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Preface
"We are pan of the Earth and it is part of us. ... All things are connected."
--Chief Seattle
This report was prepared by the Work Group of the Wisconsin Tribes Comparative Risk
Project that was supported by the U.S. Environmental Protection Agency (EPA). It documents
the risk evaluation of the environmental problems faced by Tribes in Wisconsin. It is the first
effort to evaluate the risks faced by Native Americans in a comparative risk framework. The
Project was a cooperative effort of the Planning and Management Division in Region 5
(Chicago), the Offices of Policy, Planning and Evaluation (OPPE) and Water (OW) in EPA
headquarters, and the eleven Tribes of Wisconsin.
Over the last five years, EPA has supported over twenty comparative risk projects in EPA
regions and in states to facilitate better approaches for managing environmental problems. While
these projects have revealed many similarities in the seriousness of risks across the country, there
were also distinct differences that reflect the environmental diversity of our Nation. Even where
risks are similar, the causes of risk sometimes differ, necessitating unique solutions to achieve
the greatest reduction in risks for our environmental protection dollar.
Native Americans, with their special relationship to the land and the ecosystems within
which they live, different governmental structures and relationship to the U.S. Government, and
distinctive cultural influences, may face different types, amounts, and causes of environmental
risks than the "typical" American. This pilot project sought to adapt the comparative risk
analytical framework to the conditions experienced by the Tribes in Wisconsin to both identify
these differences in risks and provide a first step in developing the most effective ways of
reducing them.
Most of the analytical work and decision-making for this project was conducted by the
Work Group, consisting of professional staff of Region 5, OPPE, and OW. The Tribal Chairs
and their staff reviewed, contributed to, commented on, and endorsed the work of the EPA Work
Group, as did EPA program analysts and management.
For further information on this project, contact:
U.S. Environmental Protection Agency
Office of Policy, Planning and Evaluation
Regional and State Planning Branch
401 M Street, SW (PM-222A)
Washington, DC 20460
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U.S. Environmental Protection Agency
EPA Region 5, Planning and Management Division
77 West Lake Boulevard (ME-19J)
Chicago, IL 60604-3507
U.S. Environmental Protection Agency
Office of Water
401 M Street, SW (WH-556)
Washington, DC 20460
Great Lakes Inter-Tribal Council
Post Office Box 9
Lac du Flambeau, WI 54538
For further information on other comparative risk projects, contact the Regional and State
Planning Branch, PM-222A, Office of Policy, Planning and Evaluation, U.S. Environmental
Protection Agency, Washington, D.C. 20460.
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Contents
Preface i
Contents iii
Tables v
Figures vi
Executive Summary vii
I. Introduction 1
A. Background on the Wisconsin Tribes 2
B. Background on the Comparative Risk Process 5
T^pes of risk 6
The risk assessment process 7
II. Project Methodology 10
A. General Approach 10
B. Modifications of Comparative Risk Methods 14
Overall nature of the comparative risk approach 14
Approach for health risk 16
Approach for ecological risk 17
Approach for social and economic damages 18
Geographic coverage of the project 19
Diversity across the reservations 19
C. Ranking Methods 20
Health risk ranking procedure 20
Ecological risk ranking procedure 21
Social and economic damages procedure 21
III. Project Results 23
A. Health Risk Ranking 23
B. Ecological Risk Ranking 27
C. Social and Economic Damages Ranking 32
D. Data Gaps 35
E. Need for Environmental Protection Infrastructure 38
F. Comparing the Results with Other Studies 39
G. Project Recommendations 42
H. Suggested Next Steps 43
III
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Appendix A: Definitions of Problem Areas Considered for Ranking . A-l
Appendix B: Background Papers on Problem Areas B-l
IV
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Tables
Table 1: Information on Wisconsin Tribes 2
Table 2: Members of Project Work Group 10
Table 3: Environmental Problems Evaluated 11
Table 4: Combined Health Risks 28
Table 5: Cancer and Non-Cancer Health Risks 29
Table 6: Combined Ecological Risks 33
Table 7: Aquatic and Terrestrial Ecosystem Risks 34
Table 8: Social and Economic Damages 36
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Figures
Figure 1: Native American Settlements in Wisconsin 3
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Executive Summary
This report describes the results of a project conducted in 1991 and 1992 to evaluate the
environmental risks faced by the 11 Native American Tribes in the State of Wisconsin. The
study is the first comparative risk project conducted by the U.S. Environmental Protection
Agency (EPA) that focuses on Native Americans. The project is a cooperative effort by EPA's
Region 5 (Chicago); Office of Policy, Planning, and Evaluation; Office of Water; and the eleven
Tribes in Wisconsin.
The Indian Tribes of Wisconsin have a lifestyle, culture, values and environment different
than most Americans. Their reservations are relatively isolated and undeveloped and are much
more nearly in their natural condition than the land surrounding them. The Tribes rely
extensively on harvesting local fish, game and plants for subsistence. They also place high
cultural value on preserving the quality of their environment, and seek to manage their activities
so as to maintain their lands in undiminished condition for future generations. However, stresses
from growing development outside the reservations and pressures for economic growth on the
reservations have combined to generate significant environmental problems for the Tribes.
This project has used the standard methods of comparative risk assessment to rank the
relative seriousness of the different environmental problems facing the Tribes, given their specific
situation. It is a pilot effort to see if comparative risk techniques can provide useful insights
when applied in the Indians' distinctive natural and cultural setting. Like all comparative risk
projects, the results depend extensively on the judgment of the project work group in evaluating
the data that was assembled bearing on the Tribes' environmental problems. The work group
conducting the project consisted of representatives from EPA Headquarters and EPA Region 5,
including four Native Americans. While not pure science, the analysis and rankings are
extremely valuable for setting priorities and developing plans of action for addressing
environmental problems that affect the Tribes.
The project has four specific objectives:
o To determine the relative severity of the different environmental problems facing
the Wisconsin Tribes;
o To learn how the comparative risk framework and methods should be adjusted to
fit the unique characteristics of the Wisconsin Tribes;
o To determine how the risks facing the Wisconsin Tribes compare with those
facing broader populations studied in other comparative risk projects; and
o By gaining a better understanding of the environmental problems facing the
Tribes, to provide a start toward managing them better.
Twenty-two environmental problems were ranked separately in terms of the health risks,
ecological risks, and social and economic damages they pose to the Tribes. These rankings were
VII
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developed through use of standard comparative risk methods, with several modifications to reflect
the unique focus on Native Americans. In estimating health risks, particular attention was given
to the influence of Tribal lifestyles on exposure pathways. Heavy subsistence consumption of
local fish and game was very important. In evaluating social and economic damages, two non-
traditional categories of damages were given great weight: damages to Indian cultural and
religious values, and damages to subsistence activities. One traditional damage category was also
emphasized damages to natural resources of commercial value to the Tribes. For ecological
risks, traditional assessment methods were not changed. We maintained that the methods and
conclusions about ecological risks in a particular area should be the same whether the study is
performed from the perspective of Native Americans, the mainstream culture, or any other group.
The environmental problems ranked as most serious for each type of risk were:
Human health risk:
- Food contamination
- Nonpoint source pollution of surface water*
- Indoor air pollution other than radon
- Indoor radon
- Drinking water contamination
- Groundwater contamination
Ecological risk:
- Nonpoint source pollution of surface water*
- SOx/NOx (acid deposition)
- Physical degradation of water and wetlands
Social and economic damages:
- Nonpoint source pollution of surface water*
- Physical degradation of water and wetland habitats
- Food contamination
- Physical degradation of terrestrial ecosystems
- Unmanaged hazardous waste sites (past disposal)
- SOx/NOx (acid deposition)
Notes:
We ranked all of these problems as "high risk" relative to the other problems studied. Although these problems are listed
here for each type of risk in descending order of severity, we are much less confident in this ordering within the high risk category
than in the more fundamental distinctions between high, medium, and low risk.
* For this project, the "nonpoint source" category is defined to include all means by which pollutants reach surface water
other than from point sources, including runoff, air deposition, and ground-water discharge. This definition differs somewhat from
that commonly considered by EPA's Office of Water.
VIII
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Several of these problems rank very differently than they did in the recent Region 5
comparative risk project, and in other comparative risk projects focusing generally on mainstream
American society. This is despite use of similar analytical and ranking methods in each of these
studies. Some of the major differences are:
o Food contamination from environmental sources (except residues of agricultural
pesticides) has never been noted as a top problem in other projects. The Indian
diet includes large quantities of local fish and game species that have
bioaccumulated and bioconcentrated environmental contaminants as a result of
being atop lengthy food chains.
o Problems deriving from industrial activity rank unusually low for the reservations,
but often rank high in other studies. There is very little industrial activity on or
near the reservations.
o Problems deriving from long range transport of pollutants rank unusually high on
the reservations. To generalize very broadly, most comparative risk projects have
found that most of the important risks derive from sources within or near the study
area. The reservations, though, face problems deriving largely from pollutant
sources farther away and outside the reservations. This has substantial
implications for risk management.
o Most studies find criteria air pollutants to pose high health, ecological and
economic risks. On the reservations, by contrast, they pose rather low risks (with
the exception of acid deposition). The density of mobile and industrial sources
of criteria air pollutants is very low near the reservations.
Another surprising result was that despite the isolated and generally undeveloped character
of most of the reservations (largely as a result of most Tribes' conscious choice to avoid industrial
development and maintain the natural quality of their land), the Tribes are faced by some serious
environmental problems.
Air deposition of PCBs, mercury and other toxics on water and land is perhaps the most
important single source of risks. Fish and game have bioaccumulated these toxic chemicals (in
a process accelerated by acid deposition) to levels posing substantial health, ecological, and
cultural risks to a Native American population that relies heavily on local fish and game for
subsistence. As the extent of fish and game contamination is more fully investigated by state and
federal authorities, advisories suggesting limited or no consumption of fish and game are being
established for a large portion of the Tribes' traditional hunting and fishing areas.
A second important problem facing the Tribes is very high levels of radon for many of
the reservations. At 5.8 pci/1, the weighted average indoor radon level substantially exceeds
EPA's action level of 4 pci/1 across the over 1,000 sampled Indian homes. Conditions exist that
would lead to substantial levels of other indoor air pollutants also: a very high incidence of
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smoking among the Indian population, general reliance on wood stoves for home heating, a long
heating season, and newer, airtight (low ventilation) housing.
The largely natural condition of most of the reservations and the low level of many of the
risks facing the Tribes relative to those facing typical urban Americans should not be interpreted
to suggest a relatively low level of need for environmental protection for the Tribes. The treaties
with the U.S. under which the Tribes ceded some lands and rights and maintained others led to
a significant trust responsibility for the federal government. In keeping with that trust
responsibility, the EPA Indian Policy of 1984 commits the Agency to considering Tribal concerns
and interests whenever its actions may affect reservation environments.
The standard by which the U.S. government judges Indian needs for environmental
protection should not only involve comparison of conditions facing the Tribes now with
conditions facing other Americans now. It should also involve a historical comparison
comparing current conditions with those prevailing a century or more ago, when the Federal
commitments to the Tribes were made. Other factors which EPA must consider include Tribes'
reliance on natural resources for subsistence and the cultural importance of the environment to
the American Indians. The treaties, trust responsibility, and EPA Indian Policy require a high
level of protection for the reservation environments.
EPA's comparative risk framework tends to emphasize current, demonstrated
environmental risks without focusing on how environmental problems may increase in the future.
In addition to analyzing the risks from current environmental problems, it is also necessary to
consider: a) the need to protect the land and Indian culture from risks for the very long term
future, and b) the expected vulnerability of the small amount of reservation land to growing risks
from outside the reservations in the future. Comparative risk projects serve as the analytical
foundation on which efforts to reduce risk are based. We believe that it is very important to
direct environmental management efforts for the Tribes both at current risks (where most of the
attention in this project was devoted) and at potential future risks.
The Tribes feel particularly vulnerable to worsening environmental problems in the future
for several reasons. The isolation of the reservations has protected them to some degree so far.
However, development outside the reservations will continue and pollutants will increasingly flow
into the reservations. The Tribes feel powerless to influence the nature and impacts of this
development. The Tribes have a nearly complete lack of administrative or physical infrastructure
with which they can manage or even influence environmental problems from sources either
within or outside of the reservations. For example, Tribal environmental staffs are minimal; there
are few Tribal laboratories and minimal environmental monitoring has occurred; there are no air
or water quality standards for the reservations; and many drinking water treatment, sewage
treatment and waste disposal facilities are substandard.
In addition, the Tribes place high value on their traditional harmonious relationship with
their natural surroundings. They are limited in pursuing their traditional activities to the small
vestigial reservation areas. These areas must remain undamaged for centuries into the future if
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the Tribes are to maintain their ancestral values.
Although our primary intent was limited to ranking the risks facing the Wisconsin Tribes,
we have also made some suggestions about where to concentrate in managing the risks. The
following is a list of the environmental problems facing the Wisconsin Tribes for which
infrastructure development (both administrative and physical) would be most beneficial in order
to reduce current risks and avoid growing future risks:
Highest priority for infrastructure development:
Protection of surface water quality (nonpoint, industrial, and municipal sources)
Protection of ground-water and drinking water quality
Municipal solid waste
Aquatic and terrestrial habitat alteration
Radon
Pesticides
Food contamination (both subsistence fish and game, and USDA commodities)
Note that these priorities for infrastructure development are somewhat different than the
list of the most serious risks. Several factors in addition to the severity of the risks are
considered in developing a priority list for action ~ these factors generally include the economic,
political, and institutional feasibility of addressing the risks.
After completing the analysis and risk evaluations, we have two recommendations for the
use of this project's methods and results: 1) use the analysis and rankings to help guide risk
management activities both on the reservations and in EPA and other Federal agency programs;
and 2) use the adapted comparative risk methodology in future comparative risk projects with
other Tribes.
This project is intended to serve as the analytical foundation to begin a process of
planning for activities that will help solve the environmental problems faced by the Tribes.
Hopefully, this process will include not only the Tribes and EPA, but also the State, other Federal
agencies, industry, and others whose activities affect the Tribes' environment. Priorities for
environmental action should reflect the risks faced by the Tribes. The analysis and rankings from
this project, together with consideration of cost-effectiveness, technical, legal, and political
feasibility, can help in identifying and developing strategies and Tribal environmental programs
that will deliver effective solutions to environmental problems.
XI
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I. Introduction
Since 1986, the U.S. Environmental Protection Agency (EPA) has performed or supported
about twenty-five comparative risk projects, aiming to evaluate the environmental risks facing
different regions, states or cities within the U.S. Each of these projects has focused on the entire,
diverse population of Americans living within the geographic boundaries of the study area. EPA's
Regional and State Planning Branch (RSPB), which supports comparative risk projects in EPA
Regions and states, has been interested in supporting Tribal comparative risk analysis to
complement Regional and State projects. Recently EPA has become more concerned with the
equity of environmental protection programs for particular minority subpopulations. The RSPB
has also been interested in investigating how the risks facing different subpopulations differ from
Regional and State averages. Region 5 was particularly interested in investigating how risks
differ for the eleven Native American Tribes in Wisconsin. Early in the project, EPA's Office
of Water (OW) joined in collaboration with the Office of Policy, Planning and Evaluation (OPPE)
and Region 5, because many of the risks faced by the Wisconsin Tribes were most likely related
to water issues.
In this project we have used the methods of comparative risk analysis to assess and rank
the environmental risks facing a very specific minority population members of the eleven
Native American Tribes living in Wisconsin. Comparative risk methods have been modified
somewhat to better reflect the problems and values of Tribes. The 20,000 to 30,000 members
of the Wisconsin Tribes both live in a setting and pursue a lifestyle quite different from those of
the average American. The Indian reservations in Wisconsin are rural, thinly populated and
largely undeveloped. The Indians place great value on maintaining a traditional harmonious
relationship with their natural environment, and they rely extensively on subsistence hunting,
fishing and gathering. Not surprisingly, therefore, the pattern of environmental risks facing the
Wisconsin Indians is rather different than that facing the average American.
The project has four specific objectives:
o To determine the relative severity of the different environmental problems facing
the Wisconsin Tribes;
o To learn how the comparative risk framework and methods should be adjusted to
fit the unique characteristics of the Wisconsin Tribes;
o To determine how the risks facing the Wisconsin Tribes compare with those
facing broader populations studied in other comparative risk projects; and
o By gaining a better understanding of the environmental problems facing the
Tribes, to provide a start toward managing them better.
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A. Background on the Wisconsin Tribes
Eleven Tribes or bands of Native Americans now live in Wisconsin. Most of these Tribes
are native to Wisconsin, although two (the Oneida and the Stockbridge) moved to Wisconsin
from New York and New England over a century ago. The historical range of these Tribes was
far greater than their current reservations ~ Indian rights to vast areas of Wisconsin were ceded
to the U.S. in a series of treaties in the mid-1800's. Nearly all of the current reservations for the
Tribes in Wisconsin were established in treaties during the period of 1831-1873, or by Acts of
Congress from 1913-1939. Figure 1 shows the location of the current reservations. Table 1
provides additional information on each of the Tribes.
Table 1: Information on Wisconsin Tribes
Tribe
Bad River
Lac Courte Oreilles
Lac du Flambeau
Menominee
Mole Lake
Oneida
Potawatomi
Red Cliff
St. Croix
Stockbridge-Munsee
Winnebago
Origin
Mative/Chippewa
Sative/Chippewa
Native/Chippewa
Native
Native/Chippewa
New York
Native
Native/Chippewa
Native/Chippewa
New England
Native
Members
on/near res.
1,431
2,279
1,485
3,582
343
4,437
466
1,391
1,209
826
1,912
Reservation
Area (acres)
124,000
75,000
92,000
235,000
1,694
65,730
11,692
14,100
2,371
46,000
4,265
TribaUy
Owned (acres)
56,345
43,610
30,303
222,522
1,694
2,741
11,692
7,569
1,940
16,028
4,265
Reservation
Established (year)
1854
1873
1854
1854
1939
1831/1838
1913
1854
1938
1856
1963
Federally recognized Indian Tribes are sovereign dependent nations that have developed
a trust relationship with the U.S. government. Through treaties with the U.S., Tribes have
relinquished title to most of their historical lands, but in many cases have retained certain rights
to use of the lands, as well as the right to govern themselves. Particularly important in
Wisconsin, a 1983 court decision has declared that the Chippewa Tribes still maintain their
historical rights to fishing, hunting and gathering throughout the northern 40% of the state despite
the 1837 and 1842 treaties that ceded this land to the U.S. (the "Voigt Decisions": Lac Courte
Oreilles v. Voiet. 700 F. 2d 341 (7th Circuit 1983) et. seq.).
Most Indian Tribes have the right to exercise civil and certain criminal authority over their
reservation lands. State powers over these lands are sharply limited. Under the Constitution, the
Federal government can regulate many aspects of Indian life. Court decisions have also declared
a special responsibility of the federal government toward Indian Tribes - to act as "trustee" on
behalf of and for the benefit of Indian Tribes. In an environmental context, the unique legal
position of Indian Tribes has resulted in Tribal authority to establish environmental standards for
the reservations (independent of state standards, but consistent with any federal minimum
standards) and a federal responsibility to contribute to the achievement of the standards.
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Figure 1: Native American Settlements in Wisconsin
BAD RIVER j
(Chipp«wa)'
LAC DU FLAMBEAU
(Chipp«vva)
POTAWATOMI
LAC COURTE ORBLUES
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Most of the Wisconsin Indian reservations are thinly populated, rural, relatively isolated
and undeveloped. The primary economic activities on most of the reservations involve natural
resource development - logging, sawmills, fishing, hunting, wild rice gathering and cranberry
farming. Tourism provides some income, with lakeshore cottages and resorts, cultural events,
and guided fishing and hunting. Commercial activities are limited but growing, with Tribal
government offices, community centers, health clinics, grocery stores, gas stations, and the like
having been developed at an accelerating pace. Several reservations have developed profitable
gaming enterprises and associated motels, which draw many non-Indians. Heavy industry is non-
existent on the reservations, and there are only a handful of light industrial plants. Except for
wild rice and cranberry harvesting, agriculture is of little importance on most reservations. Only
the Oneida and St. Croix reservations have been significantly transformed by agricultural
development. Nearly all of the land on the other reservations is in natural or managed forests,
lakes and wetlands.
Economic conditions on the reservations are generally depressed. Unemployment is very
high. Many of the business ventures started by the Indians have failed. Both as a matter of
cultural tradition and because of limited incomes, the Indians rely heavily on locally harvested
fish, game and grains for their food supply. Schools, health care and housing are heavily
supported by the Federal government, and are adequate.
As might be expected with so little development, environmental conditions on the
reservations are quite good compared with those faced by most Americans. Air and surface water
quality are excellent relative to typical conditions elsewhere in the U.S.. Chemical contamination
of drinking water sources on the reservations is rare and most reservation residents obtain
drinking water of good chemical quality from untreated ground-water wells. Fish and game are
abundant by comparison with other areas in the U.S.. (although they are not as abundant as they
were historically in the local area, and some species such as mink, eagles and otters are clearly
stressed). Pesticide use on the reservations is minimal, and hazardous wastes are neither
produced nor disposed in significant quantities on the reservations (with the exception of small
quantities of medical wastes).
Despite these generally good conditions, the reservations do have some important
environmental problems. Long range transport of contaminants (acids, mercury, PCBs and
others) and their deposition from the air have led to bioaccumulation of contaminants in fish and
game. To heavy subsistence consumers of local fish and game, these contaminants pose
substantial health risks. Naturally occurring contaminants radon in soil and metals in ground
water are problems in some areas.
The lack of facilities for avoiding or mitigating potential environmental problems
generated on the reservations is also worrisome. Sanitary and bacteriological problems are
particularly likely, though monitoring data generally do not exist for documenting the presence
or absence of such problems. Most reservation households rely on septic systems for domestic
waste disposal. Many of the septic systems are known to be in very poor condition, often
discharging directly to lakes or the land surface. Most households get their drinking water from
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shallow, untreated, and often poorly constructed private wells. Although chemical contamination
is rare, bacteriological contamination of drinking water supplies from septic fields affecting the
wells is likely. The public systems for drinking water supply and for wastewater collection and
treatment are also problematic. Most of the community water supply facilities provide no
drinking water treatment whatsoever; most of those providing some treatment do not maintain
a sufficient chlorine residual to protect against bacteriological contamination. Many of the
wastewater treatment facilities are in poor condition, and several consistently violate their permit
requirements. Most of the solid waste from reservation households was historically open
dumped. None of the many scattered landfills on the reservations have adequate operating
procedures, cover, site security, leachate collection, rodent control or monitoring. In sum, the
facilities to protect reservation residents from environmental problems that they may generate
themselves are inadequate by common standards. To the extent that environmental problems of
a sanitary or microbiological nature are modest on the reservations, it is entirely because the
density of habitation is low. The engineered environmental systems on the reservations provide
little protection against such risks.
Tribal officials are also worried about another source of vulnerability to environmental
risks -- there is little legal and management infrastructure directed at understanding and mitigating
environmental problems. Tribal environmental staffs are small or nonexistent. No Tribal ambient
air or water standards have been developed. Monitoring efforts are limited, with large gaps in
data. The Tribes have little ability to influence pollution sources outside the reservations that
affect reservation lands or the off-reservation areas where fishing and hunting rights have been
retained.
B. Background on the Comparative Risk Process
The comparative risk process is a means of setting priorities among environmental
problems. American society is now faced by a bewildering variety of environmental problems -
- problems that involve numerous different pollutants, sources, and exposure pathways and that
can affect human health, ecosystems, and social and economic values in many adverse ways. The
problems in total exceed the resources for dealing with them. Which problems should
environmental managers work hardest to solve? How can limited resources be focused to achieve
the greatest improvement in our environment? The comparative risk process allows risk
managers to allocate limited time and financial resources to address and remediate those hazards
deemed pose the greatest risks to human health and the environment.
In the first stage of a comparative risk project, the environmental problems facing a
geographic area of interest are compared in terms of the severity of the risks they pose. In these
projects, analysts review available data on the full range of environmental problems facing the
area, evaluate each problem using a consistent analytical framework, and set priorities among
these problems in terms of the human health and ecological risks, and, for many projects, the
economic and social damages that they pose. The different environmental problems are ranked
in terms of their relative seriousness. With this understanding providing a critical background,
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the second stage of a comparative risk project involves deciding what to do about the
environmental problems. Following completion of their risk analyses, project managers use the
analyses and other factors to identify and develop strategies that will deliver the greatest risk
reduction potential for the resources invested. Plans are developed for addressing the problems.
The first stage of the comparative risk process thus requires assessing and comparing
risks, and the second involves decisions about managing risks. These two stages are kept
separate, with the first stage being conducted by individuals with a more technical and scientific
orientation, and the second stage being conducted by personnel with broader concerns for the
administrative, legal, economic, and political aspects of environmental policy. The Wisconsin
Tribes project to date has focused on the first of these two stages risk assessment.
While comparative risk evaluations reveal many similarities in risks across the country,
they also reveal distinct differences that reflect the environmental diversity of our Nation. Even
where the risks are similar, the causes of risk sometimes differ, necessitating unique solutions to
achieve the greatest risk reduction for our environmental protection dollar. As resources to
finance environmental protection become more and more scarce, it is imperative that we make
our investments as wisely as possible. Comparative risk helps us to do that by suggesting where
our efforts can do the most good.
Types of risk
In most comparative risk projects, including this one, three varieties of risk are considered:
to human health, to ecological systems, and to social and economic values. Definitions and
examples of these three types of risk are:
Health risk: cases of human disease or injury caused by the environmental problem.
Health effects can range from cancer (e.g., lung cancer from indoor radon) to problems involving
the nervous system (e.g., from mercury) to gastrointestinal disease (e.g., from pathogens in
drinking water) to injuries (e.g., from accidental releases) to numerous other non-cancer effects.
Ecological risk: damage to the structure and function of natural ecosystems caused by
the environmental problem. Some examples include: eutrophication of water bodies from
nutrients in nonpoint source runoff, loss of species' range, breeding grounds and other effects
from physical modification of habitat, and forests with reduced growth rates and increased
susceptibility to pests due to acid deposition.
Social and economic damages: losses to social or economic values caused by the
environmental problem. Examples from this project include: reduced commercial or subsistence
fishing yields from polluted water bodies, increased maintenance expenses for buildings and other
materials exposed to acid deposition, costs of replacing or treating contaminated drinking water
supplies, and costs of medical treatment and lost productivity for individuals suffering adverse
health effects. Also included under social and economic damages are intangible losses, such as
the cultural losses resulting from fewer eagles and other species of religious significance, and the
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adverse effects of odors or reduced visibility associated with air pollution.
The risk assessment process
In the simplest sense, risks from environmental pollutants are a function of two
measurable factors: hazard and exposure. To cause a risk, a pollutant has to be both toxic or
cause stress (present an intrinsic hazard), and be present in the environment at some significant
level (thereby coming in contact with humans, plants, animals or materials of economic or
cultural value). Risk assessment interprets the evidence on hazard and exposure, judging whether
or not an adverse effect will occur, and usually making the necessary calculations to estimate the
extent of total effects.
STEPS IN RISK ASSESSMENT
1. Hazard identification involves weighing the available evidence and deciding
whether a substance causes a particular adverse effect. Most attention has focused on
human health effects, particularly cancer, but hazard identification extends to ecological
impacts (e.g., would suspended sediment in water harm fish reproduction?) and to social
and economic damages (e.g., would acid deposition reduce profits from forestry?) also.
2. Dose-response assessments determine potency -- how strong a particular
adverse effect is caused by a pollutant at various levels of exposure or dose.
3. Exposure assessment entails estimating the concentrations, frequency and
duration of exposure by humans or other receptors to pollutants of concern, the routes or
pathways of exposure (how the pollutant gets to the receptor), and the number of
receptors exposed for various combinations of exposure and pathways. The best method
is direct measurement or monitoring of ambient conditions, but this is often prohibitively
expensive. In practice, risk assessors usually rely on estimates of emissions and limited
monitoring information, combined with mathematical models that estimate resulting
concentrations.
4. Risk characterization estimates the risk associated with the particular
exposures in the situation being considered. While the final calculations are often
straightforward (exposure multiplied by potency equals risk), the way in which the
information is presented is important. The final assessment should display all relevant
information, including such factors as the nature and weight of evidence for each step of
the process, the estimated uncertainty of the component parts, and the distribution of risk
across various sectors of the population.
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The general risk assessment paradigm serves as a guide in conducting comparative risk
analysis, but it is typically applied quite loosely because of the broad scope of the necessary
analysis.
One might imagine conducting a traditional risk assessment for all the pollutants
associated with each problem area, summing across pollutants, and then comparing the estimated
risks for each problem. In fact, that would be an impossibly large task. Most problem areas
involve numerous pollutants (sometimes potentially thousands), each of which may cause several
damaging effects, and each of which occurs in thousands of different patterns of exposure across
the study area. The risk analysis methods used for comparative risk projects generally consist
of:
o Identifying representative or typical exposure scenarios for representative or key
pollutants associated with each problem area,
o Estimating risks for the chosen scenarios using generally available information on
hazards and dose-response relationships, and
o Scaling up or extrapolating from the portion of the problem area that can easily
be analyzed to the entire problem area.
The risk assessment process conducted in a comparative risk project is thus different from
the typical scientific risk assessment process that is often conducted for a single chemical or a
single contaminated site. Because of the extremely broad scope of a comparative risk project,
it is not possible to marshall enough resources to complete a full quantitative risk assessment on
each problem area before comparing and ranking them. Full risk assessment, in which data on
emissions and ambient concentrations are collected, exposures are modeled, and ultimate impacts
are projected, is very costly. In the Wisconsin Tribes project, then, we collected and analyzed
available data on environmental conditions in the Wisconsin reservations, but supplemented the
data extensively with judgment. The judgments derived from work group members' professional
knowledge, from results of risk studies in nearby areas thought likely to be similar to the
Wisconsin reservations, and from experience gained in previous comparative risk studies
elsewhere.
Note that even if resources for the Wisconsin Tribes project had been unlimited, judgment
would still have been necessary. Risk analysis is an uncertain process. Subjective interpretation
of the results of any risk analysis is always necessary, weighing the strength of the data base used
and the validity of the assumptions made.
