  events  associated with  the 24 OSWER problem areas.  Some typical
assumptions made by the Workgroup include the following.

      •     An acute  event observed  in the past was used to predict
            an acute  event in the future.

      •     Annual numbers of events are assumed to be  constant.

      •     The frequency of acute events occurring in one area was
            extrapolated to determine  the frequency of acute events
            for the nation as a whole.

      •     The location of sensitive ecosystems  (as reflected in
            the exposure index for ecological risks) was assumed to
            be  more   likely  in areas with  low human  population
            density.

      •     The potential loss  in property  value  (as reflected in
            the welfare effects severity index) was assumed to be
            associated  with  the  ignitability  of  the  substance
            released.

      Data for  nearly every  OSWER problem  area was incomplete  in the area of
acute events.   As  such, the workgroup made a  series of assumptions about missing
data.   Therefore,  caution  should  be  exercised  in   interpreting  the  study
findings.
                                      C-3

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                                                        FIGURE C-1
                                           ACUTE  EVENTS METHODOLOGY
n
i
                  Acute Risk Parameters

             A Population Exposure
             B  Frequency
             C  Severity (Death and Injury
                Score or Mammalian Toxicity
                Score. Whichever is Higher)
            Acute Health
          Effect Composite
                Chronic Risk Parameters
             A  Population Exposure
             B  Frequency
             C  Severity (Release and
                Chronic Toxicity Score)
           Chronic Health
         Effect Composite
                                                  Overal

                                                 Risk Score

                                                    for
                                                Problem Area
                 Welfare Risk Parameters
             A  Property Exposure
               (Proportional to Population
               Exposure)
             B Frequency
             C  Severity (Release and
                IgnitabSty /Reactivity Score)
           Welfare Effect
             Composite
               Ecological Risk Parameters
             A Ecosystem Exposure
               (Inversely Proportional to
               Population Exposure)
             B Frequency
             C Severity (Release and
               Aquatic Toxicity Score)
Sum
          Ecological Effect
            Composite

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                                        TABLE  C-l

                                ACUTE  EVENTS RANKINGS
    PROGRAM AREA/SOURCE
                                          Acute    Chronic                        Total
                                         Exposure  Exposure  Welfare  Ecological    Score
HIGH
Transportation of Hazardous Materials
Oil & Gas Operations Waste
Oil Spill Response
Accidental Releases at Chemical Facilities
Petroleum Underground Storage Tanks
Industrial Non-Haz. Waste Facilities

16
12
14
14
12
12

14
13
13
12
12
11

13
13
13
11
12
12

11
13
11
11
10
10

54
51
51
48
46
45
MEDIUM

Solid Waste Management Units                  11       11      11           10      43
Hazardous waste storage and treatment  tanks    10       11      10           10      41
Land disposal  of hazardous waste              10        9      10           12      41
Other TSDFs                                    9       11      10           10      40
Removal  Activities/Other Emergency Response    10       11      10            9      40
UST Hazardous  Substance Tanks                 11       12       9            7      39
Exempt Storage Tanks                           9       11       9           10      39
PCS Wastes                                    9       10       9            9      37
Underground Injection of Hazardous Waste       10        9       9            9      37
Hazardous Waste Combustion                     8       10       9            9      36

LOW
Ocean Dumping
Remedial Actions at NPL Sites
Municipal Waste Combustion
Land Treatment of Hazardous Waste
Mining Waste
Ocean Incineration
Mixed Waste
Municipal Landfills
8
8
8
7
8
7
7
5
7
9
9
9
8
8
7
7
8
8
7
6
6
7
7
5
11
9
8
8
7
7
5
8
34
34
32
30
29
29
26
25
                                            C-5

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C.2  OTHER HEALTH EFFECTS

   Scope of Effort.  The Other Health Effects Workgroup addressed both noncancer
and cancer  risks  associated with exposures that  were not addressed  in acute
events.  This constitutes the majority  of  the types of risks that are addressed
by OSWER  program  offices in  the  support  of various  regulations.   Twenty-two
problem areas were addressed.

   Methodology.  The Other Health Effects  Workgroup (see Figure C-2) sought to
(1) build upon readily available  information and  (2)  draw from the experience
of Unfinished Business.  The Workgroup examined  both cancer and noncancer risks.
The analysis of noncancer risks was  limited to  those risks not addressed in the
Acute Events Workgroup.   The approach to developing a ranking of problem areas
involved (1) collecting information for each of the problem areas, (2) assembling
that information to support  the rankings, (3)  developing an  algorithm for the
assignment  of points  associated with risk factors for problem  areas,  and (4)
convening  a meeting  to  exercise  the  methodology.   The  development  of  the
algorithm involved considerable professional judgment on technical risk and value
judgments on the relative importance of differing types of risks (e.g., cancer
risks and noncancer risks were both used to  develop one score).

   Data Sources and Uncertainty Levels.  Comprehensive risk modeling studies were
not available for  many of the problem areas.  For areas with available studies,
all of the  potential  exposure pathways  through which  health  risks  might occur
were  rarely  covered.    Therefore,  after all available  comprehensive  risk
information was reviewed, additional data for the problem areas on the individual
parameters affecting risk were collected.   These data included types of wastes
and waste  management  units,  chemicals  or constituents  of concern,  types  and
numbers  of  releases,  exposure pathways,  concentrations  of constituents  at
exposure points, potentially exposed populations, and numbers and distributions
of sources.

   The percent  of the potential  cancer risks  covered by the models  and  the
uncertainties  associated  with the  modeling  effort were  assessed.    For  some
problem areas, several sources of risk estimates provided conflicting results.
Potential reasons  for these  conflicts were identified by analyzing the modeling
approaches  used.   The estimates  obtained with the model having the  greatest
technical accuracy were  adopted by the Workgroup.

   Generally, there was considerably less  information on noncancer effects than
on cancer  risks,  and far fewer  of these effects have  been studied  through
national modeling efforts.   Where data  were available  on individual chemicals
for which noncarcinogenic health  risks  have been  associated,  a  method similar
to that  used  in  Unfinished Business  was used.   Sufficient information  was
available to implement this scoring approach for very few problem areas, however.
Therefore,  for most  problem  areas,  the  existing  information on  chemicals
associated with noncarcinogenic health risks was summarized,  and a  qualitative
assessment  of the likelihood  that the  problem  areas would result in exposures
exceeding  RfDs was  based  on  the  findings   of  previous  investigators  and
professional judgment.
                                      C-6

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   Results. The results of Workgroup deliberations for this effort are presented
in Table C-2.   As explained in the Workgroup report,  the extent and quality of
data had little influence on  the  relative  ranking  of problem areas.  Moreover,
a comparison  of  the rankings of  OSWER  rankings  with those  of  the Unfinished
Business report  suggest  that there are  at least some  similarities  among the
reports.

   The results of the Other Health Effects Workgroup  placed Superfund Activities,
Industrial Nonhazardous  Waste Management  Facilities,  Solid Waste  Management
Units, and Hazardous Waste Storage and  Treatment Tanks,  Drums,  and Containers
at the top of the ranked list.  In contrast to the  Acute Events Workgroup, Oil
Spill Response was among the  lower risk  problem areas.  It is worthwhile noting
that Solid Waste Management Units  received  a high ranking in this Workgroup but
there was a lack of data to support this ranking at the time that the rankings
were  developed.   Recently,  however,  the  Regulatory  Impact Analysis  for the
Corrective Action rule has been released, which generally supports the rankings
assigned by this workgroup.

   Discussion.  A number  of assumptions were made  or limitations existed for the
assessment of other health effects.

   •    Hazard (e.g., toxicity,  potency) information is not available for most
        substances.

   •    Where hazard information exists, it is based largely on animal data at
        high  doses,  resulting in  uncertainty  when  extrapolation to humans and
        low doses occurs.

   •    Information on interactive effects  (e.g., synergism, antagonism) is not
        available for most substances.

   •    Data  limitations and  general nonacceptance  of a quantitative noncancer
        risk  assessment  methodology  led  the Workgroup  to  employ a  highly
        qualitative noncancer methodology.

   •    When  modeling was conducted for a  representative  facility or site for
        a problem area,  it was often difficult to then scale the results up to
        the entire problem area.

   •    Assumptions regarding corrective action or  averting action vary widely.

   •    Assumptions regarding exposed populations vary widely.