In sum, the findings of the Wisconsin Tribes project, as for any comparative risk project,
should be viewed more as the informed judgment of those performing the project than as the
results of a scientific risk assessment. The comparative risk process utilizes data when available,
although often times data does not exist. One of the beneficial outcomes of a comparative risk
exercise is the identification of data gaps. The comparative risk process is an ongoing,
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developing process, not a final, conclusive report. The results are a mix of scientific data, formal
and informal analyses, and much best professional judgement. We collected large amounts of
data and conducted extensive analyses. We took pains to make our judgments, where necessary,
in a systematic and objective fashion. The rankings were done with carefully developed
methodologies. Although the methods were not perfect, they imposed consistency and objectivity
in each problem area. In addition, we conducted analyses and developed rankings in collegial
fashion, with the entire group questioning and debating major points.
The process and results of our deliberations documented in this report were reviewed and
endorsed by the eleven Wisconsin Native American Tribes. The report was also reviewed by
technical staff in each of Region S's media Divisions and Office of Health and Environmental
Assessment, whose comments, as well as those of the Tribes, were incorporated.
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II. Project Methodology
The objective of the project was to evaluate and rank the environmental problems facing
the eleven Wisconsin Tribes. The problems were to be ranked in order of severity, from most
serious to least. We relied largely on a traditional comparative risk approach to achieve this
objective.
A work group consisting of officials from EPA Headquarters and Region 5 was
established to conduct the project. Half of the work group members are Native Americans.
Table 2 lists the members of the work group and the contractor who provided analytical support.
Table 2: Members of Project Work Group
Kestutis Ambutas
Diane Davis
Steve Dodge*
Ed Fairbanks*
John Haugland
Ron Korn*
Caren Rothstein
Catherine Tunis
Lysa Twocrow*
Indian Coordinator, EPA Region 5
Indian Coordinator, Office of Water, EPA Headquarters
(beginning June, 1992)
Indian Environmental Liaison for Wisconsin, EPA Region 5
Indian Environmental Liaison Minnesota, EPA Region 5
Planning and Assessment Branch, EPA Region 5
Intern, Menominee Tribe
Indian Coordinator, Office of Water, EPA Headquarters
(through October, 1991; currently Indian Coordinator,
EPA Region 8)
Regional and State Planning Branch, Office of Policy,
Planning and Evaluation, EPA Headquarters; also Office
of Water, October, 1991 through January, 1992)
Intern, Sioux Tribe
* Native Americans
Also: Stuart Sessions; Contractor, Environornics, Inc.
We took the steps described below.
A. General Approach
1. Establish plans and ground rules. We decided to evaluate the same list of
environmental problems with the same problem definitions as has been used in most of the
Regional comparative risk projects, including the project conducted by Region 5. Making the
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list of problems the same in the Wisconsin Tribes project as in the Region 5 project would
facilitate comparing the ranking results across the two projects. The environmental problems
evaluated in the Wisconsin Tribes project are listed in Table 3. Eventually one problem not
evaluated individually in the Region 5 project food contamination ~ was found to be of
sufficient importance to the Wisconsin Tribes that it warranted addition to the Region 5 list. Two
problems that were found by Region 5 to pose significant risks ~ global warming and
stratospheric ozone depletion were not studied in this project, because information on them and
their rankings would probably be exactly the same for the Tribes as for the entire region.
Table 3: Environmental Problems Evaluated
1. Industrial wastewater discharges to lakes and rivers
2. Municipal wastewater discharges to lakes and rivers
3. Nonpoint source discharges to lakes and rivers
4. Aggregated public and private drinking water supplies
5. Aggregated ground-water contamination
6. Physical degradation of water and wetland habitats
7. Storage tanks
8. Hazardous waste sites with active disposal (RCRA)
9. Hazardous waste sites with past disposal (Superfund)
10. Industrial solid waste sites
11. Municipal solid waste sites (including open dumps)
12. Accidental chemical releases to the environment
13. Pesticides
14. Food contamination
15. Sulfur oxides and nitrogen oxides (including sulfates and acid deposition)
16. Ozone and carbon monoxide
17. Airborne lead
18. Particulate matter
19. Hazardous/toxic air pollutants
20. Indoor air pollutants other than radon
21. Indoor radon
22. Physical degradation of terrestrial ecosystems/habitats
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Definitions of these problems are listed in Appendix A. For a few of the problems, the specific
definition what is included and what is excluded has a particularly important effect on how
the problem was eventually ranked. Definitions that should be noted include:
o Nonpoint source discharges include air deposition and discharge of contaminated
ground-water (e.g., from septic systems) as well as runoff.
o Food contamination includes all contaminants in food from environmental sources.
It thus includes pesticide residues.
o Hazardous air pollutants include effects only while the pollutants are airborne.
The reader should also note that the definitions used result in double-counting of some
environmental risks the same risk may be counted under more than one problem. Thus, for
example, leachate from a municipal waste dump that contaminates ground water that is used as
a drinking water supply is counted under three problems: municipal solid waste sites, ground-
water contamination, and drinking water supplies. Some earlier comparative risk projects
attempted to define environmental problem areas mutually exclusively, so that there was no
double-counting of risks. This approach led to confusion when the project's analysis was used
because risks typically thought to be associated with given environmental problems may or may
not have been included in the definition used. Subsequent projects have opted to use problem
definitions with some double-counting of risks in order to lessen this confusion. The most
important instance in this project where a risk is counted under multiple problems involves air
deposition of mercury and PCBs that are bioaccumulated and bioconcentrated, and are eventually
consumed by Native Americans as they eat fish or game. Risks resulting from this sequence are
counted under nonpoint sources and under food contamination, but not under hazardous air
pollutants.
We decided to rank the environmental problems based upon each of three different types
of risk that they pose: to the health of the members of the Tribes, to the natural ecosystems of
the reservation lands, and to the social and economic well-being of the Tribes. Each type of risk
required somewhat different data and analytical techniques, and the rankings of problems were
quite dependent on the type of risk at issue (e.g., some problems posed serious health risks but
minimal ecological risks, and some problems showed the opposite pattern).
We also decided to adopt a "residual risk" ground rule. Under this approach, all the risks
that will eventually ensue from the current level of an environmental problem are evaluated. The
current level of the problem reflects the current degree of compliance or noncompliance with
environmental control requirements. Problem area rankings based upon residual risk should be
interpreted carefully:
o Under the residual risk approach, an environmental problem might appear to pose
low risks for either of two very different reasons: the problem intrinsically poses
low risks, or it intrinsically poses high risks that have been reduced to low levels
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by an effective control program. The control program holding risks to a low level
may be quite important. One should not simply assume that a problem posing low
residual risks warrants minimal control efforts.
o Residual risks relate to the current level of the environmental problems. Trend
information instances where an environmental problem is improving or
worsening over time ~ is unlikely to be reflected in rankings based upon a
snapshot of the problems as they currently exist.
2. Acquire data and conduct risk analysis. We acquired existing information pertaining
to the environmental problems affecting the Wisconsin Tribes. We developed a preliminary list
of desired information on each environmental problem, and the likely sources of such information
were then contacted. Much of the desired information proved not to exist. In other cases,
because of limitations of time and budget, some of the desired information could not be obtained.
Nevertheless, the information acquired was sufficient to characterize at least roughly the nature
of each of the environmental problems as they affect the Tribes. The primary sources from
which data were obtained included: the Tribes themselves, Wisconsin State agencies, EPA Region
5, the Indian Health Service (U.S. Department of Health and Human Services), the Bureau of
Indian Affairs (U.S. Department of the Interior), and EPA Headquarters. Much of the data was
acquired by two Indian student interns hired for this purpose.
The contractor for the project summarized the available data and performed analyses using
the data to estimate the risks associated with each problem area. The findings for each problem
area were summarized in a series of papers for the entire work group. These papers are included
as Appendix B to this report.
3. Rank the environmental problems. We met for two full days to discuss the findings
and rank the environmental problems in terms of the severity of the risks they pose to the
Wisconsin Tribes. We developed ranking criteria and procedures for this purpose that are
described in the remainder of this chapter.
Our ranking relied both on the quantitative data and analysis generated for each problem,
and on the collective judgment of the work group members. For each problem area, the paper
summarizing the available data and risk calculations was reviewed and discussed. Individual
work group members added additional relevant professional information or experience. A group
discussion ensued and continued until consensus was reached on how a particular problem should
be ranked. The work group's combination of some individuals with a close knowledge of Tribal
lifestyles and conditions on the reservations with other individuals with extensive experience in
comparative risk analysis was very productive in achieving as accurate a portrayal of the relative
risks to the Tribes as was possible within the time and resource constraints of the project.
4. Develop a final report. The contractor for the project drafted a report summarizing
the project results. We reviewed and modified the draft, producing an interim report from the
project. In 1992, the project results and interim report were presented to the 11 Wisconsin Tribes
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for their review. This final project report was then developed in conjunction with the Tribes and
other reviewers at EPA.
Over the course of the project, we convened formally for four one-day or longer meetings.
During the analysis and ranking phase of the project we held bi-weekly conference calls, while
during the remainder of the project conference calls were held approximately monthly. We held
two meetings with representatives of the Wisconsin Tribes in order to review the draft project
findings and solicit Tribal comments.
B. Modifications of Comparative Risk Methods
This set of project activities conducted for the Wisconsin Tribal project is consistent with
those typically undertaken in comparative risk projects. However, there was a qualitative
difference between the Wisconsin Tribes project and other comparative risk studies in terms of
level of effort. The Wisconsin project was a pilot comparative risk project, intended to learn
quickly about the nature of the environmental risks facing the Wisconsin Tribes and to investigate
how the general comparative risk methodology could be applied to a specific sub-population.
The amount of resources applied to the Wisconsin project (work group time and contractor effort)
was somewhat less than in other projects, and the data gathering and analysis were performed
rapidly. Nevertheless, we felt reasonably confident in the conclusions we were able to draw.
In several meetings throughout the project, we considered the degree to which the standard
comparative risk analytical methods should be used to evaluate the distinctive environmental
issues facing the Wisconsin Tribes. The following issues were discussed and resolved.
Overall nature of the comparative risk approach
The comparative risk approach has typically been used to compare the severity of
environmental problems in geographic areas that now have at least several substantial problems.
It has indicated which current, residual risks are the worst, and has thus provided important
information in helping to set priorities for risk reduction efforts.
For the Wisconsin Tribes, however, the situation may be somewhat different. An equally
important objective in environmental management for these Native Americans may be not only
to reduce current environmental risks, but also to prevent these risks from increasing in the
future. This is not to say that the environmental problems currently facing the Tribes are not
significant -- some clearly are. But avoiding potentially greater problems in the future is also
important. We were interested in both using the comparative risk process to elucidate the current
risks facing the Tribes, and in providing some analysis that was more forward-looking.
We were also concerned about how the environmental risks currently facing the Tribes
might look when compared with those existing elsewhere. By comparison with the rest of the
country, the areas in which the Indians live are relatively pristine and free from environmental
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problems. But this does not mean that these problems ~ current and future are only worthy
of little attention. To the contrary, we believe that at least some of the Tribes' environmental
problems may need much more attention because:
o The treaties with the U.S. under which the Tribes ceded some lands and rights and
maintained others prescribe a significant trust responsibility for the U.S.. The
standard by which the U.S. government judges Indian needs for environmental
protection should not only involve comparison of the conditions facing the Tribes
now with conditions facing other Americans now. It should also involve a
historical comparison between current conditions and those prevailing a century
or more ago, when the Federal commitments to the Tribes were made. It should
also involve a view toward future vulnerabilities. The treaties and trust
responsibility require a high level of environmental protection for the reservations
and the surrounding lands on which Indian subsistence rights are retained.
o The Indians are extremely vulnerable to increasing environmental problems in the
future because they lack the technical, administrative and financial infrastructure
necessary to ward off these problems; and
o The Native American culture is uniquely dependent on maintaining a pristine
environment in their historic reservation lands and fishing and hunting grounds.
For the Indians, moving from their reservation lands is not a legally or culturally
acceptable alternative. Even small damages to the reservation environments that
seem modest to outsiders can have significant religious or economic impacts on
Tribes that rely on the natural environment for subsistence.
In effect, two separate questions were raised about whether the traditional comparative
risk framework was sufficient as an analytical foundation for planning actions for a better
environmental future for the Tribes:
1. Is the focus on risks from the current levels of environmental problems appropriate, or
might it be more useful to focus on comparing the risks from the likely future levels of
the environmental problems?
2. Should we conclude our efforts upon ranking the various risks facing the Tribes, or
should we continue on to provide some ideas about priorities in managing the risks that
have been assessed? Traditional comparative risk projects have separated the process of
risk assessment (what is the relative severity of the various risks) from risk management
(what should be done about the risks once they have been assessed).
We resolved these questions by deciding: a) To conduct a traditional analysis of current
residual risks, and b) To go further and identify the problems for which investment in enhanced
environmental protection efforts will do the most to reduce current and future risks. With regard
to the first question, the methodology for comparing projected future risks has not yet been
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developed for EPA comparative risk projects. The data needs and resources required to develop
such a methodology are beyond the scope of this project. In addition, the traditional comparative
risk analysis held some promise of showing that the pattern of risks facing the Wisconsin Tribes
is rather different than the pattern of risks facing the average American ~ and thus that Indian
environmental priorities need special attention. This analysis of current risks would serve as the
starting point if a comparative analysis of future risks is ever initiated. On the second question,
we decided to develop preliminary judgements about the best investments for reducing risks
because of the considerable effort we made in evaluating the risks from each environmental
problem and the causes of those risks. This evaluation is a crucial first step in any deliberation
about risk management. A further discussion of the best opportunities to reduce current and
future risks facing the Tribes is included in the final chapter of this report.
Approach for health risk
We discussed whether modifications were needed to traditional health risk assessment
procedures in order to make them applicable to Native Americans, and if so, what modifications.
Two specific issues were discussed:
1. The demographic and health profile of the Wisconsin Tribes is rather different than
that of the general population. The average age of the Indians on the reservations is
substantially less than that of the general population, cancer incidence is generally higher,
smoking is more common, health care may be less available, and a range of other factors
are different. There may also be important physiological differences between the races
that affect susceptibility to environmentally induced diseases. We considered how these
differences should affect estimation of health risks.
Our consensus was that such differences are important in situations when health
risk estimation depends either on data on incidence of health effects among the Indians
(e.g., data on incidence of gastrointestinal diseases may be used to provide information
about the risks from microbiological contamination of drinking water) or on
epidemiological relationships that can be corrected for cross-cultural differences in risk
factors (e.g., epidemiological relationships between blood lead and learning disabilities
can be adjusted to fit the age distribution of the Indian population). These differences
were judged not to be important, though, when health risk assessment is based upon
traditional calculations where dose is multiplied by potency for environmental pollutants
with health effects information derived from animal studies. Uncertainties already
inherent in the standard health effects data resulting from extrapolation from animals to
humans and from other causes are undoubtedly far more significant than any errors that
might result from not considering racial differences between Indians and the general
population. In general, then, data on potency of environmental pollutants was taken from
standard EPA data bases (e.g., the Integrated Risk Information System) and applied to
Native Americans just as it is applied to the general population.
2. The character of the exposure to environmental pollutants for members of the
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Wisconsin Tribes may be substantially different than it is for members of the general
population, as a function of culture, lifestyles, and the very rural setting for the
reservations. For example, the Wisconsin Tribes obtain a large portion of their food
through local hunting, fishing and gathering. One estimate is that the Chippewa Tribes
obtain 50-90% of their fruits, vegetables, grains, meat, fish, poultry, and sweets from local
harvesting. For the Indians, health risks from food consumption depend substantially on
the levels of environmental contaminants in the local area that may be bioaccumulated in
fish, game, grain or fruits. For the general population, by contrast, food consumption
risks depend much more on the level of contaminants in nationally marketed, mass-
produced, and often Federally-inspected foodstuffs. It would be a serious mistake to
assume that the Indians' diets, and hence their pattern of exposure to contaminants in
food, are similar to those of the general population.
We agreed that the major challenge in the health risk approach was to estimate
accurately the unique Tribal patterns of exposure to environmental pollutants. In some
cases this was possible. Data was obtained specifically for Native Americans on, for
example, subsistence food consumption and on reliance on private wells for drinking
water. Based on such data, it appears that the average Native American consumes about
five times as much fish as does the average American. In other cases it was not possible
to obtain exposure data particular to the Wisconsin Tribes -- we could find no basis for
improving on the standard assumptions that an adult drinks 2 liters of water and breathes
20 cubic meters of air per day.
In sum, when assessing health risks, we thought it important to improve on standard
comparative risk assumptions in estimating Indian exposure to pollutants, but we were generally
willing to use the traditional assumptions for estimating the potency of these pollutants.
Approach for ecological risk
In evaluating ecological risks, we decided to employ traditional comparative risk
approaches. Ecological risk assessment requires a scientific evaluation of the health of the
subject ecosystem and threats to it. We believed this evaluation should focus on the structure
and processes within the ecosystem independent of the uses one wants to make of the ecosystem
or the values one wants to ascribe to it. The results of an ecological risk assessment for a
particular area should be the same whether the study is performed from the perspective of Native
Americans, the mainstream culture, or another group. The ecological rankings thus are not
culturally based. Culturally important aspects of the ecosystems on and around the reservations
are evaluated under other varieties of risk:
o Risks from food consumed from the ecosystems are covered under health risks.
o Religious, cultural, and economic values associated with the ecosystems are
covered under social and economic damages.
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Approach for social and economic damages
This portion of the study involved adjustments to traditional comparative risk methods.
Social and economic damages encompass damages to all of the values held by the population
being studied. Many Native Americans' values differ significantly from those of the general
population, as a result of culture, religion and the different economic pursuits of the Tribes.
Typical methods for evaluating social and economic damages often involve converting disparate
damages into dollar estimates to provide a common metric for comparison. We felt that this
approach would not capture some social damages that are particularly important for the Tribes
which involve non-marketed and difficult-to-value activities (e.g., damages to subsistence hunting
or fishing, cultural losses due to the reductions in numbers and health of eagles over time and
area of wild rice beds). Many of the methods typically used in valuing economic damages (e.g.,
value of a recreation day, functions relating concentrations of particulate matter to soiling
damages) cannot appropriately be extrapolated to Tribal culture, and few are applicable.
We decided to use a more qualitative approach to assessing social and economic damages.
We developed a list of categories of potential social and economic damages that are important
from a Tribal perspective. These damage categories included:
o Diminution of cultural and religious values
o Damage to subsistence activities (e.g., non-commercial hunting, fishing, gathering)
o Damage to natural resources in commercial use (e.g., timber, fisheries, hunting,
trapping)
o Damage to tourism and commercial recreational services
o Health care costs and lost productivity
o Material damage and soiling
o Reduced recreational opportunities
o Damage to water supplies
o Aesthetic effects
We decided that the first three of these damage categories were more important to the Tribes than
the others. Our ranking procedure involved reviewing the extent to which an environmental
problem caused damages in each of these nine categories, weighting the first three more heavily,
and then summing the results across all the damage categories. This ranking procedure is
described more fully in the next section of this chapter.
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Geographic coverage of the project
Most comparative risk projects have focused on a defined geographic area, and have
assessed risks to the people and ecosystems within the area boundaries. Issues associated with
transport of pollutants into or out of the study area have caused difficulties.
The study of the Wisconsin Tribes has been somewhat different. The focus here is on
the risks affecting a specific group of people and on the ecosystems on which they rely. The
members of the 11 Wisconsin Tribes are somewhat dispersed -- most live on the designated
reservations, many live near but off the reservations, and a few live farther away in quite
different settings (e.g., in major urban areas or outside Wisconsin). We decided that the project
should evaluate the nature of the risks faced by the Indians on and near the reservations, and not
consider the potentially different sorts of risks facing other widely scattered individuals. The set
of individuals covered by the study could not be defined much more precisely than this.
Similarly, the geographic coverage of the study was left somewhat vague. The designated
reservations are clearly the most important lands to the Wisconsin Tribes, but other lands have
significance to them also:
o Two Tribes (St. Croix and Winnebago) have a majority of their populations living not
on reservations but in many communities dispersed throughout several Wisconsin
counties; and
o Several Tribes make extensive use of their treaty rights to fishing, hunting and gathering
in the "Ceded Territories", comprising roughly the northern third of Wisconsin.
As a result, although the geographic focus of this study is largely on the designated reservations,
some consideration is also given to conditions on the other lands of importance to the Tribes.
Diversity across the reservations
The intention of this project is to characterize the risks facing the members of the
Wisconsin Tribes as a population distinct from the American culture as a whole. This is
complicated by diversity across the reservations for the eleven Wisconsin Tribes. The
reservations range from Oneida which is nearly completely altered from its historical natural state
and adjoins the urban area of Green Bay, to several that remain largely untouched by
development. The Red Cliff reservation consists mostly of islands in and shoreline on Lake
Superior, reflecting environmental problems typical of the Lake in general. Other reservations,
by contrast, are landlocked and exhibit different problems.
Because of geographic diversity and other differences across the reservations (degree of
development, proximity to external sources of pollution, land use, and so forth), the pattern of
environmental problems facing each Tribe is somewhat different. Our assessments and rankings
are intended to reflect risks on the average across Wisconsin reservations. This averaging was
rarely done in a precise, mathematical fashion. Instead, we used our judgment to determine
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typical conditions across the reservations relating to an environmental problem, and assessed the
risks resulting from these typical conditions. Where for some environmental problem one or
another reservation differed quite sharply from the others, we ranked the problem to reflect
typical conditions, but noted in this report the reservations that differ from the general pattern.
C. Ranking Methods
The most important task for us in this project was to review the data and risk analyses
for each environmental problem, and to rank the problems in terms of their relative severity.
Documentation of this data and analysis for each of the twenty-two problem areas is contained
in Appendix B. Separate rankings were developed for: health risks, ecological risks, and social
and economic damages. These separate rankings were not combined, so no explicit ranking of
problems across all three types of risk was developed. However, there is some consistency in
the separate rankings across the three types of risk, and rough conclusions can be drawn about
the environmental problems that are generally of most importance for the Wisconsin Tribes.
The rankings ultimately depended on a mixture of data, analysis, and professional
judgment by the work group members. The procedures used to develop each ranking were as
follows.
Health risk ranking procedure
Separate rankings were developed for the cancer risks and the non-cancer risks caused by
each of the twenty-two environmental problems. Both rankings were based largely on data
regarding average risks to Tribe members, as data on the distribution of exposures across
individuals was insufficient to generate any sense of the risks to maximally exposed individuals.
The cancer risk estimates consisted largely of estimates of upper bound lifetime excess cancer
risks from exposure to carcinogenic chemicals, derived by standard EPA procedures. The non-
cancer risk estimates were derived mostly by comparing Native Americans' doses of toxic
chemicals with established reference doses, ambient standards or other "virtually safe" levels.
Some information on non-cancer risks came in the form of estimates of the number of cases of
a health effect that were actually reported among Tribe members. The non-cancer ranking
depends primarily on the relative number of individuals likely to suffer non-cancer impacts from
each problem. Information on the relative severity of different non-cancer health effects
associated with the environmental problems was considered, but as a less important factor in the
ranking.
We combined the separate cancer and non-cancer rankings into a single, overall health
risk ranking. Problems that were ranked similarly for cancer and non-cancer risks were kept in
the same category for the combined ranking. For example, if a problem was ranked as high risk
for both cancer and non-cancer, it was ranked high for combined effects also. We then discussed
those problems that had dissimilar ranks for cancer and non-cancer and eventually developed a
combined ordinal ranking by pairwise comparisons where needed.
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Ecological risk ranking procedure
Separate rankings were developed for ecological risks to terrestrial and to aquatic
ecosystems. In developing a ranking for each problem area, we reviewed the ecological stress
agents associated with the problem area, and judged the degree of ecological risk they caused by
considering several criteria:
o The nature and intensity of the effect. This reflects the seriousness of the damage
that occurs in ecosystems that are affected by the stress agents.
o The scale of the effect. This reflects the areal extent of the ecosystems that suffer
this effect.
o The reversibility and time for the ecosystem to recover once the stress is removed.
We combined the separate rankings of risks to terrestrial and to aquatic ecosystems through a
process of group discussion similar to that used to combine cancer and non-cancer health risks.
Problems ranking similarly for terrestrial and aquatic ecosystems were kept in the same category
for the combined ranking. Differing rankings were resolved through discussion.
Social and economic damages procedure
We followed a relatively simple procedure for ranking problems according to their social
and economic damages. For each environmental problem, the damage categories listed on page
18 were reviewed and those in which impacts were expected were noted. For each damage
category in which the problem had an impact, the impact was judged as being either clear and
substantial or as uncertain and modest. The decisions about whether an environmental problem
causes damage in a category and to what degree were based on two criteria:
o What proportion of all the members of the Wisconsin Tribes suffer this damage
from this environmental problem?
o How great is this damage to the individuals who suffer it?
The first three of the nine damage categories were thought to be more important than the others,
and they were given double weight in our evaluation. We used a simple scoring scheme to
develop a preliminary relative ranking of environmental problems. A problem scored one point
for each damage category in which it caused substantial impacts, and 1/2 point for each category
in which it caused modest impacts. Points were doubled for the first three categories. Problems
were first ranked in order of their total points. We then discussed the preliminary ranking and
made several modifications to it based upon group consensus.
For each of the three types of risk, we developed ordinal rankings in descending order of
severity for the twenty-two problems. Despite the limitations in data and analysis, we have
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confidence that these ordinal rankings reflect the true relative risks from the problem areas for
each type of risk. Because of uncertainties resulting from these limitations, we are more certain
of the groupings of problems into higher, medium, and lower risk categories.
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III. Project Results
This chapter recounts the conclusions developed by the project team in several areas. The
environmental problems facing the eleven Wisconsin Tribes were ranked in order of their relative
severity in terms of health risks, ecological risks, and social and economic damages. These
rankings reflect the relative risks expected from the current level of environmental problems as
they affect the Tribes. Using these rankings and the analysis that supports them, together with
a very quick assessment of risk management factors, we also developed a different, more
forward-looking ranking, in which problems were ranked according to their priority for
development of risk-reduction and risk-prevention programs.
The rankings and our rationale for them are discussed briefly in this chapter. For more
detailed information on how each environmental problem affects the Wisconsin Tribes, the reader
is referred to the papers for each problem area in Appendix B.
This chapter also includes a discussion of the major data gaps identified by the project
team in evaluating the environmental problems facing the Wisconsin Tribes and a review of the
overall findings of this project in contrast to previous comparative risk studies of environmental
problems affecting the broad population of Americans. It concludes with our recommendations
and suggested next steps.
A. Health Risk Ranking
Perhaps surprisingly, given the generally isolated and relatively unpolluted character of
the reservations, several environmental problems were found to pose substantial health risks. The
problems ranked as posing high health risks were as follows:
Food contamination. Several studies from Wisconsin and Minnesota and a large amount
of anecdotal evidence indicate that a very high proportion of Great Lakes area Indians' diets
consists of locally harvested fish, game, fruit, grain and sweets. For example, about 90% of the
Indians' consumption of meat, fish and poultry is estimated to derive from local harvesting of
deer, bear, rabbits, walleye, northern pike, ducks and other species. Several of these species are
at the top of terrestrial or aquatic food chains, and they drastically bioconcentrate certain
pollutants found in their environment. Risk calculations combining data on Indian consumption
rates for harvested fish and game with available data on concentrations of contaminants in local
samples of the edible portions of these species yield substantial estimated health threats. Excess
lifetime cancer risks are projected at about 4 x 10~3 (due primarily to PCBs, and secondarily to
a variety of banned but persistent and bioaccumulative pesticides),1 and hazard indices for non-
'. An excess cancer risk of 4 x 10 "3 means that an individual facing such a risk has an additional
4 chances in 1,000 of contracting cancer over a lifetime due to exposure to carcinogens from this
source. For some other environmental problems where EPA has regulatory authority, the goal is often
23
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cancer health effects (the ratio between the dose of a chemical received and its reference dose)
substantially exceed unity for PCBs and for mercury.2 These calculated risks represent those
associated with only a fraction of the Indians' actual diet. Data were not available allowing
calculation of the additional risks from locally harvested grains (e.g., wild rice), fruits (e.g.,
cranberries, for which there is some concern over pesticide applications) or sweets (e.g., maple
sugar), or from non-local foods (e.g., commodities provided through Federal programs, for which
there are some quality concerns).
Nonpoint source discharges to lakes and rivers. Nonpoint sources cause substantial
health risks largely through air deposition of contaminants to surface waters, bioconcentration of
the contaminants in aquatic species and in terrestrial species that feed on the aquatic species (e.g.,
ducks, otters), and heavy consumption by the Indians of the contaminated species. Health risks
due to nonpoint sources are thus double-counted substantially with those from food consumption.
Nonpoint source contamination of surface water contributes virtually no risks through the
drinking water pathway, as all of the Wisconsin Tribes rely on ground water as their regular
source of drinking water.
Substantial research has focused on the sources of mercury and PCBs in northern
Wisconsin lakes. Most of the mercury in lakes derives from wet and dry deposition from the air,
with a small amount from leaching from natural minerals. Point source contributions are
minimal, as nearly all the lakes are isolated and unaffected by point sources. Contributions from
point sources or contaminated sediments may be higher in Lake Superior (affecting the Bad River
and Red Cliff Tribes), but are still insignificant relative to air deposition.
Mercury concentrations in the atmosphere and in precipitation are very low, deriving
from long range transport, with about half being from natural sources (volcanoes and weathering
of minerals) and about half from human sources (fossil fuel burning, industrial and municipal
emissions). Mercury concentrations in the lake waters are also very low. However, fish
(particularly older, larger predator fish such as muskies, walleyes and northern pike) concentrate
the mercury that exists in their environment by factors of up to 1 million. Furthermore, acid
deposition and the resulting acidification of Wisconsin lakes accelerates the biomethylation of
up pollution so that the average excess cancer rate for someone exposed to the problem is reduced to 1
chance in 1,000,000 (a cancer risk of 1 x 10 "*). The estimated cancer risk for Indian consumption of
locally harvested fish and game is thus far higher than EPA often aims for in other programs.