   •    Data  on  concentrations of contaminants actually monitored at exposure
        points did not exist  or was not used for the most part.
                                      C-7

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                                                     FIGURE C-2
                                 OTHER HEALTH EFFECTS METHODOLOGY
n
i
co
                                                        Workgroup
                                                         Develops
                                                       Population Risk
                                                      Consensus Score
                        Each Workgroup
                           Member
Assessment of
Cancer Risks
A Release
B Transport
C Exposure
D Potency
    Assigns
 Population Risk
    Score
                                                                                   Cancer
                                                                                    Risk
                                                                                    Score
 hdrvidual Work-
 group Member
Assigns Maximum
Exposed Individual
 (ME!) Risk Score
 Workgroup
 Develops
 MB Risk
Consensus
  Score
                                                                                                            Overall
                                                                                                         Problem Area
                                                                                                            Score
    Assessment of
    Noncancer Risks
    (More Quaitative
    than Cancer Risks)
     A Release
     B Transport
     C Exposure
     D Toxicity
                                                    Workgroup
                                                     Develops
                                                    Noncancer
                                                  Risk Consensus
                                                      Score
Each Workgroup
    Member
    Assigns
 Noncancer Risk
    Score
                         Noncancer
                         Risk Score

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                    TABLE  C-2




RANKINGS FROM THE OTHER HEALTH EFFECTS WORKGROUP
Cancer Risk
PROGRAM AREA/SOURCE Population MEI
Superfund Remedial and Removal Activities
Industrial Non-Hazardous Waste Facilities
Hazardous Waste Storage and Treatment Tanks
Land Disposal of Hazardous Waste
Mining Waste
Hazardous Waste Combustion
Municipal Landfills
Municipal Waste Combustion
Land Treatment of Hazardous Waste
Oil & Gas Operations Waste
UST Hazardous Substance Tanks
Other TSDFs
Petroleum Underground Storage Tanks
Exempt Storage Tanks
Mixed Waste
Oil Spill Response
Accidental Releases at Chemical Facilities
PCB Wastes
Ocean Dumping
Ocean Incineration
Transportation of Hazardousaterials
Underground Injection of Hazardous Waste
4
4
2
2
1
3
2
3
2
2
1
2
1
1
1
1
1
1
1
1
1
1
5
5
5
4
5
3
5
4
3
3
4
2
3
3
2
2
2
1
1
1
1
1
Non- Cancer
Risk
4
3
3
3
3
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Score
13
12
10
9
9
8
8
8
6
6
6
5
5
5
4
4
4
3
3
3
3
3
                      C-9

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C.3  ECOLOGICAL IMPACTS

       Scope of Effort.  The Ecological Impacts Workgroup addressed the relative
ecological risk potential and ecosystem impacts  associated with 23 of the OSWER
problem areas.  Because the OSWER worksheets providing the requisite data were
riot available, no evaluation of removal actions  at non-NPL sites was attempted.
The Workgroup  used a semi-quantitative risk characterization approach  that relied
both on available data and professional judgment.

       Methodology.   For each  problem area,  the Ecological  Impacts Workgroup
characterized the actual impacts and potential risks associated with each problem
area (see Figure C-3).  These data elements were  grouped into the following four
data composites:  (1)  number of  sources and releases  in  a problem area;  (2)
contaminant concentration;  and (3) receptors.

       For  each  data  element,  direct  information  or  estimates  from  the
appropriate OSWER Comparative  Risk Project work sheet were  recorded with the
resulting quantitative score.  Where there was a range of values or the available
data were limited,  a  best estimate  was made.    Where   data  were  lacking,
professional judgment was used, if appropriate.   Otherwise the  category was left
blank.   When available, a list of the most common constituents associated with
each problem area was provided.  For each problem area,  data elements within the
toxicity composite were scored according to the specific contaminant associated
with that problem area that resulted  in the maximum score for  that data element
(i.e.,  the bioconcentration score  was obtained from the constituent with the
highest bioconcentration factor, and the aquatic toxicity score was obtained from
the constituent that was most toxic to freshwater organisms).

       The score for each composite was obtained  by taking the  average score for
the data elements within that composite for which data were available (missing
values  did not affect the score).   For each problem area,  an indication of the
availability of data also was provided.

       Data  Sources  and Uncertainty  Levels.    For  most  ecological  problem
areas,the sources/releases composite and the toxicity composite  reflected high
levels  of  quantitative information.    The  concentration composite  scores  and
receptor scores were generally based on more subjective information.

       Information for each of the respective parameters  for the sources/releases
composite was  compiled  from the appropriate worksheet for each problem area, and,
where necessary,  from other  information sources.   For  each of the six ecological
data categories, the direct  information from the OSWER worksheet was recorded
with the appropriate quantitative rankings.  Where  there was  a range of values
or the  available data were limited,  a  best estimate of the midpoint for the range
was made for the category.   Where data  were lacking, professional judgement was
used, if appropriate.

       Of the four catagories of toxicity values  (i.e., toxicities to freshwater,
marine, and terrestrial organisms, and bioconcentration), toxicity to terrestrial
organisms was  the  most available.   Toxicity values for  mice were  used when
available and toxicity to rabbits was used secondarily.  In compiling freshwater
and marine  toxicity values,  a hierarchy of data was created to use  the best

                                     C-10

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validated data when EPA ambient chronic water quality criteria values were not
available.   In general, the data for freshwater organisms was more abundant than
data for marine  organisms.   Bioconcentration values were  less  available than
other toxicity values.

      Results.   The results of the ranking procedure are  shown in Table C-3.
In  general,  the final  ranking did not  depend on  the  availability  of data,
although several problem areas in  the moderate risk potential category (problem
areas 3, 7,  8,  13,  and 20) might have received a higher relative  ranking  if more
data were available.  The final rankings were  dependent  largely on the scores
for two data composites:   (1)  toxicity; and  (2) number of sources and releases.
A ranking based on the product of these two scores (not shown) correlated well
with the ranking shown in Table C-3 (r = 0.89, p < 0.01),  and the groupings of
problem areas into high,  medium, and low risk categories was largely identical.
As  described  earlier  in  Section  3.2.2,  the  Workgroup  employed a  broader
definition for ocean dumping and showed a striking difference  (higher risks) as
compared with most workgroups.

      Discussion.   The ideal  approach to  a ranking procedure  of  this nature
would be to  use a quantitative risk assessment methodology to characterize risks
to certain species or ecosystems.  In this project,  such an  approach was  limited
by theoretical, data, and resource limitations.  Because of these limitations,
a qualitative risk characterization approach that relied heavily  on professional
judgment was  used.   Data availability was a major limiting  factor.   For many
problem areas, the  score  for  several  data  elements  (particularly those within
the concentration  and receptor composites)  were  based  largely on professional
j udgment.
                                     C-ll

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                                                       FIGURE  C-3
                                   ECOLOGICAL  EFFECTS METHODOLOGY
  Sources/Releases
    Categories
   Number of  Sources
   Types of Sources
C  Geographic Density/
   Distribution
   Frequency of  Releases
   Duration  of Releases
   Area of Sites
                              Sources/Releases
                                 Composite
   Concentration
    Categories
 Magnitude of Releases
 Size of Area Affected
 Compartments
 Receiving  Releases
 Fate of Contaminants
 Concentrations at or
 Distance to  Receptor
                               Concentration
                                Composite
Receptor Categories
                                  Receptor
                                 Composite
Compartments Con —
taininy Affected
Organisms
Exposed  Populations
Size of Affected
Populations
                                                   Sum
                                                                                                         Bio-concentration
                                                                                                             Category:
                                                                                                         Highest Value for
                                                                                                          All Contaminants
                                                                                                            Present at
                                                                                                           Problem Area
                                                                                                            Toxicity to
                                                                                                            Freshwater
                                                                                                            Organisms
                                                                                                            Category:
                                                                                                          Highest Value
                                                              Combined
                                                              Exposure
                                                               Factor
 Toxicity
Composite
                                                                                                         Toxicity to Manr
                                                                                                       _|    Organisms
                                                                                                            Category:
                                                                                                          Highest Value
                                                                                                              Toxicity to
                                                                                                              Terrestrial
                                                                                                              Organisms
                                                                                                               Category:
                                                                                                             Highest Value
                                                                     Lcological Risk
                                                                Characterization Score

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                       TABLE  C-3