2. For non-cancer effects, when the ratio between the dose received of a chemical and its "reference
dose" exceeds unity, the dose is above the level considered "safe" (based typically upon laboratory
experiments with substantial margins of safety built in). Because of the safety margins built into reference
dose calculations, a dose exceeding the reference dose cannot be said to be "unsafe" strictly speaking,
such a dose exceeds the level at which safety is virtually certain. Exposure to a toxic substance resulting
in a hazard index exceeding one may result in adverse health effects, with the likelihood of adverse health
effects increasing as the hazard index increases. Hazard indices below one signify exposures that are
nearly certain not to produce adverse health effects.
24
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deposition and the resulting acidification of Wisconsin lakes accelerates the biomethylation of
mercury into methylmercury a form much more easily assimilated by the tissues of freshwater
fish. The Wisconsin Department of Natural Resources has been finding that about 1/3 of the
lakes it tests in northern Wisconsin have game fish contaminated with mercury to a degree
warranting issuing a fish consumption advisory for the lake.
PCBs show a somewhat similar pattern of sources and bioconcentration as does mercury.
Air deposition is the primary source of the pollutant (for Lake Superior, 90% of PCB loadings
come from air deposition), and larger, older predator fish show much higher concentrations.
Several differences between PCBs and mercury are:
o PCB concentrations in fish appear to have been declining over the past two
decades or so, whereas mercury concentrations appear to be steady.
o In some areas of the Great Lakes other than Lake Superior and isolated inland
lakes, point sources are significant contributors of PCBs.
o No information suggests that acid deposition plays any role in causing increased
concentration of PCBs in fish.
Indoor air pollutants other than radon. Unfortunately, no data could be obtained on
concentrations of indoor air pollutants other than radon in Tribal housing. However, we still felt
confident in ranking this problem as a significant health risk. All comparative risk studies done
elsewhere have used national data on indoor air pollution scaled to the area being studied. As
in each of the other comparative risk studies, we found indoor air pollution to be one of the
largest sources of both cancer and non-cancer health risks for the Tribes because of the
significant sources and concentrations of air pollutants indoors (secondary cigarette smoke,
combustion products, molds, allergens, solvents, asbestos, etc.) and the large fraction of time
people spend indoors. In fact, several characteristics of Wisconsin Indian lifestyles make them
even more subject to health risks from indoor air pollution than is the general population:
o In most risk studies of indoor air pollution, environmental tobacco smoke
("passive smoking") is the single greatest source of risk. An Indian Health Service
official estimates that perhaps 3/4 of the adult Wisconsin Indian population
smokes, in contrast to 38% of adult Indians nationwide and 26% of all American
adults.
o Indian homes in Wisconsin are disproportionally heated (more than 50%) by wood
burning, a form of heating that commonly produces much higher risks from indoor
air pollution than electric, gas or oil heating. Use of kerosene and other unvented
space heaters is also common in Indian housing.
o The heating season is far longer in northern Wisconsin than is typical in the rest
of the U.S., with houses closed up for more of the year.
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o With extensive recent construction, Indian homes are generally newer and
probably more airtight than the average homes in the U.S., providing less
ventilation and opportunity for exchange of cleaner outdoor air for polluted indoor
air.
Indoor radon. Results of radon monitoring in over 1,000 Wisconsin Indian homes show
a very high weighted average level of 5.8 pci/1, well above EPA's suggested action level for
radon remediation of 4 pci/1. The estimated average individual excess lifetime cancer risk at this
average concentration of radon in reservation homes is about 2.5 x 10"3 for non-smokers and is
extremely high for smokers at 4.5 x 10"2. Smoking greatly exacerbates cancer risk associated
with radon exposure; on average, radon risk to smokers is about 15 times higher than risks to
non-smokers. Lung cancer, which is caused by exposure to radon, is nearly always fatal to those
contracting it. Radon concentrations appear to differ substantially across the reservations, being
quite low in the northernmost reservations (Red Cliff and Bad River), and very high for the
Menominee and Stockbridge-Munsee reservations. Although there may be some upward bias in
these figures due to selective monitoring (homes suspected of having radon problems are often
the first tested), we believe that these data are indicative of a very high cancer risk to Wisconsin
Indians from indoor radon.
Drinking water contamination and Ground-water contamination. We ranked these
two problems as causing high health risks, though clearly lower than the four problems already
discussed above. The health risks from drinking water and ground water are overlapping and
identical, as all of the Wisconsin Tribes' drinking water supplies are obtained from ground water
and treatment of the ground water is minimal. The limited available data on drinking water
quality for Wisconsin Tribal water supplies suggests likely problems with the following
contaminants:
o Radionuclides. Levels appear fairly high. Levels in many of the community
systems and private wells are likely to exceed EPA's probable forthcoming
national standards.3 Limited data on the relationship between radon in ground
water and radon in indoor air suggests that an average of 5% of the radon in
indoor air derives from groundwater. This relationship is dependent upon
temperature and degree of agitation, among other factors. Most of this risk occurs
as radon volatilizes from water, particularly during showering, and is subsequently
inhaled.
o Microbiologicals. Although the community water systems on the reservations
rarely report a violation of the bacteriological MCLs, we are nevertheless
concerned that the minimal treatment given to reservation water supplies combined
with the widespread reports of septic system failures and poorly constructed
3. EPA has established or will establish national "Maximum Contaminant Level" (MCL) standards
prescribing allowable levels of many different contaminants in drinking water.
26
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shallow water wells could lead to frequent bacteriological contamination of
drinking water.
o Nitrates. Exceedances of the 10 mgA MCL for nitrates are probably common on
four of the reservations, judging from limited sampling data and the locations of
agricultural production.
Evidence suggests that levels of other contaminants in Tribal drinking water pesticides,
synthetic organics, VOCs and metals extremely rarely exceed health-based levels of concern.
No data are available on concentrations of lead in drinking water.
We ranked several environmental problems in the next tier, as causing medium health
risks. Highest among these was Pesticides. Pesticides in food were thought probably to cause
modest risks, based largely on concentration data in fish and game and on previous national
studies that found significant residues in many nationally marketed foods. Pesticides used in
cranberry farming and forest management were also of some concern. Municipal solid waste
was ranked as the next most serious problem, primarily because of sanitary problems associated
with its disposal in scores of open dumps across the reservations. Uncontrolled burning,
modestly contaminated leachate and runoff, and rats and other vermin are common at these sites.
Other problem areas ranked as causing medium health risks were each responsible for modest
risks in the vicinity of a few widely scattered sites: Toxic air pollutants, Municipal wastewater
discharges, and Abandoned hazardous waste sites. A final problem area -- Sulfur oxides and
nitrogen oxides (including sulfates and acid deposition) was ranked as causing medium
health risks largely because of the role of acid deposition in increasing mercury concentrations
in fish.
Ten other problems were ranked as causing low or no health risks to members of the
Wisconsin Tribes. Most notable among them were several problems relating to criteria air
pollutants Ozone and carbon monoxide, Airborne lead, and Particulate matter. Criteria
air pollutants are often judged to cause very substantial health risks in many other areas of the
country, but their levels on the Wisconsin reservations are well below health-based standards.
Table 4 summarizes our overall health risk ranking. Table 5 shows the separate rankings
for cancer and non-cancer health risks that were combined into the overall ranking.
B. Ecological Risk Ranking
We believe that ecological conditions on and near the reservations are generally good.
Most aquatic ecosystems are healthy, with naturally reproducing populations of game fish. Water
quality in most rivers and lakes is good, with only a few lakes suffering nutrient enrichment
problems and nearly all assessed stretches of rivers judged as supporting the designated uses set
by the State of Wisconsin. Most of the original wetland acreage remains. Terrestrial ecosystems
are also generally healthy, with most reservations remaining in a nearly natural, largely forested
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Table 5: Cancer and Non-Cancer Health Risks
Non-Cancer
Cancer
[Problem Area
1
Food contamination
Nonpoint sources
Indoor air pollution
Drinking water contamination
Ground water contamination
Municipal solid waste
SOx, NOx, and acid deposition
Municipal point sources
Air toxics
Storage tanks
Industrial point sources
Inactive hazardous waste
Ozone and CO
Particulate matter
Airborne lead
Accidental releases
Pesticides
Indoor radon
Physical degradation - aquatic
Physical degradation - terrestrial
Active hazardous waste
Industrial solid waste
Ranking problem Area
High
High
High
Medium
Medium
Medium
Medium
Low
Low
Low
Low
Low
Low
Low
Low
Low
Low
None
None
None
None
None
ndoor radon
7ood contamination
ndoor air pollution
Nonpoint sources
'esticides
jroundwater contamination
)rinking water contamination
Municipal solid waste
\ir toxics
Municipal point sources
nactive hazardous waste
ndustrial point sources
\ccidental releases
*hysical degradation - terrestrial
'hysical degradation - aquatic
Storage tanks
'articulate matter
SOx, NOx, and acid deposition
\irbornelead
)zone and CO
\ctive hazardous waste
ndustrial solid waste
Ranking
Very High
Very High
Very High
High
High
High
High
Medium
Medium
Medium
Medium
Medium
Medium
Low
Low
Low
None
None
None
None
None
None
29
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condition. Timbering operations are carefully controlled, and have little negative impact. Small
amounts of the reservations have been developed for housing, commercial, transportation or other
purposes. Populations of most terrestrial species seem healthy and stable or growing, particularly
deer, bear and rabbits.
There are, however, indications of some serious ecological problems. Populations of a
few predator species (eagles, mink, osprey, otters, lake trout) have declined very substantially
from historical levels, because of either toxic substances (e.g., eggshell thinning in birds resulting
from accumulations of pesticides), competition from introduced species (e.g., lamprey eels
preying on lake trout), reduction in suitable habitat throughout the region, and/or overharvesting.
Although game fish are abundant and healthy in most lakes, their numbers are reduced, probably
due to subtle changes in habitat, fishing pressure, and deterioration in water quality. Some water
bodies have undergone massive hydrologic disruptions with construction of dams, flood control
projects, and channelization. Two reservations have been extensively transformed by farming.
Acid deposition appears to contribute to some forest decline, and to acidification of surface
waters.
In sum, then, ecological conditions on and near the reservations are quite good by
comparison with most of the remainder of the U.S.. However, conditions now do not match
those of a century or more ago when the U.S. made its treaty commitments with the Tribes.
We ranked the following three problems as causing relatively higher ecological risks.
Nonpoint source discharges to lakes and rivers was ranked as causing the greatest
relative risks. Perhaps surprisingly, the high concentrations of PCBs, mercury, and other toxic
substances (which derive largely from nonpoint sources) in large fish in reservation areas do not
seem to be symptomatic of extreme ecological damage. Extensive studies of fish populations in
the ceded territories have found:
o Populations of walleye, muskie and northern pike appear lower than decades ago,
but have been stable in recent years despite increasing fishing pressure. Each of
these fish is still found in most of its historical range.
o Deformities, lesions and tumors (typical signs of substantial stress to fish
populations from toxic substances) do not appear to be common.
Nevertheless, populations of plant-eating fish (e.g., perch, whitefish) are clearly generally
healthier than populations of predator fish that bioconcentrate toxic substances to a greater
degree. Non-fish species that consume large amounts offish (e.g., bald eagles, cormorants, terns,
mink, otter) also seem to be adversely affected by toxic substances, particularly PCBs. In
addition to toxic substances, nonpoint sources are also responsible for nutrient enrichment and
eutrophication of some lakes (primarily from septic tanks and fertilizer runoff) and siltation of
some areas of fish habitat.
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Sulfur oxides and nitrogen oxides (including sulfates and acid deposition) was ranked
as causing the second most ecological damage. Precipitation in northern Wisconsin is moderately
acidic at a pH of about 4.5 to 5.0. Acidity seems to be decreasing in recent years with
decreasing emissions of SO2. Studies have found moderate ecological changes from acid
deposition in Northern Wisconsin lakes, some changes in forests, and no impacts yet on streams.
A 1988 survey found about 6% of Northern Wisconsin's lake area to be acidified (pH of
less than 6.0), which is a lower percentage than in many other areas of the country. At this level
of acidity some aquatic species are typically lost, although a diverse and healthy aquatic
ecosystem is still probable. All aquatic life is likely to be lost at a pH of about 4.2; but none of
Wisconsin's lakes approaches this level. Acid deposition to Wisconsin lakes facilitates uptake
of mercury by fish, and this in turn has adversely affected the health and reproductive success
of fish-eaters such as eagles, osprey, loons and furbearers. The acid neutralizing capacity of
Wisconsin's lakes is fairly low, with 40% classified as extremely sensitive to acid deposition.
Studies of Wisconsin forests found about 1% of the sugar maples to be experiencing
decline or to be dead as a result probably of acid deposition. 50 - 70% of the white pines
displayed premature needle loss due to a combination of acid deposition and ozone.
Physical degradation of water and wetland habitats was ranked as the third most
serious ecological problem. Maps drawn from aerial photographs show a substantial proportion
of lake and river shorelines within the reservations to be developed with low density resorts,
cottages, cabins, and docks. For several decades, some of the Tribes were actively seeking
revenue by leasing or selling their most desirable waterfront lands to outsiders. These numerous
small developments have resulted in fill and alteration of wetlands and shoreline spawning areas,
reduction of shoreline fish cover, modification of water flows, and increased siltation. Some
water bodies in reservations have been sharply altered by off-reservation hydropower dams, flood
control projects and channelization. The Lac Court Oreilles Reservation, for example, lost much
of its historical wild rice acreage because of an off-site dam and flooding.
Other environmental problems were ranked as causing lesser ecological risks to the
reservations and nearby areas. We ranked Physical degradation of terrestrial habitats as
causing medium risks. On most reservations, land development activities (housing, transportation,
timbering, agriculture, etc.) are at a sufficiently limited scale to cause no discernable impact to
terrestrial ecosystems or species. For several reservations (particularly Oneida and St. Croix),
though, agricultural and other development has proceeded far enough to change substantially the
character of the ecosystems. Pesticides was also ranked as causing medium ecological risks,
primarily because of their substantial historical impacts on eagles and fish-eating birds. There
was also some concern about the unknown, but possibly significant impacts of pesticide use for
cranberry production, timber management, and rights-of-way clearing. Finally, Municipal solid
waste sites was ranked as causing medium risks due to their impacts on plant and animal
communities in the immediate vicinity of the many scattered open dump sites.
Among the problems ranked as causing low or no ecological risks, several deserve
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mention. Municipal wastewater discharges and Industrial wastewater discharges were ranked
low because there are very few of them that actually affect reservation waters. There has been
only one Accidental release with a documented ecological impact (the rupture of an oil pipeline
traversing the Bad River), and the impact was transitory. Only one confirmed Hazardous waste
site with past disposal exists on or near the reservations (the Fort Howard sludge lagoon), and
it appears to have no ecological impact.
Table 6 summarizes our overall ranking of ecological risks. Table 7 shows the separate
rankings for risks to aquatic and terrestrial ecosystems that were combined into the overall
ranking.
C. Social and Economic Damages Ranking
As previously described (see page 18), a wide variety of different impacts were evaluated
under the topic of social and economic damages, ranging from some closely related to health
risks (e.g., the costs of health care and lost productivity associated with adverse health impacts
from pollution) to others closely related to ecological risks (e.g., the reduction in commercial and
subsistence opportunities when a resource such as a fishery is damaged) and to others not closely
related to other varieties of risk (e.g., cultural, religious or aesthetic damages). Although nine
different categories of damages were considered, our ranking of social and economic damages
gave greater weight to three:
o Diminution of cultural and religious values;
o Damage to subsistence activities; and
o Damage to natural resources in commercial use.
Nonpoint source discharges to lakes and rivers was ranked as the most important
source of social and economic damages. The designation of an ever-expanding number of the
Tribes' traditional fishing lakes as subject to fish consumption advisories is having a substantial
adverse cultural impact. Spearing of fish and sharing the catch among Tribe members has been
a traditional activity for centuries, but increasing numbers of Indians are having difficulty
participating wholeheartedly in these activities now. Many Indians are worried about limiting
their fish consumption, about where the fish they are given have been obtained, and about the
number of lakes being suggested to be off-limits. Nonpoint sources are responsible for most of
these impacts.
Physical degradation of water and wetland habitats was ranked as the second most
important source of social and economic damages. Flooding from hydropower dams and siltation
and other hydrological changes have sharply reduced or eliminated the wild rice beds in several
reservations. Resort use of prime waterfront properties by non-Indian outsiders, while welcomed
as a source of revenue in the past, is now regarded as an aesthetic problem and a cultural affront.
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33
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Table 7: Aquatic and Terrestrial Ecosystem Risks
Aquatic
Terrestrial
Problem Area
Nonpoint sources
SOx, NOx, and acid deposition
Physical degradation - aquatic
Municipal solid waste
Industrial point sources
Municipal point sources
Pesticides
Groundwater contamination
Physical degradation - terrestrial
Storage tanks
Inactive hazardous waste
Accidental releases
Drinking water contamination
Indoor air pollution
Indoor radon
Active hazardous waste
Industrial solid waste
Air toxics
Ozone and CO
Food contamination
Airborne lead
Participate matter
Ranking problem Area
High
High
Medium
Medium
Low
Low
Low
Low
Low
Low
Low
Low
None
None
None
None
None
None
None
None
None
None
Physical degradation - terrestrial
SOx, NOx, and acid deposition
Pesticides
Nonpoint sources
Municipal solid waste
Air toxics
Accidental releases
Groundwater contamination
Storage tanks
Municipal point sources
Physical degradation - aquatic
Industrial point sources
Inactive hazardous waste
Industrial solid waste
Indoor radon
Indoor air pollution
Ozone and CO
Food contamination
Airborne lead
Active hazardous waste
Paniculate matter
Drinking water
Ranking
Medium
Medium
Medium
Low
Low
Low
Low
Low
Low
Low
Low
Low
Low
Low
None
None
None
None
None
None
None
None
34
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Food contamination was ranked as causing high risks for reasons similar to those causing
nonpoint sources to be ranked as causing the greatest social and economic damages. So was
Sulfur oxides and nitrogen oxides (including sulfates and acid deposition). Acid deposition
also poses a further long term threat to the forests that define the character of most of the
reservations.
Physical degradation of terrestrial habitats was also ranked as causing high risks. Two
Tribes whose culture has been largely focused around forested lands now have reservations that
have become mostly agricultural (Oneida and St. Croix) in character. On most reservations, even
the low amount of commercial development that occurs (particularly the gaming establishments
that bring in large numbers of visitors) is sufficient to create a clash with traditional Indian
culture. Development also appears to be a significant factor in the decline of mink and other
furbearing animals that supported substantial commercial trapping activities several decades ago.
Trapping has now declined to minimal levels.
The final problem area ranked as causing high social and economic damages was
Hazardous waste sites with past disposal. Although there is only one such site known to be
on or adjacent to the reservations the Fort Howard paper company sludge lagoon ~ we
considered any such site to be a major damage to the cultural values associated with respect for
the Earth.
The problems ranked as causing medium social and economic damages introduce several
additional noteworthy types of damages. Municipal wastewater discharges, Accidental
releases, and Municipal solid waste sites all represent very poorly controlled uses of the
reservation environment for waste disposal in what is viewed as an unthinking, cavalier manner
that the Indians find culturally offensive. Pesticides are largely responsible for the reduced
populations of eagles, a bird of particular religious and cultural significance to the Indians.
Indoor radon and Indoor air pollution other than radon are both likely to produce high health
care costs and losses in productivity among those who are stricken with the diseases they cause.
Drinking water contamination and Ground-water contamination involving high iron
concentrations in many reservation water supplies cause poor tasting water and aesthetic
problems, or necessitate water treatment expenses to avoid the aesthetic problems.
Table 8 summarizes our overall ranking of social and economic damages.
D. Data Gaps
In the course of our evaluation of the risks posed to the Wisconsin Tribes from
environmental problems, we found a number of important data gaps. Improved knowledge in
these areas would contribute substantially to better understanding and more efficient management
of Indian environmental problems. The data gaps include:
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Basic environmental monitoring information. Relatively little information exists
specific to the reservations themselves on concentrations of environmental pollutants in air,
surface water, ground water, drinking water, or food. Much of the monitoring information we
obtained for this project derived from locations outside the reservations that we judged were
likely to exhibit conditions similar to the reservations. This extrapolated information is likely to
be generally representative of the reservations, but monitoring of the reservations themselves is
likely to be valuable in uncovering unexpected hot spots or anomalies.
Comprehensive ecological characterization. Information on the health of the ecosystems
in and near the reservations is widely scattered and anecdotal. Substantial information exists on
some species (e.g., walleyes, eagles) and on some problems (e.g., mercury in lakes, old from
pollution) to others closely related to ecological risks (e.g., the reduction in commercial and
bioaccumulative pesticides), but there is insufficient linkage of this information into a systematic
understanding of broad ecological trends. For example, the populations of minks and other
furbearing species appear to have declined substantially in recent decades, a change with
important ecological and cultural implications. We found no general evaluation of the reasons
for this population decline ~ whether it be excessive trapping, the sensitivity of these species to
even small amounts of human development, some adverse change in an element of their habitat,
toxic substances in their food supply, or other factors. A more systematic understanding is
needed of ecological trends and their relationship to environmental problems.
Indoor air pollution. All previous comparative risk studies have identified indoor air
pollution as one of the most serious environmental threats to the health of the general population.
No specific data were available on concentrations of air pollutants in Wisconsin Indian homes,
but several characteristics of the Indians' lifestyle led us to suspect that risks to Indians were
likely to be even higher than to the general population. Studies to characterize the extent and
severity of indoor air pollution in Indian homes and to pinpoint its causes are needed to better
characterize this high risk.
Lead. Similarly, lead has been found to be a significant source of health and social and
economic damages in most studies of other populations. No data were available for the
Wisconsin Tribes on lead concentrations in blood or drinking water. While there is no suggestion
that the Tribes are likely to have worse lead problems than the general population, some sampling
is needed to evaluate the magnitude among Native Americans of this often substantial problem.
Contamination of food other than fish and game. Sampling of local fish and game
suggests substantial risks to the average Wisconsin Indians. No data were available on
contaminants in other local foodstuffs relied upon heavily by the Indians for subsistence ~ wild
rice, seasonal vegetables, cranberries and other berries, maple sugar, etc.. These plants may or
may not concentrate contaminants from their environment and contribute further to the doses of
toxic substances in the Indian diets. Similarly, no information is available on the quality of non-
local foods consumed by the Indians, particularly the Federally-supplied commodities. Sampling
for pesticides, metals, synthetic organics and other toxic substances in the remainder of the Indian
diet beyond local fish and game would allow for a more complete characterization of the risks
37
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from food contamination.
E. Need for Environmental Protection Infrastructure
The risk rankings we developed reflect the risks that result from current environmental
problems facing the Wisconsin Tribes. The Tribes, however, feel particularly vulnerable to
worsening environmental problems in the future.
The isolation of the reservations has protected them from external environmental threats
to some degree so far. However, as development outside the reservations continues, pollutants
will flow into the reservations. The Tribes feel powerless to influence the nature and impacts
of this development. Conscious choices by the Tribes to limit industrial development and
resource extraction within the reservations have also helped to minimize environmental problems.
Such choices are becoming harder to maintain as needs for economic development intensify.
Juxtaposed against likely growing external and internal environmental threats is the nearly
complete lack of administrative or physical infrastructure with which the Tribes can manage
environmental problems from sources either within or outside of the reservations. For example,
Tribal environmental staffs are minimal; there are few Tribal laboratories and minimal
environmental monitoring has occurred; there are no air or water quality standards enforced for
the reservations; and many drinking water treatment, sewage treatment and waste disposal
facilities are substandard.
In addition, the Tribes contend that environmental quality may mean more to them than
to the mainstream American culture. The Tribes place high value on their traditional harmonious
relationship with their ecosystem. They have subsisted for centuries within the carrying capacity
of local ecosystems on the physical and biological resources provided by their lands. But the
Indians are now limited in pursuing their traditional activities to the small vestigial reservation
areas and treaty-specified hunting and fishing areas. These areas must remain undamaged for
centuries into the future if the Tribes are to maintain their ancestral values.
Comparative risk projects can provide an analytical foundation on which efforts to reduce
environmental risks are based. But the comparative risk approach evaluates current, demonstrated
environmental risks. Comparative risk alone cannot devote sufficient attention to the need to
protect the land and Indian culture from risks for the very long term future and the vulnerability
of the small amount of reservation land to growing risks in the future. It is very important to
build the capacity for Tribes to protect their environment both from current risks (where most of
the attention in this project was devoted) and from potential future risks (where less attention was
focused). We thus developed some broad recommendations for environmental protection
priorities for the Tribes to respond to the combination of current and potential future problems.
The following is a list of the environmental problems facing the Wisconsin Tribes for which
infrastructure development (both administrative and physical) is most necessary:
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Highest priority areas for infrastructure development:
- Protection of surface water quality (from nonpoint sources, and industrial and municipal
point sources)
- Protection of groundwater and drinking water quality
- Municipal solid waste
- Aquatic and terrestrial habitat alteration
- Radon
- Pesticides
- Food contamination (both subsistence fish and game, and USDA commodities)
Risks could be substantially lowered, particularly in these areas, if Tribes had the
appropriate capacity to manage environmental problems. The Tribes need capability themselves -
- in terms of both knowledge and resources and support and cooperation from other
organizations such as EPA and the State. The Tribes must be able to understand, manage and
protect their reservation environments directly, and must be able to influence the policy decisions
made off the reservations that can have major impacts on the reservations and surrounding lands
on which Indian subsistence rights are retained.
In recommending these areas for risk reduction efforts, we considered the rankings for
each type of risk together with the analysis that supports those rankings. The analysis shows the
causes of the risk ~ key information to developing effective solutions. In developing priorities
for responding to risks, we also considered a variety of factors bearing on the likely degree to
which risks in each area can be managed. We call these "risk management factors"; they include
cost-effectiveness, technical feasibility, political and organizational feasibility, legislative authority
and so forth. In developing this list of priorities, we considered all the information on current
and future risks contained in the analysis together with a very quick assessment of the risk
management factors.
The analysis documented in this report is a crucial first step in identifying where
investments in capacity-building can be most important in reducing risks. Additional analysis
and discussion of the risk management considerations will lead to the most effective and
successful solutions.
F. Comparing the Results with Other Studies
We ranked several environmental problems as consistently posing high risks across each
of the three different types of impacts. These appear to be the most significant environmental
problems affecting the Tribes overall:
o Nonpoint source discharges
o Food contamination
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o Acid deposition
o Physical degradation of aquatic habitats
The first three of these problems interrelate through long-range air deposition of PCBs, mercury,
and pesticides onto surface waters, and bioaccumulation of these toxic substances through aquatic
and terrestrial food chains in a process partly exacerbated by acid deposition. Damages then
occur to the health of Native American subsistence consumers of local fish and game, to aquatic
and terrestrial ecosystems, and to Native American cultural traditions and commercial
opportunities. Physical degradation of aquatic habitats involves a different set of issues, causing
primarily ecological and cultural damages.
In addition to these problems that we ranked as causing substantial risks across more than
one category of damage, we ranked several other important problems as causing high risks in
only one category of damage:
o Indoor air pollution and indoor radon are responsible for serious health risks;
o Physical degradation of terrestrial habitats causes significant social and economic
damages; and
o Hazardous waste sites with past disposal are also responsible for large social and
economic damages.
These rankings of environmental problems for the Wisconsin Tribes are quite different
than those developed in other comparative risk studies of the general population in a variety of
geographic areas. The most significant contrasts with other studies are discussed below. 4
Food contamination from environmental sources (except for residues of agricultural
pesticides) has never been noted as a top problem in other projects. For the Wisconsin Tribes,
food contamination clearly causes serious health and social and economic damages even without
considering a contribution to risk from pesticide residues on agricultural crops. The high risks
from this problem to the Wisconsin Tribes result from the combination of an environment in
which, though it is relatively pristine, large numbers of top-of-food-chain predators efficiently
bioconcentrate toxic chemicals and a culture that highly values subsistence harvesting activities.
Problems deriving from industrial activity rank unusually low on the reservations, but
often rank high in other studies. In the Region 5 comparative risk study, for example, accidental
releases, toxic air pollutants, abandoned hazardous waste sites, and industrial point source
4 The rankings of the relative risks to human health, ecosystems, and economic and social
systems for the Wisconsin Tribes from different environmental problems are compared here to the
relative rankings for these same problems as developed in other comparative risk studies. We did not
attempt to compare any absolute level of risk found across different studies.
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discharges all ranked far higher than they did for the Wisconsin Tribes. There is simply very
little industrial activity on the reservations or in their immediate vicinity.
Problems deriving from long range transport of pollutants rank unusually high on the
reservations. To generalize very broadly, most comparative risk projects have found that the
most serious risks usually derive from sources within or near the study area. While nearby
sources are important for some environmental problems affecting the Tribes, the more serious
problems facing the reservations derive largely from outside the reservations. This has important
implications for risk management, since extensive cooperation between the Tribes and other
governmental jurisdictions is necessary to address distant sources of contamination.
Most studies find that criteria air pollutants pose high health, ecological and economic
risks. On the reservations, by contrast, we found that they pose rather low risks (with the
exception of acid deposition).
We ranked municipal solid waste sites as causing medium health, ecological and social
and economic damages. These rankings contrast with typical findings that municipal solid waste
sites pose low risks. The higher ranking for the Tribes is due to the very poor practices in effect
at the many household waste dump sites on the reservations.
Many comparative risk studies have found that point sources of water pollution (municipal
and industrial) pose at least medium ecological and economic risks. For water bodies on the
reservations, though, there are very few point sources with any potential impact at all. Most such
point sources are small and in compliance with their state and Federal permit limits, and both
municipal and industrial point sources pose generally low risks to the Wisconsin Tribes.
Several factors explain these substantial differences between the ranking of environmental
risks to the Wisconsin Tribes and the rankings obtained in other studies of the population at
large. First is the isolated, rural, and generally undeveloped nature of the reservations. Most
comparative risk studies have focused on areas where the bulk of the population lives in
developed, industrialized urban areas. A second factor is the general choice made by the Tribes
to pursue activities on the reservations that are in harmony with the environment. The Tribes are
motivated to maintain their lands such that their environment will yield a sustained flow of goods
and services. They have generally avoided industrial development and other activities that may
seriously damage the environment. The final difference involves the lifestyle and culture of the
Wisconsin Tribes. Heavy reliance on subsistence hunting, fishing, and gathering makes the
Tribes vulnerable to whatever pollutants concentrate in local food sources. The cultural
importance of certain features in the Indians environment (e.g., eagles, wild rice, mink) means
that the Indians are much more affected by environmental problems that influence these specific
features than is the general population.