                  ECOLOGICAL IMPACTS
PROGRAM AREA/SOURCE	SCORE

Ocean Dumping                                  53.4
Remedial Actions at NPL Sites                  53.1
Land Disposal of Hazardous Waste               52.0
Municipal Landfills                            50.0
PCB Wastes                                     43.4
Mining Waste                                   42.5
Municipal Waste Combustion                     40.2
Mixed Waste                                    38.3
Hazardous Waste Storage and Treatment Tanks    36.2
Hazardous Waste Combustion                     35.8
Oil and Gas Operations                         33.2
Land Treatment of Hazardous Waste              31.1
Other TSDFs                                    30.7
Industrial Non-Hazardous Waste Facilities      30.6
UST Hazardous Substance Tanks                  30.6
Ocean Incineration                             28.7
Petroleum Storage Tanks                        27.8
Underground Injection of Hazardous Waste       24.8
Oil Spill Response                             24.7
Solid Waste Management Units                   23.0
Transportation of Hazardous Materials          22.2
Exempt Underground Storage Tanks               21.4
Accidental Releases at Chemical Facilities     19.8
                         C-13

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C.4  WELFARE EFFECTS

     Scope of Effort.   The Welare Effects workgroup  exam5_ned welfare effects
(which were defined as damages  to  economic resources that result in a reduction
in the value of commercial activities or in the value of human well-being) .  This
approach was chosen because of  the lack of studies associating economic impacts
with  OSWER  problem areas.   While the  supporting  workgroup report  is titled
"Report of the Economic Effects Workgroup",  the workgroup recommended that the
welfare effects  be used for purposes of the overview report.The objective of the
Welfare Effects Workgroup  was  to  rank OSWER problem  areas  according to their
potential relative  negative  welfare   impacts.   Negative welfare  damages were
defined as the loss in value placed upon an economic resource when environmental
contamination associated with releases from OSWER problem areas occurs.

     Data on the dollar value of welfare damages for each problem area were often
unavailable.   Consequently, the  Workgroup   did  not  attempt  to  estimate  the.
absolute dollar value  of  welfare  losses for each problem area.   As  such,  the
Workgroup decided only to estimate  relative welfare  damages  associated with
different problem  areas.   The  limitations available information also required
that  the Workgroup  had  to  rely  extensively  on  best professional judgment when
assessing  the  relative  damages.    Furthermore,   the  absence  of  rigorous,
quantitative data meant that the Workgroup was unable to estimate damages with
a high level of precision and instead used ordinal scales (i.e.,  high, medium,
and low) to assess welfare damages.

     Methodology.   The Welfare Effects Workgroup's methodology  relied heavily on
the Workgroup's  own best professional judgment  (see  Figure C-4).  The Workgroup
considered welfare  effects for  each  problem  area  for  three  general categories
of resources:

      «  residential and commercial property;
      •  natural  resources; and
      •  surface  water.

     Damage to  residential  or  commercial property was  defined  as material or
structural damages  to  either residential or  commercial properties and loss of
commercial land  for business activities. Damage to natural resources was defined
as damages to agricultural  crops,  livestock,  timber resources,  and fisheries.
Damage  to  surface  water  was defined  as  damages  to  surface  waters  used  for
drinking purposes or for  recreation.   For  each  problem area,  the  Workgroup
assigned a Welfare Damage  Score for each type of damage based on their estimate
of the degree of  welfare  damage likely to be associated with  releases in that
problem area.   Thus,  for  each problem  area, the Workgroup  assigned  a Welfare
Damage Score  for  damages  to  residential property,  commercial  property, timber
resources, crops,  livestock, fisheries, recreational use of surface water,  and
surface water used as drinking  water.   The Workgroup summed all eight scores to
devise an index  of total welfare damage associated with a problem area (overall
scoring range 8 to  80).

     The Welfare Damage Scores  assigned to each type of damage ranged between 1
and 10.  A  score  of 1 was assigned when welfare damages were estimated to be
relative low,  a score of 5 was  assigned when welfare damages were estimated to

                                     C-14

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be moderate, and a score of 10 was assigned when welfare damages were estimated
to be high.

     In assigning Welfare Damages Scores, the Workgroup  agreed on a series of
assumptions or  guidelines  to  estimate the magnitude of welfare  damages.   The
Workgroup assumed that welfare damages would be greater when one or more of the
following was true:

     •    a large volume of waste is released;

     •    substances released have a high toxicity;

     •    the concentration of constituents  of concern in substances
          released is high;

     •    the degree of regulation in a problem area is relatively low;

     •    the number  of sites  or  facilities  in  a problem  area is
          relatively high;

     •    population density surrounding typical sites or facilities
          is relatively high;  and

     •    there is a high density of natural  resources  close to the
          problem area.