We believe that the very substantial differences between the pattern of environmental risks
facing the Wisconsin Tribes and that facing the general population suggest that the Indians need
somewhat different environmental programs than does the population at large. Priorities for
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environmental action for the Indian Tribes should differ from those for the general population,
as a reflection of the differing risks facing each group. The understanding provided by this
project of the relative environmental risks facing the Tribes, together with consideration of risk
management factors, will help in developing more effective environmental programs to protect
the unique people and resources of the Wisconsin Tribes.
Other Tribes in other areas, as well as other minority groups, may face other patterns of
environmental risks that differ from those faced by the population as a whole. The comparative
risk process could be of significant value to other groups in determining more clearly what their
specific environmental protection needs may be.
G. Project Recommendations
After completing the analysis and risk evaluations, we have two recommendations for the
use of this project's methods and results: 1) use the analysis and rankings to help guide risk
management activities both on the reservations and in EPA and other Federal agency programs;
and 2) use the adapted comparative risk methodology in future comparative risk projects with
other Tribes.
This comparative risk project has assembled a significant amount of data that has been
combined with professional judgement in a consistent analytical framework to evaluate the risks
that affect the Wisconsin Tribes and the environment in which they live and on which they
depend. The project has produced valuable information and insights on these risks and possible
ways to prevent, control, and reduce them. We recommend that these analytical results be used
on the reservations to target and address current (and potential future) high risks. We also
recommend that the analysis and rankings be used in EPA's programs to help guide their priority-
setting and program activities. Discussions with other Federal and State agencies can begin a
process where these project results are used to help guide actions in their programs as well.
The comparative risk framework has been used successfully by EPA and other state and
local governments to evaluate and rank risks that are used to set priorities for action. This
project has adapted the framework to more accurately assess the risks faced by the Native
Americans and their environment by considering the different pathways and exposure routes
affecting the health of the Tribes and their cultural and economic values that are affected by
environmental problems. We believe that these methods have been very useful in evaluating the
risks faced by the Tribes and will provide valuable insights to improve risk management
activities. We recommend that these adapted methods be used to assess risks for other Native
American Tribes to determine how risks differ on their reservations and empower them to more
effectively address those risks.
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H. Suggested Next Steps
Most of our effort in this project has centered on risk assessment ~ evaluating the
environmental problems facing the Wisconsin Tribes and ranking them in terms of their relative
severity. In conducting this process we have gained a better understanding of these problems and
some broad insights on how to address them, and have identified areas where improved
information can significantly increase our ability to understand, evaluate, and ultimately address
the Tribes' environmental risks.
In several areas, a better understanding of the problem would contribute significantly
to targeting remedial programs at key portions of the problem:
o More detailed information on the ecology of the reservation areas and how it is
influenced by various habitat altering activities;
o Studies to characterize the extent and severity of indoor air pollution in Native
American homes and commercial structures; and
o Sampling to determine the quality of the remainder of the Indian diet beyond local
fish and game.
In determining what should ultimately be done to address risks, one cannot simply apply
all resources to the top-ranked problems, or even to proportion the resources according to the
rankings with somewhat more resources going to the top-ranked problems than to the lower-
ranked problems. The rankings of residual risk alone will not tell you how resources can be used
most effectively to reduce those risks. But the rankings, together with the analysis that supports
them, will provide insights into the causes of the risk and will serve as a very powerful tool for
developing effective and efficient solutions for addressing those risks. The risk management
factors ~ cost-effectiveness, technical feasibility, political and organizational feasibility, and
legislative authority5 can help you determine which proposed solutions, with what
implementation plan and on what time schedule, are best.
Some environmental problems clearly pose high risks to the Tribes now: the interrelated
problems of food contamination, nonpoint sources and acid deposition; habitat alteration; indoor
air pollution, and radon. Comprehensive programs should be developed to address these specific
problems, beginning with the existing measures that are already under way.
For other environmental problems that have been found to be less serious, the lower level
of many of the other environmental risks on the reservations is due to the low density of risk-
5 Lack of legislative authority is not always an insurmountable barrier to implementing necessary
solutions. There may be non-regulatory solutions, such as education or economic incentives, that can be
implemented, or an agency can work with legislative bodies to implement needed legislation.
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producing activities on or near the reservations, and not to the fact that risk-producing activities
are well managed. Infrastructure for managing environmental risks on the reservations --
programs for environmental research, monitoring, standard setting and enforcement, as well as
facilities for sewage treatment, solid waste disposal, drinking water treatment and the like is
very limited. The current modest programmatic and physical infrastructure could easily be
overwhelmed by future growth of population and economic activity. The Tribes need both better
environmental management programs and improved environmental protection facilities to keep
risks from growing in the future. At a minimum, the Tribes need adequate environmental
protection staffs, a basic monitoring program (at least for the larger reservations), environmental
quality standards that reflect Tribal designated uses, credible implementation and enforcement
programs, and support for constructing and operating appropriate waste management facilities.
An environmental education program for the reservations and surrounding communities can help
generate public support for building the necessary Tribal environmental protection capacity.
Many of the risks faced by the Tribes derive from activities outside the reservation rather
than on the reservations. The Tribes have very little ability to affect decisions on these activities
and protect their interests. Native Americans should be able to participate in environmental
decisions affecting them (affecting both the reservations themselves and the ceded territories)
made at the State, regional, and national levels. The Federal trust responsibility should be fully
upheld in the environmental area. This may include measures to reflect the Tribes' interests on
issues such as: re-licensing decisions for hydroelectric projects, other major developments needing
Federal and State approvals, decisions on State designated uses for land and waters in the ceded
territory, and State and Federal environmental budget priorities.
Even if these steps can be accomplished ~ if Tribes develop effective environmental
management programs for the reservations, and if they participate in and have their interests
represented in decisions explicitly affecting their environment there will still be a residual of
environmental problems stemming from long range transport of pollutants from diffuse sources.
Broad scale acid deposition and air deposition of PCBs and mercury appear to be such issues.
To address these problems, we believe that all elements of society governments, industry, and
households ~ can benefit from use of pollution prevention as the solution of first choice, together
with pollution control, regulatory, economic incentives, or other actions as appropriate, to both
prevent and reduce risk from environmental problems. American society at large can learn from
the Native Americans' credo of living in harmony and partnership with the environment.
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Appendix A: Definitions of Problem Areas Considered for Ranking
1. Industrial Wastewater Discharges to Lakes and Rivers
These are sources of pollution that discharge effluents into surface waters through discrete
conveyances such as pipes or outfalls. This problem area does not include publicly and privately
owned municipal wastewater discharges. Pollutants of concern include total suspended solids;
BOD; toxic organics, including pthalates and phenols; toxic inorganics such as heavy metals; and
thermal pollution. Typical sources of discharge include metal finishing, pulp and paper
processing, and iron and steel production. Facilities requiring permits under the National
Pollution Discharge Elimination System (NPDES) fall under this problem area.
2. Municipal Wastewater Discharges to Lakes and Rivers
This problem area includes all constituents of the outfalls of publicly and privately owned
municipal wastewater treatment facilities. Both municipal sewage treatment outfalls and
industrial discharges that flow through publicly operated treatment works are included in this
problem area. Major contaminants include all those found under Industrial Wastewater
Discharges to Lakes and Rivers, plus ammonia, chlorination products, and nutrients. Combined
Sewer Overflows (CSO's) are included in this problem area.
3. Nonpoint Source Discharges to Lakes and Rivers
Nonpoint Source Discharges include pollutants that reach surface waters through sources other
than discrete conveyances for effluents. This includes runoff from agricultural, urban, industrial,
silvicultural, or undisturbed land. Possible pollutants are quite varied, including most of the
constituents of the point source discharges to surface waters. Storm water carries a large amount
of solids, nutrients, and toxics. Other sources included in this problem area are: surface discharge
of septic tanks, releases from contaminated in-place sediments, air deposition of pollutants (except
for acids), and mine drainage. Pollutants not included in this problem area are those from acid
deposition, solid waste disposal, hazardous waste sites (RCRA and CERCLA), and physical
impacts from discharges of dredge and fill material.
4. Aggregated Public and Private Drinking Water Supplies
As drinking water arrives at the tap, it may contain a wide variety of contaminants from both
natural and man-made sources, and point and nonpoint sources. Since many of the contaminants
can be traced to other problem areas, Drinking Water risk evaluation will involve much double-
counting with those other problem areas (Industrial Wastewater Discharges, POTW Discharges,
Nonpoint Source Discharges, Storage Tanks, hazardous and non-hazardous waste problem
areas.etc). Drinking Water is included as a problem area because remediation/treatment options
can occur either at the source of contamination (the other problem areas) or at the delivery
system of the drinking water (treatment or switch to alternative supplies). Drinking Water
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includes both delivery systems that serve 25 or more people and are therefore covered by the
Safe Drinking Water Act, and those which serve fewer than 25 people and are not so covered.
Pollutants of concern include disinfection byproducts, pesticides, inorganics (such as heavy
metals), radionuclides, toxic organics, fluoride from natural sources, and microbiological
contaminants.
5. Aggregated Groundwater Contamination
All forms of groundwater pollution, including sources not counted in other problem areas,
compose this problem area. These include fertilizer leaching, septic systems, road salt, all
injection wells, nonwaste material stockpiles, pipelines, and irrigation practices. The list of
possible contaminants is extensive and includes nutrients, toxic inorganics and organics, oil and
petroleum products, and microbes. As with drinking water, there is much double-counting in this
problem area. It is included as a separate "special" problem area like drinking water because a
true understanding of the overall risks to this resource is particularly important, and because such
an understanding is difficult if the risks are split between many different problem areas.
6. Physical Degradation of Water and Wetland Habitats
Damages arising from alterations in the quantity and flow patterns of groundwater and surface
water are included in this problem area. Such disturbances include channelization, dam
construction and operation, surface and groundwater withdrawals, construction and flood control,
irrigation distribution works, urban development, and the disposal and runoff of dredge and fill
materials. Physical changes to water flow and aquatic habitats are included in this problem area,
as is chemical contamination resulting from physical changes (e.g. dredging of contaminated
sediments).
7. Storage Tanks
Storage Tanks includes routine or chronic releases of petroleum products or other chemicals from
tanks that are above, on, or under ground, tanks owned by farmers, fuel oil tanks of homeowners,
or other storage units (such as barrels). Stored products include motor fuels, heating oils,
solvents and lubricants that have air emissions or can contaminate soil and groundwater with such
toxics as benzene, toluene, and xylene. This category excludes hazardous waste tanks. Acute
releases (explosions, tank collapse) are examined under Accidental Releases.
8. Hazardous Waste Sites with Active Disposal (RCRA)
This category generally includes the risks posed by active and inactive hazardous waste sites
regulated under the Resource Conservation and Recovery Act (RCRA). These sites include
RCRA open and closed landfills and surface impoundments, hazardous waste storage tanks,
hazardous waste burned in boilers and furnaces, hazardous waste incinerators, and associated
solid waste management units. Seepage and routine releases from these sources contaminate soil,
surface water, groundwater, and pollute the air. Contamination resulting from waste
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transportation and current illegal disposal are also included. Radiation from hazardous "mixed
waste" from RCRA facilities is included in this problem area.
9. Hazardous Waste Sites with Past Disposal (Superfund)
This category includes hazardous waste sites not covered by RCRA, but by Superfund. Most are
inactive and abandoned. Sites can be on the National Priorities List (NPL), deleted from the
NPL, candidates for the NPL or simply be noted by the federal government or states as
unmanaged locations containing hazardous waste. Sites may contaminate ground or surface
water, pollute the air, or directly expose humans and wildlife. There are many pollutants,
including TCE, toluene, heavy metals, and PCB's. Radiation from hazardous "mixed waste" in
abandoned/Superfund sites is included in this problem area.
10. Industrial Solid Waste Sites
Industrial Solid Waste Sites includes open and closed industrial landfills, industrial sludge and
refuse incinerators, and industrial surface impoundments. These sources can contaminate ground
and surface water and pollute the air with particulates, toxics, BOD, microbes, PCDF's, PBB's,
and nutrients. Contamination may occur through routine releases, soil migration or runoff. Most
sites are regulated under Subtitle D. This category excludes active and inactive hazardous waste
sites. Although the list of potential contaminants is similar to that of municipal solid waste sites,
the concentrations, volumes, and mixes of pollutants found on typical industrial sites are
frequently very different.
11. Municipal Solid Waste Sites (including open dumps)
Municipal Solid Waste Sites includes open and closed municipal landfills, municipal sludge and
refuse incinerators, and municipal surface impoundments. These sources can contaminate ground
and surface water and pollute the air with particulates, toxics, BOD, microbes, PCDF's, PBB's,
and nutrients. Contamination may occur through routine releases, soil migration or runoff. Most
sites are regulated under Subtitle D. This category excludes active and inactive hazardous waste
sites.
12. Accidental Chemical Releases to the Environment
Contaminants may accidentally be released into the environment in a variety of ways during
transport, storage, or production. An industrial unit may explode and emit toxics into the air, a
railroad tank car may turn over and spill toxics into surface water or roads, or a ship may run
aground and spill oil or other cargo into the environment. Damages to property, personnel, and
wildlife may occur from intense, short term releases of toxic or flammable chemicals. Acids,
PCB's, ammonia, pesticides, sodium hydroxide, and various petroleum products have been
accidentally released.
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13. Pesticides
This problem area addresses risks arising from the application, runoff, groundwater
contamination, and residues of pesticides to humans and the environment. It included risks to
people applying agricultural pesticides, including farm workers who mix, load, and apply them.
Also included are risks to the public and non-target plants and wildlife as a result of short range
drift, overspray, and misuse. Disposal of mixed pesticide wastes has resulted in the generations
of highly toxic, largely unknown byproducts that have entered the air and caused serious health
problems. Suburban spraying of property, often done with high pressure systems, can result in
contamination of neighboring property, residents, pets, and livestock. Aside from direct exposure,
additional pesticide risks stem from exposure through ingestion of residues on foods eaten by
humans and wildlife. Bioaccumulation and food chain effects are also included in this category.
Note that the accidental releases and indoor air pollution from pesticides are respectively included
in the Accidental Releases and Indoor Air problem areas.
14. Food Contamination
This problem area includes the effects of all contaminants introduced through environmental
channels into the food eaten by humans. It includes chemicals (including pesticides)
bioconcentrated or bioaccumulated in organisms eaten as food by humans unless the chemical
was intentionally applied to the food. The effects of pesticide residues on grain or fruit are thus
excluded when the pesticides have been applied to these crops, but the effects of residues in fish
or game that have eaten the grain or fruit are included. The effects of food additives (e.g.,
nitrites, growth hormones, dyes) are excluded. The effects of substances added during food
storage, processing, or preparation are excluded.
15. Sulfur Oxides and Nitrogen Oxides (including Sulfates and Acid Deposition)
Sulfur Oxides and Nitrogen Oxides cause a wide variety of primary and secondary effects.
Primary effects include health, visibility, and welfare impacts. A major secondary effect is acid
deposition, which results from chemical transformation of oxides of sulfur and nitrogen,
producing acid rain, snow, and fog, as well as dry deposition. Acid deposition alters the
chemistry of affected aquatic and terrestrial ecosystems, damaging plant and animal life. Sources
are a wide variety of industrial, commercial, and residential fuel and related combustion sources.
This problem also includes visibility effects resulting from the long range transport of sulfates.
16. Ozone and Carbon Monoxide
Ozone and Carbon Monoxide are major air pollutants in many areas, arising from both mobile
and stationary sources. Damage to forests, crops, and human health can be severe. Note that
volatile organic compounds (VOC's) are critical precursors to ozone formation, but the direct
effects of VOC's are included in the Air Toxics problem area. To the extent that VOC's result
in ozone, those ozone effects are captured by this problem area.
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17. Airborne Lead
Air emissions of lead result from many industrial and commercial processes. This problem area
includes both direct exposure to lead and exposure to deposited lead from airborne sources. It
does not include exposure to airborne lead from drinking water delivery systems or lead found
in homes and buildings from leaded paint.
18. Paniculate Matter
Both total suspended particulates (TSP) and fine particulates/PMlO are included in this problem
area. Major sources include motor vehicles, residential fuel burning, industrial and commercial
processes, and in some cases, strip or open pit mining.
19. Hazardous/Toxic Air Pollutants
This problem area covers outdoor exposure to airborne hazardous pollutants from routine or
continuous emissions from point and nonpoint sources. Pollutants include asbestos, various toxic
metals (e.g. chromium, beryllium), organic gases (benzene, chlorinated solvents), polycyclic
aromatic hydrocarbons (PAH's, such as benzo(a)pyrene, primarily in particulate form), gasoline
vapors, incomplete combustion products, airborne pathogens, cooling towers, and a variety of
other volatile organic chemicals and toxics. The problem area covers exposure through both
inhalation and air deposition of these pollutants to land areas. Runoff of pollutants deposited on
land or direct deposition to surface waters is addressed in Nonpoint Sources. Major sources
include large industrial facilities, motor vehicles, chemical plants, commercial solvent users, and
combustion sources. This category excludes, to the extent possible, risks from pesticides,
airborne lead, radioactive substances, chlorofluorocarbons, emissions from waste treatment,
storage and disposal facilities, storage tanks, and indoor air toxicants.
20. Indoor Air Pollutants Other than Radon
This category applies to exposure to accumulated indoor air pollutants, except radon, primarily
from sources inside buildings and homes. These sources include unvented space heaters and gas
ranges, foam insulation, pesticides, tobacco smoke, wood preservatives, fireplaces, cleaning
solvents, and paints. The pollutants include tobacco smoke, asbestos, carbon dioxide, carbon
monoxide, nitrogen oxides, lead, pesticides, and numerous volatile organic chemicals such as
benzene and formaldehyde. Occupational exposures are included, as is inhalation of contaminants
volatilized from drinking water.
21. Indoor Radon
Radon is a radioactive gas produced by the decay of radium, which occurs naturally in almost
all soil and rock. Risks occur when radon migrates into buildings through cracks or other
openings in the foundation, water, or fuel pipes. The gas is trapped by dense building materials
and can accumulate to very high levels. When inhaled, radon decay products can cause lung
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cancer. This category includes radon volatilized from domestic water use, and also includes
occupational exposures. The problem area does not include outdoor radon.
22. Physical Degradation of Terrestrial Habitats
Sources affecting terrestrial ecosystems/habitats include both chemical and non-chemical stress
agents. Because chemical sources of degradation are addressed in other categories, this category
includes physical modifications (such as mining and highway construction) and other sources of
degradation (such as dumping of plastics and other litter) that affect terrestrial
ecosystems/habitats. Effects on undisturbed lands/habitats that result from nearby degradation
(habitat fragmentation, migration path blockage) are also included in this problem area. EPA
often has no regulatory authority over sources of physical degradation, while in other cases it may
be able to influence them through the NEPA/EIS process.
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Appendix B: Background Papers on Problem Areas
Industrial, Municipal and Nonpoint Source Discharges B-3
Drinking Water and Ground-Water Contamination B-14
Physical Degradation of Aquatic and Terrestrial Habitats B-22
Unintended Releases of Toxic Substances B-26
Pesticides B-34
Food Contamination B-38
Criteria Air Pollutants B-49
Hazardous/Toxic Air Pollutants B-59
Indoor Air Pollutants Other than Radon B-62
Radon B-80
General References B-83
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Problems have been grouped for discussion in background papers as follows:
1. Industrial wastewater discharges to lakes and rivers
2. Municipal wastewater discharges to lakes and rivers
3. Nonpoint source discharges to lakes and rivers
4. Aggregated public and private drinking water supplies
5. Aggregated groundwater contamination
6. Physical degradation of aquatic habitats
22. Physical degradation of terrestrial habitats
7. Storage tanks
8. Hazardous waste sites with active disposal (RCRA)
9. Hazardous waste sites with past disposal (Superfund)
10. Industrial solid waste sites
11. Municipal solid waste sites (including open dumps)
12. Accidental chemical releases to the environment
13. Pesticides
14. Food contamination
15. Sulfur oxides and nitrogen oxides (including sulfates and acid deposition)
16. Ozone and carbon monoxide
17. Airborne lead
18. Particulate matter
19. Hazardous/toxic air pollutants
20. Indoor air pollutants other than radon
21. Indoor radon
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Industrial, Municipal and Nonpoint Source Discharges
This paper provides information relating to three environmental problem areas:
1. Industrial wastewater discharges to lakes and rivers.
2. Municipal wastewater discharges to lakes and rivers.
3. Nonpoint source discharges to lakes and rivers
Available Data
We used several sources of data for this assessment:
o The Wisconsin 305(b) report for 1990, which provides an assessment of surface water
quality throughout the State. The assessment is based on a combination of monitoring
results from fixed stations, special studies, and the field knowledge of DNR personnel.
Unfortunately, these three sources tend to concentrate on large rivers, water bodies near
populated areas, and water bodies with known problems. Rivers and lakes within the
Wisconsin tribal reservations meet none of these criteria. Hence, the assessment data
from the State is limited and not very specific regarding the condition of surface waters
on the reservations.
o The Wisconsin Nonpoint Source Assessment Report for 1988. This provides some
additional data on surface water quality. It ranks types of nonpoint sources in terms of
their impact on water quality statewide.
o A study by EPA Region 5 identifying point sources that might potentially affect surface
water quality on reservations. Point sources were defined as having a potential effect if
they were within 30 miles upstream or within 10 miles adjacent in the case of lakes. In
our view, this is a reasonably conservative way to identify potential impacts -- it typically
requires a combination of a large discharger and a small stream to find significant impacts
30 miles downstream. 31 point source dischargers that could potentially affect reservation
surface waters were identified in this study.
o Anecdotal responses by the Wisconsin tribes about surface water problems and their
sources provided in the 1988 CERT/GLIFWC study of tribal environmental needs.
Problems were often cited in this study based upon speculation, and actual monitoring
data to buttress the speculation is rarely available.
o Miscellaneous publications regarding the health of fish populations and water quality
in specific water bodies.
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Findings From These Data Sources
The Wisconsin 305(b) report lists no water bodies on reservations among those
"significantly impaired by point sources of toxic pollutants". The 305(b) report characterizes
surface water quality as generally good in the northern and north-central regions of the state
where the bulk of the reservations are located. Detailed water quality assessments are not
available for the specific lakes and river reaches in reservations. Broader assessments by the
State of the entire river basins within which the reservations are located show the following
pattern:
o Water quality fully supports State of Wisconsin 14,709 miles (96 %)
designated uses
o Water quality partially supports State of Wisconsin 498 miles (3 %)
designated uses
o Water quality does not support State of Wisconsin 0 miles
designated uses
o Water quality threatened 95 miles (1 %)
Water quality on the reservations appears to be substantially better than the average throughout
the state -- statewide only 62% of the assessed stream miles fully support State of Wisconsin
designated uses. Note, however, that these are State designated uses rather than Tribal ones. The
uses the Tribes would like to make for waters (particularly with reference to their historical
condition at the time the treaties were signed) are probably higher than are currently provided for
by the State standards.
Data from the 305(b) report pertaining to the river basins within which the reservations
are located clearly portray nonpoint sources (primarily agriculture) as contributing significantly
more to water quality problems than point sources.
Information from the Region 5 study on point source dischargers potentially affecting the
reservations is presented at the end of this paper. We supplemented the information from Region
5 with what we could learn quickly about each of the dischargers. Significant findings include:
o 3 of the reservations have no point source dischargers that potentially affect them. Two
reservations (Bad River with 13 and Red Cliff with 7) account for the bulk of the 31
potentially important dischargers.
o Most of the 20 dischargers potentially affecting these two reservations are counted as
doing so because they are within 10 miles of the reservations along Lake Superior. Lake
Superior affords large dilution, and we doubt that any of the dischargers along the lake
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actually affect these two reservations substantially.
o Of the 31 potentially important dischargers, 7 are industrial, 23 are municipal and 1 is
unknown.
o Only 2 of the 31 dischargers are in significant noncompliance with their State permit
limits. These are two small POTWs.
o Of the 7 industrial dischargers, only 2 are listed in EPA's TRI data base as significant
dischargers of toxic pollutants, one potentially affecting Bad River and one potentially
affecting Lac Courte Oreilles. The other 5 industrial dischargers are unlikely to be
significant sources of toxic effluents (one power plant, one sawmill, one food processor,
and two fish hatcheries).
o Of the 23 municipal dischargers, one serves a population of nearly 10,000 (Ashland,
which discharges to Lake Superior). The remainder appear to serve populations of less
than 3,000. Such small POTWs are unlikely to cause any significant water quality
problems when they are in compliance with their State permit limits.
Actual or suspected surface water quality problems reported by the reservations for the
CERT/GLIFWC survey and in subsequent comments are reported below. We have also noted
the type of source (industrial, municipal or nonpoint) that is most responsible for each problem.
I M NPS
Bad River:
o Mercury in fish x
o Concerns about Kakagon Slough, an important wetland and
rice-producing area: problems with pleasure boats,
sedimentation, maybe heavy metals and pesticides x
o Failing septic systems x
o Runoff from old toxic sludge storage site x
Lac Courte Oreilles
o Wild rice lost through dam and flooding
o Sewage from resorts flows untreated into lakes x
o Possible runoff from open dumps x
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I M NFS
o Off-reservation dam has changed water levels and interfered
with fish spawning
o Herbicides used on rights-of-way may run off x
Lac du Flambeau
o Mercury in fish x
o Pulp mill outfall in lake x
Menominee
o Sewage treatment improvements needed at Keshena x
Mole Lake
o No problems cited
Oneida
o Agricultural pollutants -- pesticides, fertilizer, sediment x
o Runoff from active and abandoned solid waste sites x
Potawatomi
o Sedimentation in lakes and streams x
o Runoff from landfills and industrial sites x
o Septic systems overloaded and poor condition x
Red Cliff
o Contaminants in Lake Superior fish: mercury, pesticides x
St. Croix
o Mercury in fish x
o Rice harvest down, walleyes down, carp up ?
o Water quality problems in Yellow River ?
B-6
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I M NFS
o Septic system discharges x
Stockbridge-Munsee
o Plywood mill yard runoff x
o Tribal sewage treatment lagoons have potential impact x
o Septic system failures x
Winnebago
o Need sewage treatment plant. Septic systems inadequate x
General Conclusions About Surface Water Quality
Surface water quality on reservation lakes and rivers is generally very good, with the
exception of the issue about contaminants in fish. Any other problems cited are localized and
small. Most lakes are classified as mesotrophic, with relatively little nutrient enrichment. Few
lakes are actually acidified, although most of the lakes are quite sensitive to acidification.
Relatively few point sources potentially affect reservoir surface waters, and their actual impacts
are probably minor.
Comparing the relative impacts of different sources of water quality problems, it seems
clear that nonpoint sources (particularly air deposition and septic systems) are far more important
than point sources. A relative comparison of the impact of industrial and municipal point sources
is not so clear -- each causes minor impacts. On balance, it appears that municipal point sources
cause slightly greater impacts than industrial point sources because of their greater prevalence and
poorer compliance record.
Health Risks
Health risks from surface water contamination can arise in either of two primary ways:
consumption of contaminated drinking water, or consumption of contaminated fish. No
Wisconsin reservations obtain their drinking water from surface sources, so this pathway is not
of concern. Consumption of contaminated fish, however, represents a substantial health risk to
the average member of a Wisconsin tribe (see paper on food contamination). The contaminants
primarily responsible for this health risk are PCBs and mercury. At present, these contaminants
derive almost completely from nonpoint sources air deposition and natural minerals. Only a
very few of the reservation lakes or rivers have point sources upstream of them. For the few
water bodies potentially affected by point sources, PCBs and mercury may plausibly derive from
current point source discharges or from past discharges that have contaminated sediments that are
now still releasing these toxic substances. Nonpoint sources appear to cause substantial health
B-7
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risks, while industrial and municipal point sources contribute minimal health risks.
It may be of interest here to summarize the recent research on the source of the mercury
levels in fish. Mass balance studies of isolated lakes in northern Wisconsin indicated that nearly
all of the mercury derives from wet (in rain and snow) and dry (in particles) deposition from the
air, with a small amount from leaching from natural minerals. For most lakes, mercury
contributions from point sources, runoff, or sediments are unlikely. Concentrations of mercury
in precipitation are extremely low; perhaps 1/4 derives from industrial and municipal air
emissions of mercury, 1/4 derives from fossil fuel burning, and 1/2 derives from natural air
emissions (volcanoes and weathering of minerals). Current concentrations of mercury in
precipitation appear 2-3 times as high as they were in pre-colonial times.
Mercury concentrations in lake waters in northern Wisconsin are often only 1/10 that in
precipitation. However, fish concentrate the mercury that exists in their environment by factors
of up to 1 million. Acid waters appear to play a critical role in facilitating conversion of
inorganic mercury to organic forms that tend to concentrate in fish tissues (biomethylation of
mercury into methylmercury a form easily assimilated in fish tissue). Typically, fish that are
larger and older and higher up the food chain (large fish such as muskies, walleye and northerns
that eat small fish) show the highest levels of mercury contamination. Typical concentration
levels for mercury might be:
In precipitation 10 parts per trillion
In lake water 1 part per trillion
In large sport fish 1 part per million
The Wisconsin Department of Natural Resources (DNR) has been finding that about 1/3 of the
lakes it tests in northern Wisconsin have game fish contaminated with mercury to a degree
warranting issuing a fish consumption advisory for the lake.
PCBs show a somewhat similar pattern of sources and bioconcentration as does mercury.
Air deposition is the primary source of the pollutant (for Lake Superior, 90% of PCB loadings
come from air deposition), and larger, older predator fish show much higher concentrations.
There are several differences between the nature of the problem with PCB and with mercury,
however:
o PCB concentrations in fish have been declining for the past decade or so, whereas
mercury concentrations appear to be steady.
o In several of the Great Lakes other than Lake Superior, point sources are a significant
contributor of PCBs. This is particularly true in industrial harbor areas, where point
sources and previously contaminated sediments continue to release PCBs.
o No information suggests that acid deposition plays any role in causing increased
concentration of PCBs in fish.
B-8
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Ecological Risk
Perhaps surprisingly, the high concentrations of toxic substances in large fish in
reservation areas do not seem to be symptomatic of substantial ecological damage. Although the
concentrations are high enough to pose a health threat to human consumers of fish, the fish
populations themselves in lakes and rivers near the reservations appear generally healthy.