     Whenever possible,  quantitative data were used as the basis for estimates
of welfare  damages.   When no quantitative data were available,  the Workgroup
used its best professional judgment to estimate values for these parameters.

     Data Sources and  Uncertainty Levels.  The key data source  relied  on to
develop welfare damage estimates were problem  area fact sheets prepared by the
Office of Program Management and Technology.  The fact sheets contained data on
most parameters considered in the analysis.  When data were not available from
the fact sheets, attempts were made to identify other data  sources.  If no other
data could  be identified,  the Workgroup  relied  on its own best professional
judgment to estimate welfare damages.

     Results.   The final ranking of the Welfare Effects Workgroup is presented
in Table C-4.   The Workgroup divided the problem areas  into three groups.

     (1)  High:   problem areas with  total welfare damage scores of 25
          or greater.

     (2)  Medium:  problem areas scoring between 15  and  25.

     (3)  Low:  problem areas  scoring below 15.

     The Workgroup concluded that comparisons  beyond this level of detail were
not justified considering the quality of data supporting individual scores.  At
this level of  comparison, however, the Workgroup expressed reasonable confidence
in its conclusions.

                                     C-15

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     Discussion.  The Welfare Effects Workgroup chose not to consider four other
potential welfare effects:

     •    aesthetic values;
     •    potential use values;
     •    secondary or indirect  effects;  and
     •    economic effects arising from ground water contamination.

     Aesthetic  and potential  use  values  were not considered  because  the
Workgroup judged that sufficient data were not available  to realistically assess
these effects.   Secondary or indirect  effects  were  not  considered because the
Economic Effects Workgroup wished to avoid overlap  with other Workgroups.   For
example,  the  Welfare  Effects Workgroup  did not consider  costs  from  medical
expenses of exposed individuals because  it  was  felt that this should be dealt
with  by the  Other  Health Effects  Workgroup.   Similarly,   it  was  felt  that
potential welfare loss  resulting from ecological damages  should be addressed by
the  Ecological  Effects Workgroup.   By  the  same  rationale, welfare  effects
arising from  ground water  contamination  was not considered as  this  was  to be
addressed by the Ground Water Valuation Workgroup.
                                     C-16

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                                                FIGURE C-4
                                   ECONOMIC EFFECTS METHODOLOGY
o
I
                                                   Property Damage
                                                     Composite
Property Damage
   Category
 A Commercial
 B Residential
Natural Resource
Damage Category

  A Timber
  B Crops
  C Livestock
  D Rsheries
               Surface Water
              Damage Category
              A  Drinking Water
              B  Recreational
                 Water
                                    Sum
 Natural Resource
Damage Composite
                      Sum
 Surface Water
Damage Composite
Sum
   Overal
Welfare Damage

    Score

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                                                                TABLE C-4

                                                WELFARE  EFFECTS  WORKGROUP  RESULTS









o
1
;— »
co












PROGRAM AREA/SOURCE
Superfund Activities
Solid Waste Mgmt Units (SUMUs)
Land Disposal of Hazardous Waste
Industrial Non-Hazardous Waste Facilities
Petroleum USTs (Including Used Oil)
Municipal Landfills
Haz. Waste Storage & Treatment Tanks
Mining Wastes
Exempt Storage Tanks
Oil & Gas Operations Waste
Other TSOFs
Municipal Waste Combustion
Combustion of Hazardous Waste
Transportation
Hazardous Substance USTs
Land Treatment of Hazardous Waste
Oi 1 Spi 1 1 Response
Underground Injection
Ocean Dumping
PCS Wastes
Accidental Releases 3 Chem. Manufacturing Fac.
Mixed Waste
Ocean Incineration
Surface Water
Recreational Drinking
Water
10 10
10 5
5 5
5 5
5 5
5 5
5 5
5 1
5
1
1
1
1
1
1
1 1
1 1
0 1
1 0
0 0
0 0
0 0
0 0
Natural
Resources
Timber Crops Livestock Fisheries
15 1 5
15 5 5
15 5 5
11 1 1
01 1 1
11 1 1
11 1 1
55 1 1
01 0 1
15 5 1
11 1 1
11 1 1
11 1 1
11 1 1
01 1 1
10 0 1
00 0 1
00 0 0
00 0 1
00 0 1
00 0 0
00 0 0
00 0 0
Property Overall
Commercial Residential Score
55 42
55 41
55 36
10 10 34
10 10 33
10 5 29
10 5 29
1 1 20
55 18
1 1 16
55 16
1 5 12
1 1 8
1 1 8
1 1 7
1 1 6
00 2
0 0 1
00 2
0 0 1
00 0
00 0
00 0
Scale:
0 = No, or insignificant,  level of economic impacts
1 = Relatively Ion level of economic impact
5 = An Average (or medium)  level of economic impacts
10 = Relatively high level  of economic  impacts

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G.5  GROUND WATER VALUATION

     Scope of  Effort.   The  objectives of the Ground Water Valuation Workgroup
were to  assess and  compare  the extent to which OSWER problem areas contribute
to ground water resources damage.   The Workgroup analyzed nine problem areas.
Nine other problem  areas considered by other OSWER Comparative Risk Workgroups
were not analyzed since either presented only a minimal threat to ground water
or because no  reliable data were available  on  the  potential of these problem
areas to contribute to ground water contamination.

     Methodology.  The methodology used by  the Ground Water Valuation Workgroup
was  based  on  a methodology developed  by  the  Office  of Solid  Waste's  (OSW)
Economic Analysis Staff for quantifying resource damage associated with ground
water contamination (see Figure C-5).   This methodology  is based on the concept
of resource damage  and replacement costs.  In this approach it is assumed that
ground water used as drinking water is generally a free resource.  When such a
resource becomes unusable due to contamination,  there is a cost associated with
its replacement.  This cost is taken  to represent the "value" users place on a
contaminated resource, or how  much they  would be willing  to pay for the least
expensive substitute resource.

     For each  problem  area,  the Ground Water Valuation Workgroup  developed a
series of scenarios representing the range  of potential contamination likely to
occur from releases in that  problem area.   Each  scenario was based on different
runs of  a  series of problem area-specific ground water  contamination models.
These models  simulated pollutant release from  a facility or waste management unit
and predicted concentrations of pollutants at various distances downgradient from
sources  of contamination.   The models also  predicted plume  size,  duration of
contamination,   and  assumed well  density.   Based on  the  results  of these model
runs,  the  Ground  Water  Valuation   Workgroup  then   developed  engineering
specifications  for  replacement water  supply  (based  on  a new  system's  design
capacity, available water sources, and period of operation)  for each scenario.
A series of engineering cost algorithms were then applied to predict capital and
operating costs for the replacement supply.  These costs (expressed in present
value terms)  were assumed to be  an approximation of  the  resource value  of the
ground water  under that scenario.  Aggregate national costs were then calculated
by extrapolating estimated costs  to the universe of facilities  or  sites  in a
problem area based  on  the estimated distribution of  scenarios  in each problem
area.

     Data Sources and Uncertainty Levels.  No  single data source was used to base
model estimates on.  Generally, cost, distribution, failure potential, and types
of contamination were taken from data in regulatory  impact  analyses  (RIAs)  or
similar reports on impacts of various waste  management practices.  In most cases
these data were based  on  samples of sites  or  facilities.   Generally,  data
deficiencies   required  that   the Workgroup  had  to  make  assumptions   about
environmental  settings  of various  types  of facility  or  site,  hydrological
parameters,  exposed populations,  types of waste  handled,  facility size,  and
water use patterns.

     Current  and future  ground water  use was estimated  on  the basis of  U.S.
Geological Survey  water  supply  data covering  the 1975-1980  period.    The

                                    C-19

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probability of future use was  estimated based on the assumption of an increased
rate of use of 1.4 percent per year.

     Results.   The Ground Water Valuation final ranking is presented in
Table C-5.  Aggregate national costs  (not shown)  ranged from $0 for Combustion
of  Hazardous  Wastes  to  $15  billion for  USTs.    Other  significant  findings
included:

     *     NPL  sites have  the  highest mean resource damage  per site
          (present value  costs of $9.7 million  per  site).

     •     The  number of facilities in each problem area plays a significant
          role in  determining  aggregate  national  resource damage  cost
          estimates.

     •     The  size  of facilities within a  problem area is highly correlated
          with high resource damage cost  estimates.