Extensive studies of fish populations in the ceded territories by the GLIFWC and WDNR have
found:
o Populations of walleye, muskie and northern pike are approximately stable over recent
years despite increasing fishing pressure. Each of these fish is still found in most of its
historical range. 56% of the lakes in which walleye can be found and 30% of the lakes
in which muskie can be found have naturally self-sustaining populations of these fish.
Most of the remainder of the lakes have populations that are maintained at least partly by
stocking.
o Deformities, lesions and tumors (typical signs of substantial stress to fish populations
from toxic substances) do not appear to be common.
Nevertheless, there are some signs of ecological damage in aquatic ecosystems, largely from
nonpoint sources:
o Many acres of fish spawning beds have been silted over or actually filled in.
o A few lakes have suffered acidification or accelerated eutrophication, with substantial
resulting changes in the resident aquatic species.
o Lake trout populations have declined sharply, partly due to the adverse effects of PCBs
on development of the young fish larvae.
In general, populations of plant-eating fish (e.g., whitefish, perch) are healthier than those of
predator fish, suggesting a broad impact from bioconcentration of toxic substances.
Additional damages to species other than fish have resulted to animals that consume large
amounts of fish:
o Young Forester's terns waste away through a condition induced by PCBs in their diet
that is similar to starvation.
o Cormorants have difficulty hatching because of edema (fluid retention in the head,
neck, and abdomen preventing the chick from lifting its head to crack out of its shell),
and some are born with deformities such as fused vertebrae and crossed bills. PCBs are
suspected as the cause.
B-9
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o Bald eagles living inland have far greater reproductive success than those living near
the Lake Michigan shoreline. Blood from young bald eagles living near the shore has up
to nine times the concentration of PCBs as those hatched farther inland.
o Mink and otter populations have declined very sharply (though potentially due to
several factors in addition to toxic substances).
Like mercury, PCBs also bioconcentrate in animal tissues. PCB concentrations in tern eggs have
reached 25 million times their concentration in water.
Social and Economic Damages
No studies are available quantifying the effects of various sources of water pollution on
social and economic values in the areas of the reservations. We would estimate these effects as
follows:
o Diminution of cultural and religious values. There could be substantial losses here.
The knowledge that a large portion of the Tribes' traditional fishing grounds is populated
with fish not fit for consumption and that many additional areas may also be contaminated
substantially reduces these values.
o Damage to subsistence activities. Tribal catch levels and the amount of effort expended
per unit of catch both seem to be holding reasonably constant over the past 5 years. Over
a longer time period, effort per unit catch has clearly increased. However, this is
probably more a result of greater fishing pressure than of pollution.
o Damage to commercial fishing. The Red Cliff commercial fishing operation has
become more difficult as a result of declining populations of some Lake Superior species.
The population declines result jointly from fishing competition and the lamprey eel as
well as pollution.
o Surface water pollution might also be expected to cause some damages to tourism,
health care costs, reduced recreational opportunities, and aesthetic concerns.
B-10
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List of Point Source Dischargers Potentially Affecting Reservation Waters
Name of Discharger
Bad River
Anderson S.D.
Ashland
Bad River Tribe
Hurley
James River Co., Ashland
Knight
Knowles Mgt. Co.
Mellen
Montreal
Northern States Power, Bayfield
Pence
Saxon
WI-DNR Copper Falls St. Park
Forest Co. Potawatomi
Wabeno S.D.
Lac Courte Oreilles
Louisiana Pacific Co., Hayward
Lac du Flambeau
Lac du Flambeau Tribe
Menominee
Keshena Well #1
Menominee Tribal Enterprise
WI-DNR Langlade Rearing
Municipal or
Industrial Comments
M Unknown small # served
M 9615 served
M About 1000 served
M 2418 served
I Pulp mill, in TRI
M Unknown small # served
? ?
M 1168 served
M 877 served
I Power plant, not in TRI
M < 1000 served
M < 1000 served
M Small
M 800 served
Paper mill, in TRI
M About 1500 served
M Iron from water tmt.
I Sawmill, probably with little
toxics
I Hatchery, probably with little
toxics
B-ll
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Oneida
Hill Ctr -- Oneida Tribe
Oneida Res. Site I
Oneida Res. Site II
Provimi Inc.
Red Cliff
Bayfield
Bell San. District
Madelaine S.D.
Ondossagon Public School
Pikes Bay S.D.
Washbum
WI-DNR Bayfield Hatchery
Stockbridge-Munsee
Stockbridge-Munsee WWTP
M Small
M Total served about 1000 for
M the two sites. Oneida Site I
in noncompliance for BOD,
TSS, bacteria
I Food processing, not in
TRI. Probably with little toxics
M 874 served
M Small
M Small
M Small
M Small. Noncompliance for
TSS
M 1957 served
I Hatchery, probably with little
toxics
M < 1000 served
B-12
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Sources
Bro, Kenneth M., et.al. "Relative Cancer Risks of Chemical Contaminants in the Great Lakes."
Environmental Management. 11:4. 495-505.
The Conservation Foundation. Great Lakes. Great Legacy? 1990.
Council of Energy Resources Tribes / GLIFWC. Environmental Needs Survey for Tribes of
Region 5. Jan./Feb., 1988.
DeVault, David S. "Contaminants in Fish from Great Lakes Harbors and Tributary Mouths."
Archives of Environmental Contamination and Toxicology. 14. 587-594.
DeVault, David S., et.al. "Contaminant Trends in Lake Trout (Salvelinus namaycush) from the
Upper Great Lakes." Archives of Environmental Contamination and Toxicology. 15. 349-356.
Great Lakes Fishery Commission. "Lake Superior: the State of the Lake in 1989." Special
Publication 90:3.
National Audubon Society. Special video program: Great Lakes. Bitter Legacy. NTAS 704.
Pratt-Shelley, Judy, Great Lakes Indian Fish and Wildlife Commission. Various correspondence
and fact sheets on mercury in fish. 1991.
Tenney, Kenneth S., U.S. EPA Region 5. Memo:"NPDES Dischargers Impacting Indian Lands."
23 Dec., 1986.
U.S. Department of the Interior and Bureau of Indian Affairs. Casting Light Upon the Waters:
a Joint Fishery Assessment of the Wisconsin Ceded Territory. 1991.
U.S. Environmental Protection Agency. Toxic Chemical Release Form 1989 Data Summary.
2 February, 1991.
Wisconsin Department of Natural Resources. Health Guide for People Who Eat Fish from
Wisconsin Waters. October, 1991.
Wisconsin Department of Natural Resources. Nonpoint Source Assessment Report. August,
1988.
Wisconsin Department of Natural Resources. Water Quality Assessment. Report to Congress.
1991.
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Drinking Water and Ground-Water Contamination
This paper provides information relating to problem areas # 4 and # 5, "Aggregated Public
and Private Drinking Water Supplies" and "Aggregated Ground-Water Contamination."
Available Data
We used several sources of data for this assessment:
o Wisconsin's 1988 Nonpoint Source Assessment Report, which contains an extensive
review of ground-water quality and contamination incidents, including maps of the
locations where nitrate, pesticide and VOC contamination has been detected.
o Qualitative reports about drinking water quality for each of the Wisconsin reservations.
These are relevant to both the drinking water and ground-water issues because all of the
tribes rely on untreated or minimally treated ground water as their source of drinking
water. The quality of drinking water as it arrives at the consumer's tap is virtually
identical to the quality of the ground-water source.
o Data from Region 5 and the CERT/GLIFWC study on violations of drinking water
standards by community water systems for the reservations. Unfortunately, the
monitoring data available for community water systems on the reservations cover
microbiological contaminants only.
o A variety of materials describing the amount of activities that might potentially
contaminate ground water that occurs on reservations, including: USTs, household waste
dumps, industrial waste sites, septic systems, abandoned wells, and spills.
o A DRASTIC map for the state, indicating the vulnerability of ground water in each
reservation to contamination from surface sources.
o Specific data on nitrates, radionuclides and other contaminants in ground water for some
reservation areas.
Evaluation of Drinking Water and Ground-Water Quality
All Wisconsin tribes draw their drinking water from ground water sources. Roughly half
the population is served by community water systems and half relies on private wells. Most of
the private wells and many of the community wells are shallow at roughly 50 feet in depth.
Some of the community wells are drilled as deep as several hundred feet. Many of the
community water systems provide no treatment. A few are chlorinated (though studies reveal that
a chlorine residual is often not maintained throughout the distribution system) and several are
B-14
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fluoridated also. Several systems use iron filters to remove undesirably high concentrations of
iron. Water from private wells is rarely treated.
Relative to water systems elsewhere in the country, those serving Wisconsin tribe
members provide very little treatment. As a result, the quality of ground water underlying the
reservations and the quality of the drinking water consumed by reservation residents are virtually
identical.
Natural ground water quality in the area of the reservations is generally good for drinking
and other purposes, with the following exceptions:
o High levels of radioactive contaminants are widespread in central and northern
Wisconsin. Perhaps half or more of the reservation community water systems would
violate the currently contemplated EPA MCLs for radioactive constituents. Radon
volatilized from drinking water may contribute a small fraction (perhaps 5%) of the radon
in reservation homes.
o Many systems are plagued with high natural iron levels. Although iron causes no
health risk, it gives the water an unpleasant taste and smell and can stain laundry and
other materials. Complaints have been noted about drinking water taste and smell
problems on at least five of the Wisconsin reservations.
o In extremely rare situations, cadmium and fluoride occur naturally in sufficient
concentrations to exceed health based standards.
Anthropogenic contamination shows the following pattern:
o Nitrate levels averaged 13.5 mg/1 (relative to the MCL of 10 mg/1) in sampled wells on
the Stockbridge-Munsee reservation. Judging from the pattern of agriculture in the state
and the locations at which nitrate exceedances have been found, nitrate concentrations are
probably similarly high for the Oneida reservation and some of the Winnebago and St.
Croix communities. Exceedances of the nitrate standard are rare on the other reservations.
An overlay map is available showing the locations of monitored nitrate exceedances
relative to the locations of Wisconsin reservations.
o Pesticides have virtually never been detected in wells on reservations at levels
exceeding standards (see overlay). They are rarely detected at any level in wells on
reservations (see overlay).
o VOCs have virtually never been detected at levels exceeding standards in wells on
reservations, with the exception of several instances in the Winnebago and St. Croix areas
(see overlay). VOCs are generally a good marker for anthropogenic chemical
contamination from USTs, waste sites, or spills. This result is expected, as USTs,
hazardous wastes, industrial dumps and chemical spills are all relatively rare on
B-15
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reservation lands.
o Microbiological contaminants are monitored on a regular basis by the community water
systems on reservations. Reported violations of the MCLs are very rare.
o However, there are extensive reports of poorly functioning septic systems on
reservations. Septic systems are likely located near private wells, and perhaps public
wells are nearby also. Bacteriological contaminants from imperfect septic systems may
easily contaminate ground water and drinking water supplies, especially when: a) Ground-
water wells are typically shallow, and b) Numerous old improperly abandoned wells
provide conduits for migration of contaminated water from the surface to aquifers.
o The Wisconsin reservations are in areas where ground water is generally quite
vulnerable to contamination from surface activities. It is the extremely low rate of such
surface activities on reservations that is responsible for the usually good quality of ground
water on the reservations.
o We have no data on lead levels in drinking water in reservation homes. We would
guess that such levels are low, as much of the reservation housing is relatively new and
use of lead pipe and solder are rare in newer housing and water supplies on the
reservations are not particularly corrosive. However, harmful effects are being found from
lead at ever-diminishing levels, and lead in reservation drinking water is an issue worthy
of further research.
Health Risks
We judge the health risks from the different classes of contaminants in reservation
drinking water and ground water to be as follows:
o Pesticides: minimal.
o VOCs: minimal
o Metals other than lead: minimal
o Radionuclides: substantial. It is common nationally for about 5% of indoor radon in
homes to derive from drinking water/ground water. If this is the case on the reservations,
the average member of a Wisconsin tribe faces an excess lifetime cancer risk of 1 x 10~4
from radon in drinking water/ground water.
o Microbiologicals: perhaps moderate. Although the community water systems on the
reservations rarely report a violation of the bacteriological MCLs, we are nevertheless
concerned that the minimal treatment given to reservation water supplies combined with
the widespread reports of septic system failures could lead to frequent bacteriological
B-16
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contamination of reservation water supplies. We expect that a substantial portion of the
incidence of gastrointestinal problems among Wisconsin Indians may be due to
bacteriological contamination of water supplies. Limited data are available on the
frequency of gastrointestinal problems. The Menominee Tribal Clinic reports about 100
cases annually of gastrointestinal problems prompting clinic visits. Extrapolating to all
the Wisconsin tribes, about 600 total cases might be expected per year.
o Nitrates: minimal. Although water supplies exceeding the nitrate MCL are probably
common for four tribes, the specific health effect that the nitrate MCL protects against -
- methemoglobinemia ~ occurs extremely rarely. Less than 5 cases are reported annually
for the entire U.S.
o Lead: unknown. Risks from lead in drinking water at the tap may be low, but we have
no actual data on this issue. Lead does not occur in ground water on the reservations at
levels of concern. Sampling of tap water and blood for lead levels would be worth while.
Ecological Risk
Drinking water contamination poses no ecological risks. Contaminated ground water may
eventually discharge to surface water and cause ecological risks, but this effect is typically
defined to be covered in the "Nonpoint Sources" problem area.
Social and Economic Damages
High levels of iron in some private wells and community systems for several reservations
cause taste and odor problems. Some individuals may purchase bottled water at high cost to
avoid these problems. Several community wells are treated for high iron levels, at a cost of
perhaps a few thousand dollars per year. Several wells have been closed because of problems
with iron.
There is no indication that any other water supply expenses (e.g., for treatment or for new
wells) have been incurred by Wisconsin tribes because of contamination of ground water or
drinking water.
Adverse health effects from radon and microbiological contaminants will result in costs
for medical treatment and lost productivity by those who become ill.
B-17
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B-20
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Sources
Indian Health Service. Annual Surveys of Sanitation Facilities for each Reservation. 1991.
Kammerer, Phil A., Jr., U.S. Geological Survey. Groundwater Quality Atlas of Wisconsin.
Information Circular 39. 1981.
Mattson, Mark H., Indian Health Service. Letter listing nitrate test results. 31 May, 1991.
U.S. Geological Survey. Water Resources of the Lac du Flambeau Indian Reservation.
Wisconsin Department of Natural Resources. Map: Groundwater Contamination Susceptibility
in Wisconsin. 1987.
Wisconsin Department of Natural Resources. Nonpoint Source Assessment Report. August,
1988.
B-21
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Physical Degradation of Aquatic and Terrestrial Habitats
This paper provides information relating to two environmental problem areas:
6. Physical degradation of water and wetland habitats, and
22. Physical degradation of terrestrial ecosystems/habitats.
Aquatic Habitat Alteration
A variety of physical activities in addition to pollution ~ have altered the nature of the
water and wetland habitats on the reservations. Although the quality of the aquatic habitats on
the reservations is generally quite good in comparison with off-reservation areas, the reservation
aquatic ecosystems are nevertheless substantially altered relative to the way they existed many
decades ago. The pace of alteration appears to have slowed in recent years, with habitat-
disturbing activities occurring less frequently now than in the past.
The following are the activities thought to lead to significant alteration of the reservations'
aquatic ecosystems:
Residential and recreational development. For several decades, some of the Tribes
were actively seeking revenue by leasing or selling their most desirable waterfront lands to
outsiders. This has resulted in a substantial amount of low density waterfront development,
including resorts, cottages, cabins and docks. The numerous small developments involve fill and
alteration of wetlands and shoreline spawning areas, reduction of shoreline fish cover,
modification of water flow patterns, and increased siltation. Maps drawn from aerial photographs
are available from the Wisconsin Geological Survey that show the extent of this development.
We have reviewed the maps for the lakes and rivers within the reservations, and find that
shoreline mileage is distributed among different uses in the following rough proportions:
o Urban high intensity development. 0 - 5 % of shoreline in all reservations.
o Low to medium density non-agricultural development. 5 - 20 % of shoreline for
most reservations.
o Agricultural development. 2 - 20 % of shoreline for all reservations other than
Oneida, for which 80 % of the shoreline is agricultural.
o Undeveloped. Most commonly about 70 - 80 % of a reservation's shoreline is
undeveloped.
The maps are available for review by the work group, but cannot be reproduced here because of
B-22
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their very fine level of detail.
Water management projects. Several water bodies in reservations have been sharply
affected (and in some cases have been created) by off-reservation hydropower dams, flood control
projects and channelization. The Lac Court Oreilles Reservation, for example, lost much of its
historical wild rice acreage because of an off-site dam and flooding. Over 25 hydropower
projects affecting the reservations and ceded territories, some involving many separate dams, are
scheduled for relicensing by the FERC during the 1990's.
Introduced species. The sea lamprey was introduced to the Great Lakes by the maritime
industry many decades ago. Lampreys are responsible for much of the precipitous decline in the
lake trout population, and, despite extensive control efforts, still consume valuable fish at a rate
exceeding that for commercial, sport, and subsistence fishing combined. A more recent concern
in northern Wisconsin is purple loosestrife, an exotic perennial plant introduced to the southern
U.S. over a century ago. Once established in wetland habitat, loosestrife tends to dominate the
plant community and out-competes native species. Efforts to control the spread of loosestrife in
reservation wetlands are showing mixed results.
Fishing pressure. Fishing may be considered to be another important form of aquatic
habitat alteration. Fishing pressure in northern Wisconsin has clearly increased by historical
standards, although it seems relatively constant over the past decade or so. Annual statewide
sales of fishing licenses reached about 1 million in 1948, increasing gradually to 1.5 million in
1982 and then declined to about 1.4 million in 1989. Recreational, commercial and subsistence
fishing are controlled by the Wisconsin DNR and the GLIFWC so as not to deplete sustainable
fish populations.
Agriculture. For several reservations, notably Oneida, with Stockbridge-Munsee and St.
Croix to a much lesser degree, agricultural development has substantially affected aquatic
habitats. Draining of wetlands and siltation are major impacts that typically accompany
agriculture.
The impact of these sources of habitat alteration on aquatic ecosystems in the reservations
is mixed. Some water bodies have been completely changed by major water projects. Other
water bodies are virtually unaffected.
Populations of key inland fish (walleyes, muskie and northern pike) are approximately
stable over recent years across the studied lakes in the ceded territory. Each of these fish is still
found in some lakes throughout nearly all of its historical range, but many individual lakes have
lost their populations of these fish. 56 % of the lakes in which walleye can be found and 30 %
of the lakes in which muskie can be found have naturally self-sustaining populations of these
fish. Most of the remainder of the lakes have populations that are maintained at least partly by
stocking.
Habitat alteration appears to have had a major adverse impact on wild rice. Wild rice is
B-23
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quite sensitive to alterations in water levels, shoreline development and introduced species, and
can even be damaged by boat wakes. Wild rice acreage and density have declined sharply within
the memory of many Wisconsin Native Americans. Data collected more recently show a decline
of about 25 % during the five years from 1985 through 1989.
Terrestrial Habitat Alteration
For most reservations, the percentage of the overall land area that has been developed
appears to be less than the percentage of the shoreline that has been developed. Despite pockets
of residential and commercial development, most reservations retain their historical natural,
forested and wetland character. We reviewed a large map of Wisconsin showing gross land uses.
Only the Oneida reservation showed any significant land use other than natural forest and brush
land, wetland and surface water. Population densities across the reservations average only about
half of that throughout Wisconsin as a whole.
Activities occurring on the reservations that alter terrestrial ecosystems include:
o Agriculture. Most reservations have little agricultural development. Oneida,
however, has been largely transformed by agriculture, and agricultural
development is extensive also in the St. Croix areas.
o Residential and commercial development. All reservations have small but growing
settled areas, with cabins, recreational camps and roads, power lines and other
associated facilities adding to the impacts from development.
o Timber harvesting. Most of the reservations have active timbering programs,
including in some instances clearcutting. These operations are carefully managed
for sustained yield. Although substantial ecological changes occur on and
immediately around a logged tract, the portion of the reservations' total area that
is undergoing logging at any one time is quite small. For example, timber
harvesting on the Menominee Reservation has remained at a nearly constant
annual level since 1915. About 1.5% of the volume of sawtimber and pulpwood
is cut each year. This amount is set at less than natural growth and replanting, so
that there is a slow net increase in timber value over time, at somewhere between
zero and one percent per year.
The impact of these activities on the ecological character of most reservations is in some
ways not discemable. The composition of the forests remains largely unchanged. Populations
of those species whose abundance has been surveyed (bear, deer, grouse, rabbits) are constant or
increasing. Some ecological changes are apparent, however. Populations of eagles and furbearers
have declined substantially in recent memory. While some of this decline may be due to habitat
alteration, much of it is probably due to bioconcentration of pesticides and mercury in the food
of these species.
B-24
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Sources
Fact Sheet on Stockbridge-Munsee Community.
Great Lakes Indian Fish and Wildlife Commission, 1988 - 1990 Annual Reports.
Great Lakes Indian Fish and Wildlife Commission, Chippewa Treaty Harvest of Natural
Resources, Wisconsin, 1983 - 1990.
Menominee Tribal Enterprises. Forest Management Plan 1983-1997.
Menominee Tribe. Manuscript comparison of 1985 - 1990 game abundance surveys.
U.S. Department of the Interior, Bureau of Indian Affairs. Biennial Reservation Report: Fish,
Wildlife, and Reservation. Various reservations. 1990-1991.
U.S. Department of the Interior, Bureau of Indian Affairs. Casting Light Upon the Waters: a
Joint Fishery Assessment of the Wisconsin Ceded Territory. 1991.
Wisconsin Department of Natural Resources. Map: Generalized Land Cover Interpreted from
ERTS -1 Satellite Imagery.
Wisconsin Department of Natural Resources. Maps: Shoreland Use in Wisconsin.
B-25
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Unintended Releases of Toxic Substances
This paper provides background information on 4 problem areas involving unintentional
releases of toxic substances (whether products or wastes) to the environment:
7. Storage tanks
8. Hazardous waste sites, both managed (RCRA) and unmanaged (Superfund)
9. Solid waste sites, both industrial and municipal (including open dumps)
10. Accidental chemical releases to the environment
Available Data
Data of three sorts was acquired relating to these four problems:
o Measures of the extent to which storage tanks, hazardous waste sites, solid waste sites
and accidental releases occur on the Wisconsin reservations.
o Monitoring data around specific sites at which some of these activities have occurred
on the Wisconsin reservations.
o Statewide data on the locations at which elevated concentrations of VOCs (the most
common indicator of pollutant releases from these activities) have been detected in ground
water.
These data have been interpreted below to provide a very rough impression of the degree of risk
from each of these problems.
Overview
These four activities typically concentrate in areas of high population density and high
industrial activity. Neither of these qualities typify the Wisconsin reservations, and the numbers
of storage tanks, hazardous wastes sites, solid waste sites and accidental releases are low.
Coupling this low threat with the very low density of residences on reservations, there are
generally few people living near these activities on the reservations, and potentially exposed
populations are very low.
If a release of toxic contaminants occurs on a reservation, however, it is generally likely
to affect ground water. According to Wisconsin's DRASTIC map, most of the reservations are
characterized by a rather high vulnerability of ground water to any contamination occurring on
the surface.
B-26
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The Wisconsin DNR has compiled data throughout the state on occurrence of VOCs in
ground water, and has mapped the areas where elevated concentrations of VOCs have been
detected. Virtually none of the detections of elevated VOC concentrations have been on
reservations (see overlay at end of drinking water and groundwater contamination background
paper).
There are no documented incidents we are aware of in which releases from one of these
four source types has affected a drinking water supply on a reservation.
Storage Tanks
An inventory of storage tanks on Wisconsin reservations totals 205 tanks across the 11
reservations (see attachment). It is not clear whether the inventory counts only active tanks or
abandoned ones also. We assume that this is the number of active tanks. This represents a
density of about 1 tank per 3,000 acres of reservation land. This is much lower than the density
of tanks throughout all of Region 5 of 1 tank per about 600 acres of land.
At least one UST on a reservation has been found to be leaking (a gasoline tank at a
convenience store on the Oneida reservation). The release has been cleaned up at a cost of
several tens of thousands of dollars, and no apparent health or ecological damage has occurred.
Region 5 estimates that between 10 and 30 percent of all USTs are probably leaking. We
assume that this is likely to be the case for the reservations also. However, we believe that
health and ecological risks from USTs on reservations are likely to be very low for two reasons:
o The very low density of USTs on reservations.
o The likelihood of quickly noticing a release whenever it reaches the point of being able
to cause risks. Gasoline is quickly apparent when it either reaches a water supply
(distinctive taste and odor) or reaches surface water (distinctive sheen or slick). Social
and economic losses in the form of cleanup costs and the cost of lost product may be
modest for USTs.
Hazardous Waste Sites
There appears to be very little hazardous waste on the Wisconsin reservations, probably
as a result of the minimal history of industrial activity on the reservations. There are two known
abandoned hazardous waste sites potentially affecting the reservations:
o The Fort Howard Sludge Lagoon site on and adjoining the Oneida reservation. A
Remedial Investigation under Superfund is due to be completed in 1993. Data has shown
the presence of contaminants within the waste, ground water and air. Health risks will
be determined in the Remedial Investigation Report.
B-27
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o An abandoned industrial sludge lagoon on the Bad River Reservation. It is being
investigated.
Several other sites have been evaluated for Superfund listing, but have been found not to pose
a sufficient threat.
Very little hazardous waste is now generated on the reservations. None is known to be
disposed or stored for long periods on the reservations. Several small industrial plants (e.g.,
Simpson Electric on the Lac du Flambeau reservation) are small quantity generators who ship
their hazardous wastes off the reservations for disposal. Medical waste is generated at several
clinics and shipped off-site.
Hazardous waste, at both managed and unmanaged sites, appear to pose minimal risks to
reservation residents and ecosystems.
Solid Waste Sites
The Wisconsin tribes have a history of indiscriminate open dumping of household wastes.
Dump sites are scattered throughout the reservations. Most are now formally inactive, but have
not yet been cleaned up. At present two reservations (Menominee, Lac Courte Oreilles) continue
their open dumping, while the other 9 reservations have the bulk of their household refuse hauled
off the reservations to county or other landfills. There do not appear now to be any
environmentally satisfactory land disposal or incineration facilities on any of the reservations.
Pieces of information about solid waste disposal on the reservations that we find relevant to a
judgment about risk include:
o Many of the existing open dumps are in very poor condition, with widely scattered
trash, large rodent populations and inadequate or no provisions for periodic covering of
the dumped material.
o Many of the dump sites are (perhaps intentionally?) far from any residence or water
well.
o Three reservations cited open dumps as a possible source of surface water quality
problems in the CERT study.
o The material that has been placed in the dumps is almost exclusively household trash,
of very low toxicity. There are almost no industrial solid waste dumps.
o Ground-water monitoring has evidently been conducted around one of the Menominee
dump sites. It apparently shows some ground-water contamination, but we were not able
to obtain this data.
It is unclear what this information adds up to in terms of an assessment of the risks from
B-28
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solid waste sites. We estimate that the health risks from these sites is very low, and that
ecological risks and social and economic damages may be slightly higher.
There appear to be no industrial solid waste sites on the reservations.
Accidental Releases
There are no industrial or other facilities on Wisconsin reservations that have the potential
of releasing significant amounts of toxic substances. The TRI data base shows very few such
facilities in the immediate vicinity of the reservations.
We obtained data for the Menominee reservation listing hazardous material spills over the
past ten years (attached). Most of the incidents involved spills of petroleum products. None
appeared to cause any significant health or ecological damages. Some cleanup costs were
incurred. Assuming that the other reservations have a history of release incidents similar to that
for Menominee, risks from accidental releases are minimal.
B-29
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Wisconsin reservations
site
Bad River
Forest County Executive Cncl
Lac Courte Oreilles
Lac Du Flambeau
Menominee
Oneida
Red Cliff
Stockbridge-Munsee
Mole Lake
St. Croix
Winnebago
Total
Number of tanks confirmed per Bob Fey data
6
0
52
59
36
41
2
6
1
2
205
B-30
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HAZARDOUS MATERIALS SPILLS
1981 THROUGH PRESENT
MENOMINEE INDIAN RESERVATION
08/12/81 Gasoline tanker overturned on Highway 47 just west of
Zoar. Lost approximately 5000 gallons of gasoline.
Contaminated soil removed, monitoring wells installed,
site determined to be cleaned.
09/02/83 Fuel oil tanker overturned on Highway 47 just east of the
Langlade line. Lost 5000 - 7000 gallons of *2 fuel oil.
Contaminated soil removed and disposed of. Site
determined to be clean.
11/12/83 200 gallon fuel oil tank knocked over and spilled
material on ground. Material absorbed and disposed of
by WisDNR personnel.
11/06/84
12/13/84
03/31/86
Foundry sand dumped illegally in the Keshena dump.
Material determined to be non-hazardous and allowed to
remain on site. However, such material must be disposed
in a licensed, properly constructed sanitary landfill.
Small fuel oil spill on Highway 55 associated with a
truck crash. Lost 5-10 gallons of fuel. As per DNR
recommendation, because of remote
amount of spill, no cleanup
location,
required.
and sma11
Found a 55 gallon drum of boiler treatment at the Keshena
dump. Shipping labels etc on drum. Contacted owner and
drum was removed intact.
03/10/87 Gasoline tanker ran off Highway 47 just west of Zoar.
Ruptured and burned. Contaminated soil removed and
disposed of. Monitoring wells installed. Continual
installation of additional monitoring wells and sampling
taking place. Site has not yet been determined clean.
09/15/87 Two 55 gallon drums of windshield deicer found at Keshena
dump. Drums removed intact and disposed of properly.
12/15/88 Fuel oil tank leak at a private residence on fee land.
May have occurred over 3 year period. Because of private
land, homeowner is responsible for clean-up. As of this
time no work has been done. Advised homeowner to request
assistance from Tribe.
06/21/89 Three 55 gallon drums found in area of Jackson Creek.
Investigation revealed all barrels to have been empty and
rusted through before they were dumped. No
contamination.
B-31
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12/22/89 Small fuel oil spill in Neopit from a broken hose on a
delivery truck. Confined to the surface on asphalt road.