     Discussion.   A number of important  caveats or  limitations  should be noted
about the results of the  Ground Water Valuation Report:

     •     The  Ground Water Valuation Workgroup did not consider the effects
          of ground water contamination prevention programs, although such
          regulations  are already in place in  a number  of problem areas.
          The   effect  of  this  assumption is  to  probably  overestimate
          resource  damage  in   some problem   areas.      If  regulatory
          environments  were considered,  it is  likely that the  ranking of
          the  problem areas would change.

     •     The  Workgroup assumed that no  ground water clean-up  activities
          were performed  for any problem area except NPL  sites.  The effect
          of this  assumption  is that contamination spreads more  widely
          (i.e.,  plumes are modeled  to grow larger and  last longer)  than
          they actually  do  given current  regulations.    As  a  result,
          replacement  water supplies are assumed  to  have  larger  design
          capacity  and  operate  for  longer periods than they  probably
          actually have or do.  This  has  the overall effect of  increasing
          resource damage cost estimates.

     *     In many cases the final resource damage  estimates were based on
          poor data  and  numerous  assumptions.   Generally, the  weakest
          aspects of the  data were   related to plume  size and  water  use
          patterns.

     •     The  Workgroup  considered  using only  a  nearby  aquifer  as  a
          substitute  source  for  contaminated drinking  water.    Other
          alternatives  (e.g.,  temporary use of bottle water or point of use
          treatments)  were not considered as alternatives.

     •     The  Workgroup did not consider  regional  differences in resource
          damage.  As such, regional variation in the  cost  of replacing
          contaminated water systems  was  not considered.  Such  variations

                                     C-20

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might have considerable impacts on the overall ranking of problem
areas.

Resource  damage  models focused entirely  on human use.   Other
forms of potentially significant damage from  contaminated ground
water (e.g., the loss  of  ground water for irrigation)  were not
considered. Including other economic  losses might change overall
rankings.

The models used to calculate the impacts of contamination are not
sensitive  to  the magnitude of contamination beyond identified
thresholds.   Resource  damage  is  held to  occur  the  moment  a
threshold is passed.  At that point it is assumed that users will
stop drinking contaminated water and  seek  alternative supply the
moment the  threshold is exceeded.   Including magnitude  in the
analysis might alter the overall  ranking  of the problem areas.
                           C-21

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                                                   FIGURE C-5
                                 GROUND-WATER VALUATION METHODOLOGY
o
I
to
to
      Develop Potential
         Scenarios
        Representing
        the Range of
         Potential
                              Determine
                             Thresholds at
                            Which Chemical
                             Constituents
                            Cause Drinking
                            Water Supples
                            to be Unusable
  Use Avafeble
  Ground-water
Models to Predict
 Concentrations
  Downgraded
     from
  Release Point
                                                                          Determine
                                                                           Score by
                                                                           Setting
                                                                         Replacement
                                                                          Cost Equal
                                                                          to Resource
                                                                            Damage
    Preofct
  Capital and
Operating Costs
     for
 Water Supply
  Replacement
   Compare
Concentrations
 to Thresholds

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                                   TABLE C-5

                            GROUND WATER VALUATION
                                                 Natural       Mean
                                                 Resource    Resource
Problem Area                                     Damage*     Damage**

Underground Storage Tanks                               15000         11
NPL Sites                                                8600       9700
Municipal Landfills                                      2580        420
Solid Waste Management Units                             1750        310
Land Disposal of Hazardous Waste                         190        365
Mining Waste                                             178        360
Oil and Gas Waste                                        173          0.8
Other Treatment, Storage and Disposal Facilities           69         26
Hazardous Waste Combustion                                 0          0

The following problem areas were not evaluated but judged to  rank between  other
treatment, storage and disposal facilities and hazardous waste  combustion:

Industrial (D) Landfills
Land Treatment of Hazardous Waste
Underground Injection
Non-NPL Sites
Transportation

Similarly, the following problem areas were not modeled but judged to rank  after
hazardous waste combustion:

Municipal Trash Incineration
Hazardous Waste Cleanup
Ocean Incineration
*Natural  Resource  Damage  is reported  as water  supply replacement  costs  by
problem area in millions of  dollars.
**Mean Resource Damage is reported as water supply replacement costs by  problem
area in thousands of dollars.
                                      - 23       &U.S GOVERNMENT PRINTING OFFICE: 1989 - 748-159/00363

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