Product picked up with absorbent material. No ground
contamination.
08/26/90 Small diesel oil spill occurred when a truck leaked fuel
along a 11.3 mile stretch of Highway 47. Determination
made only effect is in the area where the truck finally
stopped. Contaminated material excavated and disposed
in Shawano Landfill.
02/10/91 Truck crash on Highway 47 at Kakkak Hill lost unknown
amount of diesel fuel from saddle tanks. Estimate from
owner of 50-60 gallons. Contaminated soil removed to
Shawano Landfill. Shallow ground water appears
contaminated. Further work will be done.
07/25/91 MTE Mill in Neopit lost 2000 gallons of wood treatment
into the ground. Working on mitigation.
07/25/91 Truck crash on Highway 55 caused a spill of fuel oil from
the saddle tanks. Unknown amount of fuel lost, estimate
somewhere between 80 and 200 gallons. Contaminated soil
removed to Shawano Landfill. Samples collected of soil.
Waiting for final interpretations of results.
Compiled by: Gary Schuettpelz, R.S.
DIRECTOR, ENVIRONMENTAL HEALTH
B-32
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Sources
Correspondence between the U.S. Environmental Protection Agency, Region 5, and the Oneida
Tribe regarding leaking underground storage tanks (USTs).
U.S. Department of Health and Human Services, Indian Health Service. Reports on Solid Waste
Disposal System Surveys for each Reservation. 1991.
Jackson, D., Indian Health Service. FY '91 Solid Waste Status Report. 1992.
Secretary of Health and Human Services. Annual Report: Sanitation Facilities Deficiencies for
Indian Homes and Communities. March, 1990; February, 1991.
U.S. Environmental Protection Agency, Region 5. Memorandum from David A. Ullrich,
Wisconsin Tribal Comparative Risk Report (provides information regarding wastes on
reservations). 30 July, 1991.
U.S. Environmental Protection Agency, Office of Waste Programs Enforcement. C.E.I.
Inspections on Indian Lands Final Report. 25 September, 1989.
B-33
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Pesticides
Some persistent, older, now-banned pesticides contribute moderately to the significant
risks involved in Indian consumption of harvested fish and game. Currently used pesticides
appear unlikely to cause significant health or ecological risks on the reservations. Locations
where pesticides have been detected in ground water throughout the state only rarely include sites
on reservations (see map overlays in Drinking Water and Groundwater Contamination background
paper in addition to those following this paper). Most of the counties in which reservations are
located are among the counties across the state where pesticides are least frequently used.
However, farming activity is common in the vicinity of the Oneida, Stockbridge-Munsee,
Winnebago and St. Croix reservations, and the intensity of pesticide usage in these areas is more
like the typical level in the state. The attached chart shows pesticide usage in reservation
counties in comparison to other counties in the state within the Great Lakes Basin.
Sources
Gianessi, Leonard P. "Use of Selected Pesticides on Agricultural Crop Production in the Great
Lakes Region." March, 1988.
Wisconsin Department of Natural Resources. Nonpoint Source Assessment Report. August,
1988.
B-34
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PESTICIDE USE IN WISCONSIN'S
GREAT LAKES BASIN
County
* Ashland
*BayfieH
*Brown
Calumet
Door
Douglas
Florence
Fond du Lac
* Forest
Green Lake
*Iron
Kenosha
Kewaunee
Langlade
Manitowoc
Marinette
Marquette
*Menominee
Milwaukee
Oconto
*Outagamie
Ozaukee
Racine
*Shawano
Sheboygan
Washington
Waupaca
Waushara
Winnebago
Total Pesticide
Use (Ibs. a.i.)
6,452
7,381
205,180
149,841
80,613
3,823
6,430
446,316
1,264
205,989
1,728
154,726
125,200
94,138
226,813
107,487
136,511
0
14,372
199,581
350,894
93,331
213,560
221,393
213,048
159,698
241,004
220,166
219,406
% Total Usage
0.16%
0.18%
5.00%
3.65%
1.96%
0.09%
0.16%
10.87%
0.03%
5.02%
0.04%
3.77%
3.05%
2.29%
5.52%
2.62%
3.32%
0.00%
0.35%
4.86%
8.55%
2.27%
5.20%
5.39%
5.19%
3.89%
5.87%
5.36%
5.34%
denotes counties with reservations
Of the 7 lowest pesticide-using counties, 5 are counties with reservations.
In the remaining three counties with reservations: Brown, Outagamie, and
Shawano, pesticide use is in line with use in other counties in the Basin.
B-35
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B-36
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B-37
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Food Contamination
This paper provides information on the risks to Wisconsin Indians from consumption of
harvested food. No data have been gathered relating to risks from consumption of non-harvested
food ~ that which is purchased from sources in general commerce. Accordingly, the risks
estimated in this paper cover those from only a part of the Tribes' total diet.
DATA SOURCES
Dietary profile
The dietary profile used in the analysis is based on a paper by Don Wedll, the Mille Lacs
Commissioner of Natural Resources, "Mille Lacs Band of Chippewa Indians: Basic Existence
Requirements for Harvesting of Natural Resources," 1984, Revised 1986. In the absence of any
other information, the dietary profile for the Minnesota Mille Lacs Native Americans is assumed
to be the same as the Wisconsin tribes for the purpose of this analysis. Data on the average
individual daily intake and the percent of food harvested for consumption are used to develop the
average daily intake of harvested foods (see table).
For comparison with some of these data, EPA's assumed daily fish consumption by the
average American is 6.5 grams. Members of the Wisconsin Tribes are assumed to consume
nearly six times as much fish, 90% from local sources.
Contaminant concentrations in harvested foods
No contaminant data was available for fruits (e.g. berries), vegetables, grains (wild rice),
milk products, or sweets (maple sugar).
Wild Game and Waterfowl
Contaminant data for wild game and waterfowl is from "Environmental Contaminant
Monitoring in Wisconsin Wild Game, 1987," from the Bureau of Wildlife Management,
Wisconsin Department of Natural Resources (DNR), August, 1988. The 120 samples in this data
collection were taken from 1984 through 1987. More recent data are not available.
Waterfowl data for this analysis includes all species of waterfowl included in the DNR
data, although most of the samples are for mallard ducks (68%). This analysis is based largely
on samples from countries in the ceded territories. Data from Brown and Outagamie counties
have been added to the sample to represent areas outside the ceded territories where the Oneida
tribe may hunt. Data included in the analysis are based on muscle-only or muscle and skin
samples; samples in the DNR data based on skin-only have been excluded. Duplicate samples
have been excluded from the analysis as well.
B-38
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The limited nature of the wild game data available from the DNR (13 small game, 14
large game) led to the use of all samples, regardless of the county of origin or type of sample.
Samples included muscle-only, fat-only (for bears), muscle and fat combined, kidney, and liver
(these organs were sampled for mercury, chromium, selenium, and cadmium only). Only five
of the wild game samples are from counties in the ceded territories.
Fish
Concentrations of contaminants in fish tissue are from the database of the Bureau of
Water Resources Management, DNR. The data used in this analysis includes the Northern and
North Central Districts and includes 287 samples for 32 different fish. The data was collected
from 1985 through 1990. The counties included in this data represent the ceded territories. All
samples are from filets. Although a wide variety of fish species are represented among the
samples, walleye and northerns are the most common. Samples where mercury was the only
contaminant that was tested for have been excluded to reduce the data set to a manageable size.
A second source of mercury concentration data is the "GLIFWC Mercury Analysis 1991,"
from the Great Lakes Indian Fish and Wildlife Commission's 1991 Mercury Project. This
analysis includes 55 samples from 23 lakes in the ceded territories, using walleye fish in all but
three cases. Samples are based on skin-off filets. We did not use this data set for this analysis,
as we thought the DNR data set probably more accurately represented the profile of the fish
species actually consumed by the Wisconsin Native Americans.
For comparison purposes, the GLIFWC analysis would result in an average concentration
of mercury (538 ug/kg) which is about 50% higher than is calculated using the DNR data (364
ug/kg).
TREATMENT OF NON-DETECT RESULTS
The analysis is based on two different assumed scenarios for the sample results that were
below detection limits for a contaminant.
1 - Contaminant concentrations below detection limits are assumed to be zero.
2 - Contaminant concentrations below detection limits are assumed to be half of the
detection limit.
Average concentrations, cancer risks, and non-cancer health indices are calculated for each case.
ESTIMATE OF CONTAMINANT DOSE
The daily dose of each contaminant received by a tribe member is assumed to be the
average concentration in the meat, poultry, or fish multiplied by the average daily intake of the
harvested food. Contaminant concentrations are averaged across all individual samples within
B-39
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each of the four food groups (large game, small game, fish, and poultry) in order to determine
the average contaminant concentration in each. The average amount of each food group ingested
is based on the Wedll study.
CANCER AND NON-CANCER RISK CALCULATIONS
Cancer Risk and Non-cancer Health Index are calculated for each contaminant-food group
pair, where concentration data is available, using Risk Assistant software. The calculations
assume ingestion for 350 days/year for 30 years, for a 70 kg adult with a 70 year lifespan. The
software uses a standard 0.054 kg/day for the daily food intake. This amount was scaled
appropriately for the average daily intake amounts taken from the Wedll study. A standard Dose
x Potency = Risk function is employed in the software along with access to contaminant specific
risk information from IRIS (Integrated Risk Information System) and HEAST (Health Effects
Assessment Summary Tables). Risks for ingested carcinogens are a function of the oral slope
factor and the dose. The Health Index for Non-cancer Toxic Effects compares the predicted
average daily dose to the reference dose at which no toxic effects are expected.
HEALTH RISK RESULTS
The results of these calculations are shown in separate tables for the four food groups in
total and for each food group separately. The estimated health risks appear significant:
o Total excess lifetime cancer risk for the average individual is about 4 x 10"3.
PCBs are responsible for nearly all of this risk, but several pesticides also
contribute risks exceeding 10"6. About half of the PCBs are estimated to come
from small game, about 1/4 from large game, about 15% from fish, and about 8%
from poultry.
o Hazard indices for non-cancer effects are two orders of magnitude greater than 1
for PCBs and they exceed 1 for mercury. Three fourths of the mercury is
estimated to derive from small game, 22% from fish, and 2% from poultry. No
data on mercury in large game was available.
These estimates are quite uncertain for several reasons:
o The small and large game food groups contribute a large fraction of the risk, but
very few game animals have been sampled for contaminants. The small game
data are particularly unreliable, as we included data on several otters in this
category. Otters are at the very top of a lengthy food chain and they can be
expected to bioaccumulate contaminants even more than large game fish.
o The data sets were too limited to allow for a rigorous match between the locations
where samples were taken and the locations of Indian harvesting. Similarly, it was
not possible to match rigorously the parts of the animal sampled and the parts
B-40
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actually eaten.
Nevertheless, the results for these four food groups clearly suggest high health risks from
harvested food for Native Americans in Wisconsin.
SEVERAL ADDITIONAL POINTS
o These calculations represent the average diet. Individuals who are particularly
heavy consumers of harvested foods will experience even higher risks.
o With no contaminant data available for harvested fruits, vegetables, grains, or
sweets, we were unable to calculate any risks for these components of the diet.
Some plants are known to concentrate toxic elements from their environment. If
wild rice, berries, maple sugar, or other staples of the Native American diet do so
also, total dietary risks for the Wisconsin tribes could be much higher than those
calculated thus far.
Further information about potential health effects comes from an ongoing University of
Wisconsin/Wisconsin Department of Health study of fish consumption and blood mercury levels
in Wisconsin Chippewa Indians. The study has found that:
o "Mercury levels in Chippewa Indians are directly related to how many walleyes
they have eaten recently. The higher the number of walleye meals a person has
eaten in the past two months, the higher the person's blood mercury is.
o The current levels of blood mercury in the Chippewa surveyed (generally 0-10
ppb) are below the levels with known health effects (symptoms of mercury
poisoning may begin at 80 ppb).
o While levels are currently below the levels with known health effects, blood
mercury levels could go up if:
- People ate more fish (especially walleye)
- People ate fish that were more contaminated (taken from more
contaminated lakes)
If people did both, eating more fish and eating fish from more contaminated lakes,
blood mercury levels could go up substantially."
Ongoing research is beginning to suggest some direct links between consumption of Great
Lakes fish with high PCB levels and adverse health impacts. A study comparing children of
women who were heavy fish consumers before pregnancy with children of non-consumers found
short-term memory and attention deficiencies at birth, at 7 months, and at 4 years in the PCB-
exposed children.
B-41
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Daily Food Consumption Breakdown for Wisconsin Indians
Food Group
Fruits/Vegetables
Grain
Meat
Large Game
Small Game
Fish
Poultry
Milk & Cheese
Sweets
Average
Daily Intake
(grams)
225.00
113.40
67.38
20.13
35.00
17.50
84.50
84.50
Percent from
Harvest
50%
75%
90%
90%
90%
90%
1%
70%
Average Daily Intake
From Harvest
(grams)
112.50
85.05
60.64
18.11
31.50
15.75
0.85
59.15
Examples of items in each food group:
Fruits/Vegetables:
Grain:
Large Game:
Small Game:
Poultry:
Fish:
Sweets:
Seasonal vegetables, bracken fern, asparagus
Chokecherries, June berries, blue elderberry, plums, blackberries,
raspberries, blueberries, cranberries, strawberries
Wild rice, yellow pond lilly, arrowhead
Deer (may be replaced by bear, moose)
Rabbits, porcupines, muskrats
Ducks, geese, coots, grouse, cranes
Walleye, northerns, perch, eelpout, suckers, sturgeon, trout
Maple sugar
Source:
Wedll, Don, "Mille Lacs Band ofChippewa Indians: Basic Existence Requirements for Harvesting of
Natural Resources," 1984, Revised 1986.
B-42
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Species Representing Food Groups
Food Group
Type. Species with Contaminant Data
Fruits and Vegetables
Grains
Milk and Cheese
Sweets (Maple sugar)
Data on the contaminants in the harvested
portion of these items was not available.
Meat
Large Game
Small Game
Poultry (Waterfowl)
Fish
White-tailed Deer
Black Bear
Cottontail Rabbit
Muskrat
Otter
Raccoon
Snowshoe Hare
Blue-Winged Teal
Canada Goose
Common Merganser
Green-Winged Teal
Lesser Scaup
Mallard
Northern Pintail
Northern Shoveler
Pied-Billed Grebe
Ringed-Neck Duck
Wood Duck
Big-Mouth Buffalo
Balck Crappie
Bloater Chub
Bluegill
Brook Trout
Brown Trout
Burbot
Carp
Channel Catfish
Chinook Salmon
Coho Salmon
Falthead Catfish
Lake Herring
Lake Sturgeon
Lake Trout
Lake Whitefish
Largemouth Bass
Musky
Northern Pike
Northern Redhorse
Rainbow Smelt
Rainbow Trout
Rock Bass
Sheepshead/Drum
Siscowett Lake Trout
Smallmouth Bass
Splake
Walleye
White Bass
White Sucker
Yellow Bullhead
Yellow Perch
B-43
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Estimated Cancer and Non-Cancer Human Health Risks in Wisconsin Indian Diet
Contaminants
Mercury
PCS
Chlordane
Dieldrin
ODD
DDE
DDT
Toxaphene
Arsenic
Cadmium
Chromium
Copper
Lead
Aldrin
Endrin
Pentachlorophenol
BHC
Hexachlorobenzene
Methoxychlor
2,4,5-Trichlorophenol
2,4,6 - Trichlorophenol
Selenium
Cancer Risk Totals
ALL FOOD GROUPS
Non- Detects = 0
Cancer
Risk
O.OOE+00
3.56E-03
1.75E-06
7.13E-05
3.50E-07
2.68E-05
3.50E-06
1.17E-04
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
2.33E-07
O.OOE+00
2.33E-07
O.OOE+00
O.OOE+00
5.83E-07
O.OOE+00
3.78E-03
Non -Cancer
Health Index
2.26E+00
1.56E+02
5.83E-02
2.75E-01
O.OOE+00
O.OOE+00
4.67E-02
O.OOE+00
2.33E-02
3.37E+00
O.OOE+00
1.17E-02
O.OOE+00
O.OOE+00
O.OOE+00
1.75E-04
O.OOE+00
4.08E-04
O.OOE+00
O.OOE+00
O.OOE+00
9.19E-02
Non -Detects = Half Det. Limit
Cancer
Risk
O.OOE+00
3.67E-03
2.04E-05
2.11E-04
4.38E-06
2.97E-05
9.33E-06
2.33E-04
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
5.83E-05
O.OOE+00
4.08E-07
4.67E-06
6.13E-06
O.OOE+00
O.OOE+00
1.17E-07
O.OOE+00
4.25E-03
Non -Cancer
Health Index
2.26E+00
1.70E+02
6.71E-01
5.00E-01
O.OOE+00
O.OOE+00
1.31E-01
O.OOE+00
1.17E-01
3.46E+00
3.09E-02
1.17E-03
O.OOE+00
3.50E-01
1.75E-02
2.92E-04
2.63E-02
1.02E-02
8.17E-03
2.33E-04
O.OOE+00
1.31E-01
B-44
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Estimated Cancer and Non-Cancer Human Health Risks in Wisconsin Indian Diet
Contaminants
Mercury
PCB
Chlordane
Dieldrin
DDD
DOE
DDT
Toxaphene
Arsenic
Cadmium
Chromium
Copper
Lead
Aldrin
Endrin
Pentachlorophenol
BHC
Hexachlorobenzene
Methoxychlor
2,4,5 -Trichlorophenol
2,4,6-Trichlorophenol
Selenium
Cancer Risk Totals
FOOD GROUP: FISH
Consume .0315 kg/day
Non- Detects = 0
Avg. Cone.
ug/kg
363.969
433.745
8.125
25.521
4.643
149.762
47.738
689.655
55.556
0.000
0.000
755.000
0.000
0.000
0.000
1 1 .282
0.000
0.769
0.000
0.000
0.000
Cancer
Risk
O.OOE+00
5.83E-04
1.75E-06
5.83E-05
2.33E-07
1.17E-05
2.92E-06
1.17E-04
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
2.33E-07
O.OOE+00
2.33E-07
O.OOE+00
O.OOE+00
5.83E-07
7.76E-04
Non -Cancer
Health Index
5.25E-01
2.92E+01
5.83E-02
2.33E-01
O.OOE+00
O.OOE+00
4.08E-02
O.OOE+00
2.33E-02
O.OOE+00
O.OOE+00
1.17E-02
O.OOE+00
O.OOE+00
O.OOE+00
1.75E-04
O.OOE+00
4.08E-04
O.OOE+00
O.OOE+00
O.OOE+00
5.83E-02
Non -Detects » Half Det. Umrt
Avg. Cone.
ug/kg
364.124
487.530
31.042
31.667
28.452
164.940
67.560
1094.828
277.778
82.857
207.143
83.556
2083.333
25.000
1 1 .071
18.846
7.308
5.385
25.000
50.000
50.000
Cancer
Risk
O.OOE+00
5.83E-04
5.83E-06
1.17E-04
1.17E-06
1.17E-05
4.08E-06
2.33E-04
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
5.83E-05
O.OOE+00
4.08E-07
1.75E-06
1.75E-06
O.OOE+00
O.OOE+00
1.17E-07
1.02E-03
Non -Cancer
Health Index
5.25E-01
2.92E+01
2.33E-01
2.92E-01
O.OOE+00
O.OOE+00
5.83E-02
O.OOE+00
1.17E-01
5.83E-02
1.75E-02
1.17E-03
O.OOE+00
3.50E-01
1.75E-02
2.92E-04
1.17E-02
2.92E-03
2.33E-03
2.33E-04
O.OOE+00
5.83E-02
SOURCE: Wisconsin Department of Natural Resources
NOTE: Blank cells indicate contaminant data was not available.
B-45
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Estimated Cancer and Non-Cancer Human Health Risks in Wisconsin Indian Diet
Contaminants
Mercury
PCB
Chlordane
Oieldrin
DDO
DDE
DDT
Toxaphene
Arsenic
Cadmium
Chromium
Copper
Lead
Aldrin
Endrin
Pentachlorophenol
BHC
Hexachlorobenzene
Methoxychlor
2,4,5 -Trichlorophenol
2,4,6-Trichlorophenol
Selenium
Cancer Risk Totals
FOOD GROUP: SMALL GAME
Consume 0.01811 kg/day
N on -Detects - 0
Avg. Cone.
uq/kg
2095.000
1929.000
0.000
6.000
0.000
10.000
0.000
0.000
0.000
0.000
0.000
0.000
600.000
Cancer
Risk
O.OOE+00
1.68E-03
O.OOE+00
1.01E-05
O.OOE+00
3.35E-07
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
1.69E-03
Non-Cancer
Health Index
1.68E+00
6.71E+01
O.OOE+00
3.02E-02
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
3.35E-02
Non- Detects = Half Det. Limit
Avg. Cone.
ug/ka
2100.000
1979.000
25.000
13.000
25.000
30.000
25.000
100.000
250.000
5.000
5.000
25.000
662.500
Cancer
Risk
O.OOE+00
1.68E-03
3.35E-06
2.35E-05
6.71 E-07
1.01E-06
1.01E-06
O.OOE+00
O.OOE+00
6.71E-07
1.01E-06
O.OOE+00
O.OOE+00
1.71E-03
Non -Cancer
Health Index
1.68E+00
6.71E+01
1.01E-01
6.71E-02
O.OOE+00
O.OOE+00
1.34E-02
3.35E-02
1.34E-02
3.35E-03
1.68E-03
1.34E-03
6.71E-02
SOURCE: Wisconsin Department of Natural Resources
NOTE: Blank cells indicate contaminant data was not available.
B-46
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Estimated Cancer and Non-Cancer Human Health Risks in Wisconsin Indian Diet
Contaminants
Mercury
PCB
Chlordane
Dieldrin
ODD
DDE
DDT
Toxaphene
Arsenic
Cadmium
Chromium
Copper
Lead
Aldrin
Endrin
Pentachlorophenol
BHC
Hexachlorobenzene
Methoxychlor
2,4,5 - Trichlorophenol
2,4,6 - Trichlorophenol
Selenium
Cancer Risk Totals
FOOD GROUP: LARGE GAME
Consume: 0.06064 kg/day
N on Detects = 0
Avg. Cone.
ug/kg
375.000
0.000
0.000
0.000
77.500
0.000
1733.330
0.000
0.000
0.000
Cancer
Risk
1.01E-03
O.OOE+00
O.OOE+00
O.OOE+00
8.98E-06
O.OOE-I-OO
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
1.02E-03
Non- Cancer
Health Index
4.49E+01
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
3.37E+00
O.OOE+00
O.OOE+00
O.OOE+00
Non -Detects = Half Det. Limit
Avg. Cone.
ug/kg
450.000
25.000
10.000
25.000
96.250
25.000
1766.670
5.000
5.000
25.000
Cancer
Risk
1.12E-03
1.12E-05
5.61E-05
2.25E-06
1.12E-05
3.37E-06
O.OOE+00
2.25E-06
3.37E-06
O.OOE+00
1.21E-03
Non Cancer
Health Index
5.61E+01
3.37E-01
1.12E-01
O.OOE+00
O.OOE+00
4.49E-02
3.37E+00
1.12E-02
5.61E-03
4.49E-03
SOURCE: Wisconsin Department of Natural Resources
NOTE: Blank cells indicate contaminant data was not available.
B-47
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Estimated Cancer and Non-Cancer Human Health Risks in Wisconsin Indian Diet
Contaminants
Mercury
PCS
Chlordane
Dieldrin
ODD
DDE
DDT
Toxaphene
Arsenic
Cadmium
Chromium
Copper
Lead
Aldrin
Endrin
Pentachlorophenol
BHC
Hexachlorobenzene
Methoxychlor
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Selenium
Cancer Risk Totals
FOOD GROUP: POULTRY
Consume .01575 kg/day
Non -Detects = 0
Avg. Cone.
ug/kg
69.540
427.450
2.790
4.750
199.180
16.230
20.690
Cancer
Risk
O.OOE+00
2.92E-04
2.92E-06
1.17E-07
5.83E-06
5.83E-07
O.OOE+00
3.01 E- 04
Non -Cancer
Health Index
5.83E-02
1.46E+01
1.17E-02
O.OOE+00
O.OOE+00
5.83E-03
O.OOE+00
Non -Detects = Half Det. Limit
Avg. Cone.
ug/kg
77.850
549.470
9.430
19.510
215.660
30.980
86.900
Cancer
Risk
O.OOE+00
2.92E-04
1.46E-05
2.92E-07
5.83E-06
8.75E-07
O.OOE+00
3.13E-04
Non -Cancer
Health Index
5.83E-02
1.75E+01
2.92E-02
O.OOE+00
O.OOE+00
1.46E-02
5.83E-03
SOURCE: Wisconsin Department of Natural Resources
NOTE: Blank cells indicate contaminant data was not available.
B-48
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Criteria Air Pollutants
This paper provides information relating to the following environmental problem areas:
13. Sulfur oxides and nitrogen oxides (including acid deposition)
14. Ozone and carbon monoxide
15. Airborne lead
16. Particulate matter
Overview
We attempted to obtain ambient air quality monitoring data for criteria pollutants for the
reservations. Ambient monitoring data for the period 1985 - 1990 was obtained from EPA's
Aerometric Information Retrieval System (AIRS) for monitors within reservations and within
counties in which reservations are located. The Wisconsin 1989 Air Quality Data Report was
also consulted for monitoring data from other areas of the state.
Very few air monitoring stations are located on reservations themselves, and these
monitors cover only paniculate matter. Several other monitoring stations, providing coverage for
a broader set of pollutants, are in locations near reservations that we judge likely to be similar
to the reservations. For several criteria pollutants, though, the only available data for Wisconsin
was for sites expected to have much more severe ambient air problems than the reservations (e.g.,
major cities, sites near major industrial point sources). In the absence of other data, we used the
data from such sites to provide an upper bound ambient concentrations on the reservations are
almost certainly well below those found at these "worst case" sites. Even at the worst case sites,
ambient concentrations of criteria pollutants rarely approached the national ambient air quality
standards, and risks appear minimal.
The following table shows the ambient concentrations of criteria air pollutants that we
used for the study. In some cases we obtained ambient data that are representative of the
reservations. In other cases (which are noted in the table), data were available only for "worst
case" sites in the state that we believe represent far worse concentrations than exist on the
reservations. The table compares the observed concentrations with the NAAQS or other health-
based threshold for each pollutant.
B-49
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Pollutant
Particulates (PM10)
Carbon monoxide (CO)
Sulfur dioxide (SO2)
Nitrogen dioxide (NO2)
Ozone (O3)
Lead (Pb)
Sulfates
NAAQS
SO ug/m3, annual arith.
mean
9 ppm, 8 hr avg
35 ppm, 1 hr avg
0.140 ppm, 24 hr max
0.053 ppm, annual arith.
mean
0.12 ppm, hrly avg; est.
< 1 exceedence
1.5 ug/m3, qrtly arith.
mean
Health Risk thresholds:
7.0 ug/m3, hospital
admissions
10.0 ug/m3, deaths,
respiratory symptoms
Observed Levels
5-20 ug/m3
3 ppm
6 ppm
0.111 ppm
0.014 ppm
0.020 ppm
0 exceedences,
Hourly avg has
exceeded .1 ppm
twice since 1989
in 1989, < 0.1 ug/m3
< 3 ug/m3
< 5 ug/m3
Location
Menominee Res.,
Stockbridge Res.,
Oneida Res.,
Boulder Jet., Vilas
Co.
Milwaukee (worst
case in state)
Rhinelander (nearly
worst case in state)
Tomahawk (typical
rural)
Milwaukee (worst
case in state)
Brown Co.
Oneida Co.
Outagamie Co.
Florence Co.,
(typical of rural WI)
Milwaukee (worst
case in state)
Boulder Jet. (Vilas
Co.)
Green Bay,
Milwaukee (worst
cases in state)
B-50
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Acid Deposition
While acid deposition is not directly responsible for major human health problems, it may
pose significant ecological risks and perhaps social and economic damages also. Ecological
effects may indirectly lead to human health risks in the case of increased mercury uptake by food
fish in acidic waters.
The Great Lakes Basin Risk Characterization Study states that evidence of acid deposition
is apparent in Wisconsin's lakes, but streams do not exhibit any noticeable effects. Although acid
deposition continues to be a problem, the state has observed decreases in acidity of deposition
in recent years accompanying decreasing SO2 emissions. Sulfates, as opposed to nitrates, are
predominantly responsible for acidity in Wisconsin's lakes.
There are a number of acid deposition monitoring sites situated across the state, and those
in the north are near enough to reservations to consider their characteristic acid deposition similar
to that on the reservations. Acid deposition sites in 1989 included those in: Cornucopia (near
Red Cliff), Round Lake (near Lac Courte Oreilles), Trout Lake (near Lac du Flambeau), People
River (near Mole Lake, Potawatomi), Suring (near Menominee), and Shawano (near Menominee,
Stockbridge-Munsee). These sites are monitored under the auspices of various programs,
including the National Atmospheric Deposition Program (NADP), the Great Lakes Atmospheric
Deposition program (GLAD), and the Utility Acid Precipitation Study Program (UAPSP). Data
is available for these sites for the years 1980-86.
Isopleth maps (for sulfates, nitrates, hydrogen ions, and pH in the years 1983-86) from
Chemical Characteristics of Wet Deposition in Wisconsin 1980-86 reveal that annual average pH
levels in deposition range from about 4.5 to 5.0. As one travels from the northwest of Wisconsin
to the southeast, pH drops. To estimate impacts on lakes one can turn to the National Acid
Precipitation Assessment Program (NAPAP) Eastern Lake Survey of lakes in the Great Lakes
Basin, which provides data on pH levels in north-central Wisconsin. This 1988 study found that
414 lakes (6% of total lake area) have a pH less than 6.0. For information about potential effects
by pH level see the accompanying chart.
In addition, the acid neutralizing capacity (ANC) of Wisconsin's lakes is fairly low.
Nearly 40% of lakes were classified as extremely sensitive to acid deposition.
Health Risks:
The only human health risk associated with acid deposition is linked to deposition of
mercury. Low pH facilitates mercury uptake by fish, posing health threats to fish-eaters. For a
more in-depth discussion of this issue, see the section on mercury contamination in fish.
Ecological Risks:
Acid deposition can prompt changes in both terrestrial and aqueous ecosystems. On land,
B-51
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acidity may have effects on the following processes: "foliar integrity, foliar leaching, root growth,
soil properties, microbial activity in soil, resistance to pests and pathogens, germination of seeds,
and establishment of seedlings" (GLB Risk Characterization study). If changes occur, they can
cascade and may have more permanent effects on an entire ecosystem. Two studies in particular
have been performed on important tree species in Wisconsin, sugar maple and white pine, and
they noted changes most likely linked to acid deposition. In a survey of the decline and mortality
of sugar maple and other northern hardwoods across Wisconsin, it was discovered that about 2%
of sugar maples were experiencing decline or were dead. About 36% of these trees did not
appear to be plagued by pests or disease, leaving acid deposition as the only viable cause. White
pines also seem to be suffering under acid deposition. A survey of white pines revealed that
many in the state are suffering from tipburn and mottling caused dry deposition of sulfur dioxide
and ozone. The problem is most severe in the southern areas of the state; however, even in the
less affected northern counties, between 50 and 70% of white pines displayed premature needle
loss.
Obviously, acidity can also affect natural repositories of precipitation. Wisconsin's lakes
are particularly affected; pH of streams does not appear to be dropping. As was mentioned
previously, 6% of lakes in northern Wisconsin have a pH of less than 6.0. At this level, some
species will be lost and reproduction will be affected. Just as small increases in acidity can affect
terrestrial ecosystems, they can also disrupt aquatic ones, by inhibiting diversity, leading to
overgrowth of dominant species. If acidity becomes extreme (i.e. pH is less than 4.2) lakes will
become lifeless.
Acid deposition, in addition to direct effects, can pose additional threats when combined
with other problems. As previously stated in the health effects section, acidic waters can
facilitate mercury uptake by fish. Not only can eating such fish induce adverse health effects in
humans, it can also affect the health and reproductive success of various fish-eaters, such as bald
eagles, osprey, loons, and furbearers (WI Acid Deposition Monitoring and Evaluation Program
1989-90). A study referred to in the GLB Risk Characterization study identified the heightened
effects produced by the combination of acid deposition and ozone, including leaching of nutrients
from plant tissue and the soil.
Economic and Social Damages:
Acid deposition probably contributes to the following categories of losses:
o Timber revenues lost through forest die-back
o Reduction in sport and commercial fisheries
o Cultural losses with effects on bald eagle, other animals, healthy ecosystem in general
o Accelerated deterioration of outdoor materials
B-52
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Particulates
Data was available from monitors on or near four reservations: Menominee, Stockbridge-
Munsee, Oneida, and Lac du Flambeau. However, with the exception of the Oneida data, only
total suspended participates (TSP) figures were available. After identifying the relationship
between TSP and particulate matter smaller than 10 mm (PM10) for sites at which both were
monitored, PM10 levels for the reservations were estimated by adjusting the monitored TSP
levels. The estimated PM10 levels on the reservations were half or less of the National Ambient
Air Quality Standards (NAAQS).
Health risks:
The estimated PM10 levels were well below the threshold levels at which adverse health
impacts might be expected. According to Region 5's formula for calculating excess mortality
from particulates, deaths are possible when PM10 levels exceed 150 ug/m3 on at least one day
of the year. The highest PM10 concentration estimated at a reservation on any day was 52 ug/m3
(Oneida). Restricted activity days may be possible when the annual average PM10 concentration
exceeds 38 ug/m3. The highest annual average PM10 concentration at a reservation was
estimated at 21 ug/m3 (Oneida). In fact, no site anywhere in Wisconsin recorded PM10 levels
exceeding either of these thresholds.
Ecological risks:
No ecological risks are expected from particulate concentrations at these levels.
Economic and social damages:
Applying Region 5's formula for materials damage (soiling, etc.) to TSP concentrations
on the reservations results in annual estimated losses of $40,000.
Sulfur Dioxide
We obtained no monitoring data for sulfur dioxide in or very near reservations, although
some monitoring was evidently performed for the Oneida reservation in 1989-1991. However,
both AIRS and Wisconsin state data lead to the conclusion that ambient sulfur dioxide poses
minimal risks on the reservations. In the 1989 Wisconsin data for sulfur dioxide, there were no
exceedences of the NAAQS and only two of 22 sites came within 20% of the NAAQS. The
remainder of the sites reported levels at less than half of the ambient standard. One of the two
sites which neared the standard is located in Rhinelander, about 30 miles from both the Lac du
Flambeau and Mole Lake reservations. It is questionable whether concentrations in Rhinelander
extend to the reservations, however, as high SO2 concentrations are usually very localized around
point sources. SO2 concentrations in Rhinelander have not actually exceeded the NAAQS since
1985.
B-53
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Sulfates Health risks
Ambient sulfate levels are not high enough to pose any significant risk to individuals
living on reservations. Wisconsin's report on atmospheric sulfate levels for 1987-88 assumes that
the Boulder Junction monitoring site in Vilas county provides information about background
levels of ambient sulfates for rural areas in the state. This site is located in northern Wisconsin
and may be assumed to be representative of the reservations. The two other sites monitored, in
Milwaukee and the Green Bay - Fox River Valley, were assumed to exhibit the highest ambient
sulfate levels in the state. Annual average sulfate levels at all three sites fell well below the
threshold levels at which Region 5 believed that adverse health impacts might begin to occur.
The levels at Boulder Junction were particularly low.
Nitrogen Oxides
No monitoring data is available for nitrogen oxides in or very near reservations.
Wisconsin monitors nitrogen oxides at four urban sites, and at none of them did 1989
concentrations approach the NAAQS. NOx concentrations are typically localized around major
point sources of fossil fuel combustion such as utilities and industrial facilities. There are few
such facilities near reservations, and we would expect concentrations on the reservations to be
substantially lower than at any of the four state monitoring sites. The Region 5 comparative risk
report indicates that there are no non-attainment areas for NOx in the entire Region. We expect
no health, ecological or economic risks from NOx on the reservations.
(The Region 5 report calculates annual economic damages from NOx relating to fading
of dyes. Their formula assumes damages at a flat rate of $1.20/person. We do not believe this
formula should be applied to the reservations, as NOx concentrations there are probably so low
as to make inappropriate this per person assumption.)
Ozone is monitored at several dozen sites in Wisconsin, none of which are in reservations.
Three sites are in counties in which reservations are located (Oneida County, Green Bay in
Brown County, and Appleton in Outagamie County). The ozone NAAQS has been exceeded
only once in the last five years at these sites, and all three counties are counted as being in
attainment with the standard.
Wisconsin does have many areas that do not attain the ozone NAAQS, but these areas are
generally just north of the Illinois border or downwind of Milwaukee. The state considers one
of its sites (People River, in Florence County) to provide concentration data that is typical of the
rural areas of the State outside of the southeast. Ozone concentrations at this site in 1989
reached .104 ppm on one day, and were otherwise below .1 ppm, well within the NAAQS.
We assume that ozone concentrations on Wisconsin reservations are like those at the
B-54
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Oneida, Brown, Outagamie and Florence County sites.
Health risks:
Region 5 took the conservative position that adverse health impacts (asthma attacks and
respiratory restricted activity days) might be experienced from ozone concentrations as low as
.1 ppm, below the ambient standard of .12 ppm. Ozone concentrations at the four Wisconsin
sites we assume as representative of the reservations have exceeded . 1 ppm at most once per year
for the past several years. We expect no adverse health impacts from ozone on the reservations.
Ecological risks:
Research at the University of Wisconsin has indicated that concentrations of ozone as low
as .06 ppm can have an impact on photosynthetic production of important crop and forest species,
such as white pine, soybeans, clover and alfalfa. Faster growing farm crops and sensitive tree
species (American sycamore, loblolly pine, pitch pine, white pine and green ash) are at particular
risk. In the field, damage to tree species from ozone is difficult to distinguish from that due to
acid deposition. For the most part, damage from air pollution to white pine, sugar maple and
other hardwoods in northern Wisconsin appears small. See the discussion of acid deposition
impacts for more information.
Economic and social damages:
Region 5 estimated region-wide crop losses from ozone at 7% for soybean production and
12 % for wheat production. Research underlying these estimates indicates that the loss rates are
far higher in the southern areas of Region 5 than in the northern areas. We roughly estimate crop
losses from ozone concentrations on the reservations at less than 5% of the annual value of
production.
Region 5 also estimated that ozone causes annual damages of $.94 per person by
necessitating addition of anti-ozonants to sensitive materials (e.g., tires). Since these costs have
been borne by every person purchasing such consumer goods regardless of the actual ozone levels
where they live, we have used this figure for the Tribes as well.
Carbon Monoxide
Although no monitoring data is available for carbon monoxide in or near reservations, it
appears very unlikely to be a problem there. Nationally this pollutant occurs in high
concentrations usually only in localized areas of high vehicular traffic density conditions that
will not prevail on reservations. Wisconsin monitors CO at 9 urban sites, and concentrations are
well below the NAAQS at all but one of them (Oshkosh, with an unusual combination of
vehicular traffic and industrial point sources of CO). No health, ecological or economic damages
are expected from CO on the reservations.
B-55
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Airborne lead poses little or no risk to individuals residing on reservations. Both the
Region 5 Comparative Risk study and the state of Wisconsin Air Quality Data Report state that
airborne lead is not a major problem in Wisconsin. The Region 5 study reported that in the
entire region, only 4 sites violated the ambient lead standard and that these sites were all located
in major cities. Wisconsin conducted monitoring in the city of Milwaukee's most heavily-
trafficked areas and found that levels in recent years are only about 5% of the NAAQS.
SOURCES
Great Lakes National Program Office. Great Lakes Basin Risk Characterization Study.
Preliminary. 29 April, 1991.
U. S. Environmental Protection Agency, Region 5. Great Lakes Atmospheric Deposition (GLAD)
Network. 1982 and 1983.
U. S. Environmental Protection Agency. Aerometric Information Retrieval System (AIRS) data,
1985-90.
Wisconsin Department of Natural Resources. Atmospheric Sulfate Levels in Wisconsin: 1985-
1986. May 1988.
Wisconsin Department of Natural Resources. Chemical Characteristics of Wet Deposition in
Wisconsin. 1980-1986. March, 1989.
Wisconsin Department of Natural Resources. 1989 Wisconsin Air Quality Data Report.
Wisconsin Department of Natural Resources. 1989 Sulfur Dioxide and Nitrogen Oxide Emissions
Report. March 1991.
Wisconsin Department of Natural Resources. Wisconsin Acid Deposition Monitoring and
Evaluation Program. 1989-90 Annual Report. January 1991.
B-56
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pH levels in NAPAP Eastern Lake Survey Lakes in the Great Lakes Basin
PH
£
5.0
PH
£
5.5
pH
x
6.0
Number of
Likes
Percent of
Lake Area
Area in
Hectares
(Acres)
Number of
Lakes
Percent of
Lake Area
Area in
Hectares
(Acres)
Number of
Lakes
Percent of
Lake Area
Area in
Hectares
(Acres)
Northeast
Minnesota
0
0%
0
0
0%l
0
14
0%'
0
Upper
Peninsula of
Michigan
95
2%
680
(1,680)
137
3%
1,200
(2,520)
189
5 %
1,700
(4,200)
North Centra]
Wisconsin
30
0 .5 %
0
163
2%
1,960
(4,843)
414
6 %
5,880
(14,530)
Upper
Great
Lakes
0
0%
0
0
0%
0
180
1 %
2,270
(5,610)
Adirondack*
129
2%
2,380
(5,880)
258
8%
9^20
(23^00)
348
10%
11,900
(29,400)
Source: NAPAP. 1988. NAPAP Interim Assessment: The Causes and Effects of Acidic Deposition.
Volume IV: Effects of Acidic Deposition.
B-57
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Notes on Effects of Acidification on Freshwater Aquatic Ecosystems
PH
7.0
6.6
6.1
6.0
5.9 - 5.8
5.8 - 5.7
5.6
55
5 J - 5.0
55 - 4.7
4.7
4.7 - 4.6
42
Effect
Reduced reproduction in most sensitive species (Daphnia')
First species lost (snails)
Reduction in zooplankton species
Loss of Daphnia. reduction in crayfish species
First fish species lost
Major crustaceans lost
First substantial change in phytoplankton density, crayfish lost
Most species of rotifers lost
Large reduction in decomposition rates
Most fish species lost
Major reduction in phytoplankton density
Major reduction in zooplankton density
Last fish species lost
B-58
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Hazardous/Toxic Air Pollutants
This paper provides information relating to environmental problem area # 17,
Hazardous/Toxic Air Pollutants.
Available Data
Very little ambient monitoring data for toxic air pollutants is available that is
representative of conditions on the reservations. The bulk of Wisconsin's air toxics monitoring
has occurred in Milwaukee. We obtained three limited sets of air toxics data for the reservations:
1. Six samples taken at Keshena on the Menominee Reservation between 11/89 and 7/90
in which suspended paniculate matter was analyzed for component metals. The results
from these samples are shown in Table 1.
2. A number of samples taken on the Oneida, Menominee and Stockbridge-Munsee
Reservations for atrazine, PCBs and Benzo-(a)-pyrine in 1989 and 1990. None of these
compounds were detected in these samples.
3. Air toxics monitoring at the Fort Howard Paper waste site abutting the Oneida
Reservation in September, 1986. The maximum concentrations observed across all the
locations at which sampling was conducted are shown in Table 2. Additional monitoring
data obtained recently for the site Remedial Investigation has not yet been analyzed.
Monitoring Results and Calculated Health Risks
Table 1: Metals in ambient air at Keshena
Metal Ambient Cone, (ug/m3) Lifetime Avg. Cancer Risk Non-Cancer Hazard
Aluminum S.OxlO"2
Barium 9.7xlO'4 2.0X10'3
Cadmium 9.0x10'5 7.0x10-"
Chromium 2.2x10'4 l.OxlO'6 * l.OxlO'1
Copper 8.5xlO'4
Zinc 9.1x10-"
Lead 2.5xlO"4 (4 orders of magnitude
< NAAQS)
* Assuming that all the chromium found was hexavalent. This is an extremely conservative
assumption, as usually nearly all chromium is in the non-carcinogenic trivalent state.
B-59
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Table 2: Air toxics near Fort Howard Site
Chemical Ambient Cone, (ppb) Lifetime Avg. Cancer Risk Non-Cancer Hazard
Acetone 104 -
Toluene 26 5xlO'2
Methylene 17 IxlO'5 2xlO'2
Chloride
Benzene 23 3x1O'4
Note -- These are the maximum concentrations found at any sampling point during the Fort
Howard monitoring program. The average concentrations found were substantially less.
Health Risks:
Health risks from air toxics on the reservations appear to be quite low.
The metals levels on the Menominee Reservation (Table 1) are perhaps representative of
the more centrally located reservations. Average individual lifetime cancer risks here appear to
be less than IxlO"6. Non-cancer hazard indices are much less than one, so non-cancer effects are
very unlikely. Concentrations and risks on the more isolated northern reservations are likely to
be lower.
The inability to detect atrazine, PCBs or benzo-(a)-pyrine on the reservations is
significant. Atrazine is the second most commonly detected pesticide in ground-water monitoring
in Wisconsin. PCBs are frequently found at worrisome levels in Wisconsin fish and game.
Benzo-(a)-pyrine is a common air toxic that marks products of incomplete combustion from
industry, transportation, or other urban sources. The inability to detect any of these compounds
suggests insubstantial emissions by agriculture, industry, transportation or households in the
vicinity of the three reservations where sampling occurred.
The Fort Howard site is perhaps the worst case source of VOCs on or very near any
Wisconsin reservation. Air toxics concentrations near this site are undoubtedly a substantial
overestimate of the levels prevailing throughout the reservations generally. The monitored
concentrations may also reflect the influence of the nearby Green Bay airport, further making this
data atypical of the reservations in general. At a maximum of 3x10"4, the average individual
lifetime cancer risks at the worst point near even this worst case site are only moderate. Non-
cancer risks near this worst case site appear minimal.
Air deposition of toxic compounds to surface water (e.g., PCBs and mercury that
bioconcentrate in game fish) are counted in the "Nonpoint Sources" problem area. Air deposition
to land, but not subsequent runoff to surface waters, is considered here.
Ecological Risks:
These ambient concentrations of air toxics would pose trivial risks to ecosystems.
B-60
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However, deposition of air toxics over a substantial period of time appears to account for the
great majority of toxics loadings to the upper Great Lakes, and substantial ecological damage.
It is unclear whether air deposition is a similar major contributor to levels of toxic
compounds in inland lakes. We would speculate that air deposition is the major contributor of
some anthropogenic chemicals (e.g., PCBs), and a less important contributor of other
anthropogenic chemicals. Mercury in inland lakes appears to derive largely from air deposition.
For some naturally occurring toxic chemicals (e.g., mercury, aluminum), acidification of inland
lakes that accelerates natural leaching and/or uptake of toxic chemicals by fish may also be
important (see the acid deposition discussion).
Note, however, that for this project, air deposition of toxic chemicals is defined as covered
by the nonpoint sources problem area.
Social and Economic Damages:
Aside from the possibility that air toxics contribute to whatever odor problems exist on
reservations, we are aware of no plausible mechanism by which toxic air pollutants could cause
substantial social or economic damages.
B-61
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Indoor Air Pollutants Other than Radon
Unfortunately, we have no information bearing directly on risks to the Wisconsin tribes
from this issue. We relied on a national study on indoor air pollutants prepared by the Regional
and State Planning Branch for our basic evaluation of the risks associated with this problem
(attached). This analysis, together with circumstantial evidence, however, points to the possibility
that health risks from this source may be very substantial.
o In most risk studies of indoor air pollution, environmental tobacco smoke is the single
greatest source of risk. (This references "passive smoking" only -- the effects of smoking
on those other than the smoker.) The fraction of the Wisconsin Indian population that
smokes is substantially higher than the fraction of the general American population that
does so. One estimate from an IHS official is that perhaps 3/4 of the adult Indian
population in Wisconsin smokes, compared with about 38 % of adult Indians nationwide
and 26 % of all American adults.
o Another very significant source of indoor air pollution is home heating. Indian homes
in Wisconsin are disproportionally heated (more than 50%) by wood burning, the form
of heating that produces the highest indoor air pollution risks. Use of kerosene and other
unvented space heaters is also probably common on Indian reservations.
o The heating season is far longer in northern Wisconsin than is typical in the rest of the
U.S.
o Indian homes are generally newer and probably more airtight than the average homes
in the U.S., providing less ventilation and opportunity for exchange of cleaner outdoor air
for polluted indoor air.
We strongly recommend that a careful effort be undertaken to assess the levels and risks of
indoor air pollution in Indian residences.
B-62
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EPA Comparative Risk Study
Indoor Air Quality Health Risk Assessment
Region 5
EXECUTIVE SUMMARY
This analysis identifies and, for several compounds, estimates the risks posed to human health
attributable to indoor air pollutants. The estimates indicate only the general range of risk to the
public in sufficient detail for comparing against other environmental problems. Although these
estimates are based on generally accepted toxicity. exposure, and risk characterization
methodologies, the results are not appropriate for other purposes.
In addition to many health effects not quantified here, estimates of the likely range of individual
lifetime risks and population risks from cancer due to indoor air pollutants in Region 5 are as
follows:
Individual Lifetime Risk of Cancer - 4xlO-3to2xlO~2
(4 in 1,000 to 2 in 100)
Population Risk of Cancer - 800 to 10,200 excess cases per year
These risks are caused primarily from environmental tobacco smoke (ETS), asbestos, and several
volatile organic compounds (VOCs): formaldehyde, benzene, carbon tetrachloride, chloroform,
and tetrachloroethylene. Among the noncancer effects, the most important appear to be a
miscellany of respiratory problems known collectively as sick building syndrome (SBS) and a
heightened sensitivity to chemicals known as multiple chemical sensitivity (MCS). Few data exist
for these conditions, but MCS creates severe physical reactions and limitations and some believe
that SBS is widespread (affecting approximately 20 percent of office buildings).
DESCRIPTION OF PROBLEM
People spend up to 90 percent of their time indoors.1 With technological changes in the chemical,
manufacturing, and construction industries, thousands of potentially dangerous pollutants have
been introduced into the indoor environment. Energy conservation standards and practices have
produced a large portion of our current building stock that are more effectively sealed but that may
not provide adequate air to dilute or purge these indoor pollutants.2 A result of these and other
possible causes (such as smoking), concentrations for several pollutants have been found to be
twice to five times more concentrated in indoor air than outdoor air.3 The health effects of
exposure to indoor pollutants have been reported to vary from mild irritation to cancer and
subsequent death.
The base of available information is growing, but the multi-disciplinary and multiple chemical
nature of indoor air quality (IAQ) issues makes comprehensive research difficult. There are no
ecological effects that can associated with indoor air pollutants and, therefore, no ecological risk
assessment for this problem area was conducted. This analysis first discusses cancerous effects,
followed by discussions of noncancerous effects.
CANCER EFFECTS
Contaminants in indoor air can cause cancer (Table 1). Because the methods used to estimate
effects differ, this section is organized by contaminant (VOCs and PAHs, pesticides, ETS, and
asbestos). The discussion of each group of contaminants includes a summary of the toxicity of the
compounds, common exposures, and a characterization of individual risks and population risks.
B-63
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Indoor Air Quality Health Risk Assessmem
Table 1. Health Effect* and Sources of Indoor Air Pollutant*
Pollutant
VOO»
Benzene
Formaldehyde
Chloroform
Carbon
TetracMoride
i 2-Diciioro-
ethane
Trichloro-
ethyiene
Tetracnioro-
ethyiene
Benzo(a)Pyrane
Peeticide*
Alarm
Alpha-BHC
Chlordane
Dieldnn
Heptachior
Proxpur
4 4' DDE
Asbestos
Chysotile
Amosite
CrocidOlite
ETS
Biological
Contaminant*
Carbon Monoxide
Sulfur Dloxld*
Nitrogen Dioxide
Substantiated Source*
Auto Exhaust, ETS, Fuet» Fumee
Adheeives, PeJnt Remover, Building
Material*, Photo Prooeaeing Chemicals
Building Materials, Combustion
Appllances/Heators/Engmes.Adhesive*
Carpeting. ETS. Home & Office
Furnishings. Auto Exfiaust
Water. Clothes Washer. Adhesives
cam Insulation Inks
Grease Cleaners Adhesives Foam
nsulation, Inks
Adhesive. Foam insulation. Tape
Adhesives. Foam Insulation inks
Photo Processing Chemicals Tape
Coatings Lubricants, Rubber
Dry Cleaning. Adhesives. Foam insul-
ation, inks
ETS, Building Mattnals.HVAC Systems
Combustion Appliancea/Heaters/Engines
Cleaners and Waxes. Pesticides Adhesives
Pants and Supplies
nsecticide, withdrawn from u S
nsecticide; banned m US
nsecticide; withdrawn in 1986
nsecticide; withdrawn from u S
nsecticide
nsecticide: common indoor jse
nsecticide
-85% of all asbestos found >r> buildings
Second most common found m Buildings
Used only for high temperature application!
Tobacco Smoking
Virusec. bacterium, molds, insect and
arachnid excrete, pollen, animal and numan
dander
Combustion Oaaen, ETS, Auto Exfiaust
Combustion of fuels containing sulfur
Combustion Appliances. ETS
Cancer
A
Bl
82
82
92
82
B2
B2
32
82
32
82
82
82
A
A
A
Aasocla
Neuro
X
X
X
X
X
X
X
X
X
ed Health
Reeplr
X
X
X
X
X
X
X
X
X
X
Effect.
Llv/Kld
X
X
X
X
X
X
X
X
X
X
X
X
X
Oevel
X
X
Reference
ASS 1966
USEPA 1987
A & S 1966
USEPA 1984
Cornisr '980
Cornisn '980
Cormsn 1980
EPA 1989
EPA'988 199C
EPA'988 '990
EPA1988 1990
EPA1986 '990
EPA'988 '990
EPA'988 1990
EPA'988 199C
EPA 1985
EPA '985
EPA '985
EPA 1969
S & S 1963
EPA 1989
Amman n undatec
EPA. 1067
Ammann, undatec
Admur 1866
Ammann undated
Kay: Car EPA weight-of-evidence carcmogenicrty rating
A« Known human carcinogen
81- Probable human carcinogen (limited human data)
B2- Probable human carcinogen (no human data)
C* Possible human carcinogen
X« Reported health effect
Neuro* Neurological impairment
Resipir* Respiratory impairment including asthma
Liv/Kid« Liver and/or Kidney dysfunction
Devel« Developmental problems including reproductive and congenital
Reference*:
Amdur, MO. 'Air Pollutants.' In Casserett and Doull's Toxicology. 3rd Ed Macmiiian Publishing. NY 1986
Ammann, M, "Effects of indoor Pollutants on Sensitive Populations.' USEPA. Office of Research & Development Reeearch Tnangie Park NC Undated
Andrews. L.S and R Snyder. Tcwe effects of solvents and vapors.' In Casarett and Doull's Toxicology 3rd Ed Macmiiian Publishing NY 1966
Cornish, MH, 'Solvents and Vapors.' In Casaerett and Doull's Toxicology 2nd Ed Macmiiian Publishing. NY. 1880
SpenglerJ.D. and K. Sexton Indoor Air Pollution: A Pubic Health Perspective Science Voi 221 No 4605, 1963
USEPA. Guidance for Controlling Aebeatoe-Corttainmg Materials m Buildings Office of Pesticides & Toxic Substances. EPA,'5CO/5-66:024 June 1985
USEPA, Health Assessment Document for Acetaldehyde, Review Draft. Office of Hearth and Environment Assessment. EPA/800/8-87/014 1967
USEPA, -Nonoccupationai Pesticides Exposurs Study (NOPES).' Office of Reeearch & Development EPAyeOO/3-90/003. January 1990
USEPA, Report to Congress on Indoor Air Quality, Office of Air & Radiation indoor Air Programs EPA/4OO/i-a8/OOiC. August 1988
USEPA, Reeearch and Development: Health Effects Assessment for Carbon Tetrachionde Draft Report. Environmental Criteria and Assessment Office,
Cmcinatti OH. No ECAO-CIN-H039. 1984
B-64
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Indoor Air Quality Health Risk Assessment
VOCs
Toxicity Assessment
The characteristics of VOCs in the indoor environment are poorly understood. Hundreds of VOCs
are commonly detected in the indoor environment and several are classified as Group A or B
human carcinogens.4 The compounds considered here were selected because they were frequently
reported, usually occur in substantially higher concentrations indoors than outdoors, and they had
readily available, pertinent data. Only one polycyclic aromatic hydrocarbon (PAH),
Benzo(a)Pyrene, was selected because of the relative insignificance of PAHs as a group to the
analysis and because of insufficient data on other PAHs. The group of VOCs commonly referered
to as phthalate esters were also not included because of the lack of sufficient exposure data and the
apparent insignificant contribution of the group to the risk analysis. The compounds selected for
analysis and their corresponding cancer potency factors are listed below in order from highest to
lowest toxicity.
Cancer Cancer
Compound Potency Factor Compound Potency Factor
Benzo(a)Pyrene5 11.5 Tetrachloroethylene5 0.051
Carbon tetrachloride5 0.13 Formaldehyde6 0.038
1,2-Dichloroethane5 0.091 Benzene5 0.029
Chloroform5 0.081 Trichloroethylene5 0.011
Exposure Assessment
The range of concentrations used in the analysis are listed below. This analysis identifies likely
exposure levels rather than worst-case or extreme exposures. The range of concentrations used,
therefore, generally reflect the differences between median and mean values reported in published
studies rather than the full range of maximum and minimum values.8 They are listed from highest
to lowest concentrations.
Concentration Rane
Compound Low High
Formaldehyde 8 424
Benzene 2 204
Carbon tetrachloride 0 45
Chloroform 0.1 44
Tetrachloroethylene 5 18
Trichloroethylene 1 13
1,2-Dichloroethane 1 12
Benzo(a)Pyrene 0.001 0.003
In determining individual exposure, this analysis assumes an inhalation rate of 23 m-^/day and an
average person's weight as 70 kg9.
Risk Characterization
This analysis uses some common exposure information and generally applies those exposures on a
24-hour basis to all residents in the region. Assuming exposures are for 24 hours is reasonable
considering that 80 to 90 percent of an individual's time is spent in an indoor environment. This
analysis does not attempt to rigorously account for differences in exposures by location (homes,
offices, and schools, for example) or to distinct groups (sensitive populations, for example), or to
account for the hundreds of chemicals found in indoor air. Individual risks and annual population
risks are calculated using the following equations.
B-65
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Indoor Air Quality Health Risk Assessment
Individual Lifetime Risk = concentration (ug/m3) x inhalation rate (23m3/day) +
1000 (ug/mg) + 70 (kg/person) x cancer potency (mg/kg-day)'1
Population Risk = individual lifetime risk x 46.378 million (Region 5's
population) + 70 years (average life expectancy)
The results are shown below:
VOCs and PAHs
Individual Risk Population Risk
(lifetime risk) (annual excess cancer cases)
Compound Low High Low High
Formaldehyde 1 x 10'4 5 x 10"3 66 3507
Benzene 2 x 10'5 2 x 10'3 13 1288
Carbon tetrachloride 0 2xlO"3 0 1274
Chloroform 3 x 10'6 1 x 10'3 2 776
1,2-Dichloroethane 3 x 10'5 4xlO'4 20 238
Tetrachloroethylene 8 x 10'5 3 x 10'4 56 200
Trichloroethylene 4xlO'6 5xlQ-5 2 31
Benzo(a)Pyrene 4 x 10'6 1 x 10'5 3 8
PESTICIDES
The data and methodology used for estimating lifetime individual risk for pesticides in indoor air is
adopted from the Nonoccupational Pesticide Exposure Study (NOPES) published by the U.S.
EPA in January 1990. Pesticides are commonly detected in indoor air. We include several
pesticides that have been withdrawn, suspended, or banned because they are expected to remain in
indoor air for decades.
Toxicity Assessment
Potency Factors are taken from the Integrated Risk Information System (IRIS).
Cancer Cancer
Pesticide Potency Factor Pesticide Potency Factor
Aldrin 17.0 Chlordane 1.3
Dieldrin 16.0 4 4'DDE 0.34
alpha-BHC 6.3 Proxpur (Baygon) 0.0079
Heptachlor 4.5
Exposure Assessment
The range of concentrations to be used in the analysis are listed below and are from studies of
Jacksonville, FL and Springfield, MA.10
Pesticide Concentration Range
(ug/m3)
Chlordane 197.1 to 198.7
Proxpur (Baygon) 15.0 to 185.2
Heptachlor 27.2 to 115.2
Aldrin 0.1 to 26.0
Dieldrin 0.8 to 6.4
4 4'DDE 0.6 to 3.8
alpha-BHC 0.2 to 0.8
B-66
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Indoor Air Quality Health Risk Assessment
An additional calculation allowed for a 2-year half-life of the cyclodiene termiticides (Heptachlor,
Aldrin, Dieldrin, and Chlordane) that have been banned, withdrawn, or suspended. Although it is
not known at what rate these pesticides degrade, this assumption helps identify the potential low
end of the range for these compounds. The NOPES study assumed an inhalation rate of
21m3/day.
Risk Characterization
The range of estimates for lifetime, individual risks as reported in the NOPES study follow, along
with estimates of the number of annual excess cancer cases to the population of Region 5.
Individual Risk Population Risk
(lifetime risk) (annual excess cancer cases)
Pesticide Low High Low High
Heptachlor 1 x 10'6 2 x 10"4 1 133
Aldrin 2 x 10'8 1 x 10'4 0.01 66
Chlordane 3 x 10'6 7 x 10'5 2 46
Dieldrin 1 x 10'7 3 x 10'5 0.1 20
alpha-BHC 4 x 10'7 2 x 10"6 0.3 1
4 4' DDE 6 x lO'8 4 x 10'7 0.04 0.3
Proxpur (Baygon) 3 x 10'8 4xlO'7 0.02 0.3
ENVIRONMENTAL TOBACCO SMOKE (ETS)
This analysis uses direct estimates of individual lifetime risk and population risk. The toxicity and
exposure assessment sections, below, provide additional information but are not used in
calculating risks.
Toxicity Assessment
Environmental Tobacco Smoke (ETS) causes a variety of health effects including lung cancer,
cardiovascular effects, increased susceptibility to infectious diseases in children, chronic and acute
pulmonary effects in children, mucous membrane irritation, and allergic reactions.11 The cancer
risk associated with ETS for nonsmokers has been estimated at 5 x 10 * ^ cancer deaths per
person per mg of tobacco exposure per day.12-13-14 (Note that these are the estimated cancer
deaths, compared to estimated cancer cases for the other compounds analyzed.)
Exposure Assessment
Due to the complex chemical composition of ETS, exposure studies generally focus on one
component of ETS (tar) and report that nonsmokers are typically exposed to 1.4 mg of tar daily.15
Risk Characterization
One study's estimate of the lifetime risks of lung cancer death from ETS is between 4 x 10'3 and
1 x 10*2 for nonsmokers and only slightly higher for ex-smokers.16 The same study estimates
that the annual number of lung cancer deaths from ETS is between 2,500 and 5,200 nationally,
depending on the methodology used. To estimate the number of deaths in Region 5, this analysis
uses the midpoint of that range, 3,850 (a number also close to an estimate in a recent EPA review
draft report), and Region 5's share of the national population (46.378 million+275.7 million or
16.8%). The annual number of lung cancer deaths in Region 5 attributable to ETS is, therefore,
3,850 x 16.8% or 648.
B-67
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Indoor Air Quality Health Risk Assessment
ASBESTOS
Asbestos is the collective name given to two groups of naturally occurring mineral fibers found in
various rock formations. The two groups being amphibole (amosite, crocidolite, etc.) and
serpentine (chrysotile). For decades prior to 1973, asbestos was the material of choice for a wide
variety of thermal, acoustical, and abrasive applications because of its unique properties. Asbestos
containing materials (ACM) are found in cement products, acoustical plaster, fireproofing textiles,
wallboard, ceiling tiles, vinyl floor tiles, thermal system insulation, and numerous other
materials.17
Toxicity Assessment
Asbestos is classified by the EPA Science Advisory Board (SAB) as a Group A known human
carcinogen.18 Asbestos-related diseases include: lung cancer, mesothelioma. and asbestosis.19 In
general, dose-response data have relied heavily on occupational exposure information from various
asbestos-related industries. Extrapolation of the relationship between exposure and disease
indicates that only a small proportion of people exposed to low levels of asbestos will develop
asbestos-related diseases. Subpopulations at greatest risk (other than those occupationally
exposed) are: smokers, children, and young adults.
EPA has reported the unit risks of lung cancer and mesothelioma from asbestos exposure. These
two cancers are by far the most important causes of death among exposed individuals. (Note that
these are the estimated cancer deaths, compared to estimated cancer cases for the other
compounds analyzed.)
Lifetime Unit Cancer Risk 20
(per 0.01 fibers/ml)
Population Mesothelioma Lung Cancer
Female Smokers 2.52 x 10'3 1.50 x 10'3
Female Nonsmoker 2.72 x 10'3 1.64 x 10'4
Male Smokers 1.81 x 10'3 2.38 x 10'3
Male Nonsmokers 2.20 x 10'3 1.85 x 10'4
Exposure Assessment
EPA surveys estimate that, nationally, 31,000 (-35 percent) schools and 733,000 (-20 percent)
office buildings contain ACM in varying states of disrepair.21 The ACM in these buildings can be
classified as friable (ACM with a high probability of fiber release when disturbed) or nonfriable.
The average lifetime exposure to asbestos in indoor environments have typically been reported at
0.01 fibers/ml.22 There are several studies of schools done in the late 1970s and early 1980s that
showed vastly higher concentrations. These studies, however, were before the 1986 Asbestos
Hazard Emergency Response Act (AHERA) was adopted into law. AHERA required Local
Education Agencies (LEAs) to carry out initial response actions and have implemented an asbestos
management plan in public and private schools by July 1989. We assume that most LEAs have
complied with this regulation and have either removed all friable and nonfriable ACM or have it
under a strict management plan that should prevent any future significant fiber release episodes.
To date, Federal regulations have not required AHERA be applied to other buildings. For these
reasons, these early school studies are omitted from our analysis. This study uses 0.01 fibers/ml
as the upper range of exposure.
The lower limit for typical concentrations (0.0004 fibers/ml) is an arithmetic mean of several
studies of public buildings. The estimate for average nonoccupational exposure concentration is,
therefore, between 0.0004 and 0.01 fibers/ml.
B-68
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Indoor Air Quality Health Risk Assessment
Risk Characterization
The lifetime individual risks of death from mesothelioma and lung cancer for nonoccupational
exposures to airborne asbestos fibers are shown below.
Asbestos Individual Lifetime Cancer Risk
Low (0.0004 fibers/ml) High (0.01 fibers/mil
Population Mesothelioma Lung Cancer Mesothelioma Lung Cancer
Female Smokers 1 x 10'4 6 x 10'5 3 x 10'3 2 x 10'3
Female Nonsmoker 1 x 10'4 7 x 10'6 3 x 10'3 2 x 10'4
Male Smokers 7 x 10'5 1 x 10'4 2 x 10'3 2 x 10'3
Male Nonsmokers 9 x 10'5 7 x 10'6 2 x 10"3 2 x 10'4
The estimate of individual lifetime risk, therefore, is between 7 x 10"*> and 3 x 10~$ and
population risk is between 5 and 1988 cases per year.
NONCANCER EFFECTS
Humans are known to respond to indoor air pollutants in a variety of ways (Table 1). The actual
response of an individual depends on at least the following: the individual's tolerance limits, the
type of pollutants in the air, the exposure or dose and the number of exposures, the target organ(s)
potentially affected, the rate of absorption and excretion by the body, and the rate of metabolism.
A precise understanding in the scientific community of these effects and their causes is lacking,
partly because the pollutants appear in complex mixtures in indoor air.
Typically, the health of most people is not severely threatened by noncarcinogenic exposures to
low levels of indoor contaminants. The efforts are usually limited to discomfort or mild illness but
include the following (with the reported percent of people in problem buildings reporting these
conditions):
Eye irritation (2323 to 81%24) Sinus congestion (51%24)
Dry throat (3523 to 71%24) Skin irritation (38%22)
Headache (3123 to 86%25) Shortness of breath (923 to 33%24)
Fatigue (172
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Indoor Air Quality Health Risk Assessment
Potential synergistic, antagonistic, and additive effects may play an important role in causing the
acute symptoms associated with SBS and MCS. Synergism is known to exist among the
following:
PAHs and irritant gases (SC>2 and NC>2)26 PAHs and ETS26
Ozone and aerosols (ammonium sulfate)27 Asbestos and ETS28
NC>2 and aerosols (ammonium sulfate)27 Asbestos and BaP29
SO2 and aerosols (sodium chloride)30
Complex mixtures of chemicals are ubiquitous to indoor environments and are made up, in part, of
environmental tobacco smoke (ETS), VOCs, pesticides, and combustion gases. (A subset of these
pollutants have been found to be carcinogenic and are discussed individually in earlier sections.)
Environmental tobacco smoke has been associated with cardiovascular effects,
increased susceptibility to infectious diseases in children, chronic and acute pulmonary
effects in children, mucous membrane irritation, and allergic responses.31
VOCs have been identified a potential causative agent in SBS investigations.32 Health
effects, reportedly attributable to exposure to VOCs, range from sensory irritation to
behavioral, neurotoxic, and hepatoxic effects.33 Formaldehyde has been shown to cause
mucous membrane irritation at very low concentrations (0.1 to 0.2 ppm) in chamber
studies.34
Pesticides are by definition poisonous, and affect the nervous system, the hepatic
system, and the reproductive system.34
Combustion gases that have been found to accumulate in indoor environments are
carbon monoxide, nitrogen dioxide, and sulfur dioxide. The effects of CO may be grossly
underestimated. One study reported that sensitive populations may be highly affected by
indoor exposures and misdiagnosed with symptoms related to flu, food poisoning, Alz-
heimer's disease, and general decrepitude.35 Nitrogen dioxide and sulfur dioxide are lung
irritants that cause respiratory difficulty in sensitive populations, particularly asthmatics.36
Airborne biological contaminants are also ubiquitous in indoor environments.
Biogenic aerosols can produce direct toxicity, or may be pathogenic or allergenic.37
CAVEATS
This analysis of the approximate health impacts of poor indoor air quality is designed to be used
only as part of a general comparison with other environmental problems. The quantitative risk
estimates are based on generally accepted toxicity, exposure, and risk characterization
methodologies and, therefore, carry all of the uncertainties typical of assessing risks (high-dose to
low-dose extrapolations and animal-to-human extrapolations, for example). Further, this analysis
has additional uncertainties resulting from the lack of specific data, particularly on exposures. For
example, this analysis uses some common exposure information and generally applies those
exposures on a 24-hour basis to all residents in the region. It does not attempt to rigorously
account for differences in exposures by location (homes, offices, and schools, for example) or to
distinct groups (sensitive populations, for example), or to account for the hundreds of chemicals
found in indoor air. As a result, the conclusions of this analysis are not appropriate for
other purposes. This analysis does, however, probably account for the major health effects
from poor indoor air quality, at least as is now known.
ADDITIONAL INFORMATION
The derivations used in this analysis are available in the Documentation Report.
B-70
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Indoor Air Quality Health Risk Assessment
SUMMARY OF QUANTIFIED CANCER RISKS
Individual and Population Risks
Carcinogenic Agents
Region 5
Individual Risks
VOCs:
Formaldahyde
Benzene
Carbon tetrachloride
Chloroform
1 ,2 Dichloroethane
Telrachloroethylene
Trichloroethylene
Benzo(a)Pyrene
Pesticides.
Heptachlor
Aldrin
Chlordane
Dieldrin
alpha-BHC
4 4' DDE
Proxpur(Baygon)
ETS*
Asbestos
Total Risk:
Lower to
---(lifetime
1E-04 to
2E-05 to
OE-t-OO to
3E-06 to
3E-05 to
8E-05 to
4E-06 to
4E-06 10
1E-06 to
2E-08 to
3E-06 to
1E-07 to
4E-07 to
6E-08 to
3E-08 to
4E-03 to
7E-06 to
4E-03 to
* Individual risks are for nonsmokers,
subpopulations.
Note: Detail may not
directly compute to
Upper
risk)---
5E-03
2E-03
2E-03
1E-03
4E-04
3E-04
5E-05
1 E-05
2E-04
1E-04
7E-05
3E-05
2E-06
4E-07
4E-07
1E-02
3E-03
2E-02
population risk
population risk
Population Hisks
Lower to
Upper
(annual excess cancer cases)
66 to
1 3 to
0 to
2 to
20 to
56 to
2 to
3 to
1 to
0.01 to
2 to
0.1 to
0.3 to
0.04 to
0.02 to
648 to
5 to
816 to
3507
1288
1274
776
238
200
31
8
133
66
46
20
1
0.3
0.3
648
1988
10,223
is computed considering additional
due to independent
derivation of
ETS risks and independent rounding.
Estimated 1990
population is
46378 tnousand
B-71
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Indoor Air Quality Health Risk Assessment
Notes
Moschandreas, D J. and S.S. Morse, Exposure Estimation and Mobility Patterns, 72nd Annual
Meeting of the Air Pollution Control Association (Cincinnati, Ohio, 1979).
2Maldonado, E.A.B. and I.E. Woods, "A Method to Select Locations for Indoor Air Quality
Sampling," Building and Environment, Vol. 18, No. 4, 1983, pp. 171-180.
3Wallace, Lance A., The Total Exposure Assessment Methodology (TEAM) Study - Phase II,
USEPA, Office of Research and Development, February, 1983.
4USEPA, Report to Congress on Indoor Air Quality, Office of Air and Radiation, Indoor Air
Programs, EPA/400/1-89/001C, (Washington, DC: U.S. Government Printing Office), August
1989, p. 4-24.
5'USEPA, Health Assessment Document for Acetaldehyde, Review Draft, Washington, D.C.:
Office of Health and Environmental Assessment. EPA 600/8-86/015A, 1987.
6USEPA, Assessment of Health Risks to Garment Workers and Certain Home Residents from
Exposure to Formaldehyde, Office of Pesticides and Toxic Substances. Washington, D.C.. 1987.
7Versar, Documentation for W-E-T Model Input Parameters: California List Constituents, Draft
Report, Washington, D.C.: USEPA, Office of Solid Waste, EPA Contract No. 68-01-7053,
1986.
o
See Documentation Report.
9Executive Office of the President, Risk Analysis: A Guide to Principles and Methods for
Analyzing Health and Environmental Risks, Council on Environmental Quality, 1989, p. 132.
10USEPA, Nonoccupational Pesticide Exposure Study (NOPES), Office of Research and
Development, EPA/600/3-90/003, January 1990, pp. 93-112.
llReport to Congress on Indoor Air Quality, p. 3-2.
12Repace, J.L., and A.H. Lowery, "A Quantitative Estimate of Nonsmokers' Lung Cancer Risk
from Passive Smoking, Environment International, 1985,11:3-22.
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Indoor Air Quality Health Risk Assessment
13Repace and Lowery, "An Indoor Air Quality Standard for Environmental Tobacco Smoke Based
Upon Carcinogenic Risk," New York State Journal of Medicine. 85:381-383.
14Repace and Lowery, "A Rebuttal to Criticism of the Phenomenologic Model of Nonsmokers'
Lung Cancer Risk from Passive Smoking," Environmental Carcinogens revs. (Journal of
Environmental Science and Health) C4:225-235.
l5Report to Congress on Indoor Air Quality, p. 4-22.
16Robins, James. National Research Council,"Appendix D: Risk Assessment -- Exposure to
Environmental Tobacco Smoke and Lung Cancer." Environmental Tobacco Smoke: Measuring
and Assessing Health Effects, National Academy Press, 1986. As reported in the 1990 USEPA
Report to Congress on Indoor Air Quality, p. 4-20.
17USEPA, Guidance for Controlling Asbestos-Containing Materials in Buildings, Office of
Pesticides and Toxic Substances, EPA/560/5-85-024. June 1985. p. 1-1.
l^Report to Congress on Indoor Air Quality, p. 4-15.
19 Guidance for Controlling Asbestos-Containing Materials in Buildings, p. 1-2.
20USEPA, Airborne Asbestos Health Assessment Update. Office of Health and Environmental
Assessment, EPA/600/8-84/003F, June 1986, pp. 163-165.
21Guidancefor Controlling Asbestos-Containing Materials in Buildings, p. 1-1.
22Report to Congress on Indoor Air Quality, p.4-18.
23Pickering, A.C., et al., "Sick Building Syndrome." In Indoor Air, Volume 3: Sensory and
Hyperreactivity Reactions to Sick Buildings, Proceedings of the International Conference on
Indoor Air Quality and Climate (Stockholm), U.S. Department of Commerce, Washington D.C.,
NTTS Publication No. PB-85-104206, August 20-24, 1984.
24National Institute for Occupational Safety and Health (N10SH), Hazard Evaluations and
Technical Assistance Branch, Guidance for Indoor Air Quality Investigations (Cincinnati, Ohio),
January, 1987.
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Indoor Air Quality Health Risk Assessment
25Sterling, E.M., et al., "Sick Buildings: Case Studies of Tight Building Syndrome and Indoor
Air Quality Investigations in Modern Office Buildings," Environmental Health Review, Vol. 29,
No. 3, pp. 11-16, 1985.
26Breysse, P.A., "The Office Environment - How Dangerous?" In Indoor Air, Volume 3:
Sensory and hyperreactivity reactions to sick buildings, " Proceedings of the International
Conference on Indoor Air Quality and Climate (Stockholm), U.S. Department of Commerce,
Washington D.C., NTIS Publication No. PB -85- 104206, August 20-24, 1984.
27USEPA, Health Assessment Document for Poly cyclic Organic Matter, Draft Report, Office of
Research and Development, Washington, D.C., 1980.
28Amdur, M.O., "Air Pollutants." In Klaassen, C.D. et al. (eds), Casarett and Doull's
Toxicology. The Basic Science of Poisons. Third Edition (New York: Macmillan Publishing,
1986).
29 Airborne Asbestos Health Assessment Update, 1986.
30Last, J.A., "Health Effects of Indoor Air Pollution: Synergistic Effects of Nitrogen Dioxide and
a Respirable Aerosol," Environment International, Vol. 9, 1983, pp. 319-322.
31Mossman, B.T., J. Bignon, M. Corn, A. Seaton, J.B.L. Gee, "Asbestos: Scientific
Developments and Implications for Public Policy," Science, January 19, 1990, 247:294.
32Report to Congress on Indoor Air Quality, p. 3-6.
3:W, p. 3-7.
34 Ibid., p. 3-6.
35 Ibid, p. 3-7.
36Ammann, H., "Effects of Indoor Pollutants on Sensitive Populations," USEPA, Office of
Research and Development, Research Triangle Park, N.C., Undated, p. 1.
31 Ibid., p. 5.
3&Repon io Congress on Indoor Air Quality, p. 3-13.
B-74
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EPA Comparative Risk Study
Indoor Air Quality Welfare Effects Assessment
Region 5
Executive Summary
Poor indoor air quality can create a variety of economic costs to society including increased medical
costs, losses to productivity, and damage to materials. The welfare effects of indoor air quality are
estimated in this study using a damage approach (that estimates the cost of physical damage caused
by a problem) to assign a value to the economic costs. Because of the lack of substantiated
research in this area, the estimates are incomplete and subject to great uncertainty. The estimates
are not statistically reliable and should be used only to compare the possible magnitude of the
welfare effects of indoor air quality with the effects of other environmental problems.
Indoor air pollutants can cause damage to materials such as metals, paints, textiles, paper, leather,
computer equipment, and electrical equipment. Although the cost of material damage may
be substantial, the value is not quantified because of the lack of research in the area. The
medical costs of indoor air relate to the cost of medical care for the health effects caused by indoor
air. For Region 5, the medical costs are estimated at $175 million to $410 million per
year. The costs of lost productivity consist of 1) reduced productive years due to major life-
threatening health effects and 2) the day-to-day productivity losses of the general work force.
These productivity losses are estimated at $9.5 billion to $10.4 billion per year.
For effects quantified in this analysis, the total welfare costs are about $10 billion to $11
billion per year for Region 5.
Introduction
Very few studies are available on the economic costs of poor indoor air quality. In its Report to
Congress on Indoor Air Quality^, the U.S. Environmental Protection Agency (EPA) identified
three major categories of economic costs: material costs, direct medical costs, and lost productivity
costs. Using available research data, EPA quantified welfare costs for direct medical costs arid lost
productivity costs but was unable to assign a dollar value to the material costs. This analysis relies
heavily on EPA's work as detailed in Chapter 5 of the Report to Congress on Indoor Air Quality
for its methodologies and assumptions. Each of the three damage categories are described in detail
in the following sections.
Materials Costs
Indoor air pollutants can cause adverse effects on materials and equipment. Costs associated with
the adverse effects could include maintenance, repair, and replacement costs for soiling, deteriora-
tion of appearance, and reduced service life. Table 1 summarizes materials that can be affected, the
types of possible damage, and the principal indoor air pollutants that can cause this damage.
As with health effects, some objects and materials can be considered a "sensitive population."
Particularly sensitive objects include leather-bound books, fine art, electrical equipment, and
computer equipment. The value of damage to unique art and antique books can be priceless.
Telephone switching and computer equipment is susceptible to corrosion caused by air particles
and gases. A representative of Bell Communications Research2 reported that the seven regional
telephone companies have spent large sums to replace, clean, or repair switches as a resulTof
indoor air contaminants. Failures have occurred throughout the system, and range in cost from as
little as $10,000 to as high as $380,000 per event. With the growing number of personal
computers in use, the cost of damage to electrical equipment could be quite substantial.
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Indoor -VirQuahtv Welfare Effect;. Assessment
EPA Comaprative Risk Study
Summary of Indoor Air Quality Issues
Regions 2, and 4-9
Air Pollution Effects on Materials
Materials
Type of Damage
P r i n cipal A i r Pollutants
organic coatings
Text i. e dyes
Paper
Magnetic storage media
Photographic materials
Rubber
Leather
Ceramics
Corrosion tarnishing
Surface erosion
discoloration soiling
Reduced tensile strength
soiling
Fading color change
Embrittlement. soiling
Loss of signal
microblemishes. "sulfidmg"
Cracking
Weakening, powdered surface
Change of surface appearance
Sulfur oxides and other acid gases
Sulfur oxides hydrogen suedes
particulate matter
Sulfur oxides nitrogen ox'des
particuiate matter
nitrogen oxides ozone
Sulfur oxides particulate matter
Particulate matter
Sulfur oxides, hydrogen sulfide
Ozone
Sulfur oxides
Acid gases. HF
Source Report to Congress on Indoor Air Quality.
Volume II. Assessment and Control of Indoor Air Pollution August 1989 p 5-6
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Indoor Air Quality Welfare Effects Assessment
Medical Costs
The annual number of excess cancer cases attributable to indoor air pollution are estimated and
presented in the health effects section. The medical costs associated with the cancer cases, how-
ever, represent a welfare effect of indoor air. As in Chapter 5 of Report to Congress on Indoor
Air Quality, the medical costs of the excess cancer are estimated using a 1981 study by Hartunian,
et a/.3 that estimates the present value of direct medical expenditures for various illnesses derived
from actual cost experi-ences. Future medical costs were discounted to present value using a 6
percent discount rate.
The calculation of the medical costs due to excess cancer cases involves multiplying the number of
excess cancer cases derived in the health effect analysis by the average cost per cancer case (avail-
able data are in 1986 dollars). Thus, the medical costs due to increased cancer cases for Region 5
equals 816 cancer cases multiplied by $24,938 per case for a total of $20 million at the low end
of the range and 10223 cases for a total of $255 million at the high end.
Chapter 5 of the Report to Congress on Indoor Air Quality calculates several other types of
medical costs related to non-cancer health effects. The first cost relates to asthmatic children. A
New York City study4 found that asthmatic children from smoking households visited hospital
emergency rooms more often than those from non-smoking households. The cost of the
increased emergency room visits by asthmatic children can be calculated as a welfare
effect of poor indoor air. The New York City study reported that the number of increased
emergency room visits equals 1.26 visits per year per asthmatic child in smoking home. The
Report to Congress on Indoor Air Quality estimated, based on National Center for Health
Statistics data, that 5 percent of children under 18 suffer from asthma. According to the Center for
Disease Control, 43 percent of children live in smoking households. The cost of the additional
emergency room visits equals the percent of children with asthma (5 percent) multiplied by the
population of children under 18 to derive the number of children with asthma. Next, the number
of children with asthma is multiplied by the percent of children in smoking households (43 percent)
to get the number of asthmatic children in smoking households. That figure is th'en multiplied by
the additional number of emergency room visits per year (1.26) and the average cost of the visits
($90). For Region 5 the resulting cost is $30 million.
Besides cancer, Environmental Tobacco Smoke (ETS) is reported to cause other major diseases.
For example, according to a study by Wells5, 32,000 cases of heart disease per year (for the
U.S.) are attributable to environmental tobacco smoke (ETS). In order to estimate the number of
heart disease cases from ETS for Region 5, the number of heart disease cases are disaggregated
from the country's total based on Region 5's population. The total medical costs for ETS heart
disease equals the estimated number of cases for Region 5 (6097) multiplied by the medical costs
per case ($9,684)) or $59 million.
Another category of increased medical costs is due to increased medical visits for the white
collar work force necessitated by indoor air quality problems. Based on a survey in New
England6, white collar workers have an extra .26 visits with doctors per year due to poor indoor
air quality. Assuming a white collar work force of 9131 million in Region 5 and an average cost
per visit to the doctor of $307, the additional medical costs equals $66 million.
Productivity Losses
The value of decreased worker productivity due to poor indoor air can also be included as a welfare
effect. Decreased worker productivity falls into two categories: reduced productivity within the
general work force and disease-specific productivity losses.
Within the general white collar work force, poor indoor air quality may cause a reduction in worker
productivity due to headaches, eye irritation, and fatigue. Workers may also spend time away
B-77
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Indoor Air Quality Welfare Effects Assessment
from their work location by taking breaks or walks outdoors to relieve these symptoms. A study
of 94 state government office buildings conducted by a coalition of employee unions8 found that 3
percent (or 14 minutes, or .23 hours) per day is lost due to poor indoor air quality. In addition,
worker days lost due to sick leave were found to increase by an average of .6 extra sick days per
worker per year.
The cost, then, of the reduced daily productivity per white collar worker equals the average white
collar wage rate ($15.56), multiplied by .23 hours/day times 2080 hours per year (52 weeks per
year times 40 hours per week) multiplied by the Region 5 work force of 9131 million. The daily
productivity losses for Region 5 equals $9 billion. The productivity losses due to increased sick
leave equals the wage rate multiplied by 4.8 sick hours, multiplied by the white collar work force
in the region for a cost of $682 million. The total general worker productivity losses for
Region 5 (both lost time and sick leave) is estimated at $9179 million.
Disease-specific lost productivity is measured based on the lost earnings caused by the increased
number of cancer cases and cases of heart disease. Lost productivity costs due to excess cancer
cases equals the number of cases multiplied by the cost of lost productivity per case ($92,645)
from the Hartunian Study9 or $76 million at the lower end of the range and $947 million at the
high end. Lost productivity costs due to excess heart disease cases equals the number of cases
multiplied by the cost of lost productivity per case ($44,896) from the Hartunian Study10 or $247
million.
Summary of Welfare Costs Attributable to Poor Indoor Air Quality
Region 5
Costs or Losses
Low High
($ million)
Medical Costs
Cancer $20 $255
Noncancer
Emergency room visits by asthmatic children 30 30
Heart disease 59 59
Increased visits to doctors by workers §& 6jj
Subtotal $175 $410
Productivity Losses
General worker productivity $9179 $9179
Cancer 76 947
Heart disease 247 247
Subtotal $9528 $10399
TOTAL $9702
The largest portion of the welfare costs are attributable to lost productivity among the general white
collar work force. These estimates for the white collar labor force productivity losses are in the
billions of dollars and should only be considered a gross estimate to be used to compare the
possible magnitude of the welfare effects of poor indoor air quality with the welfare effects of other
environmental problems.
B-78
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Indoor Air Quality Welfare Effects Assessment
Notes
iUSEPA, Report to Congress on Indoor Air Quality, Office of Air and Radiation, Indoor Air
Programs, EPA/400/1-89/001C, (Washington, DC: U.S. Government Printing Office). August
1989, Chapter 5, pages 5-1 - 5-21.
2Weschler, C, Bell Communications Research, Personal Communication with David Mudarri,
EPA, June 30, 1988 as cited in Report to Congress on Indoor Air Quality, page 5-7.
3Hartunian, N. et al., The Incidence and Economic Costs of Major Health Impairments.
Lexington Books, 1981, as cited in Report to Congress on Indoor Air Quality, pages 5-7 - 5-8.
4Evans, D., et al, "The Impact of Passive Smoking on Emergency Room Visits of Urban
Children with Asthma", American Review of Respiratory Diseases, 135:567-572: summarized in
Residential Hygiene, Vol. 4, No. 2, page 12, as cited in Report to Congress on Indoor Air
Quality, page 5-10.
5Wells, A.J., "Passive Smoking Mortality: A Review and Preliminary Risk Assessment",
Presented at 79th annual meeting, Air Pollution Control Association, Minneapolis, Minnesota.
1986, as cited in Report to Congress on Indoor Air Quality, page 3-6.
^Report to Congress on Indoor Air Quality, page 5-11.
''Report to Congress on Indoor Air Quality, pages 5-12.
^Report to Congress on Indoor Air Quality, page 5-11.
9Hartunian, N. et al, The Incidence and Economic Costs of Major Health Impairments,
Lexington Books, 1981, as cited in Report to Congress on Indoor Air Quality, pages 5-7 - 5-8.
10Hartunian, N. et al, The Incidence and Economic Costs of Major Health Impairments,
Lexington Books, 1981, as cited in Report to Congress on Indoor Air Quality, pages 5-7 - 5-8.
B-79
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Radon
This paper provides information relating to environmental problem area #21, Indoor
Radon.
Data Acquired:
Recent radon sampling data for buildings on reservations were available through the
Indian Health Service (IHS). Two data sets were available: results from about 250 buildings for
which actual monitored readings were available, and test results from nearly 1000 buildings for
which the only information reported was the proportion of readings exceeding 4 pci/1 (EPA's
"Action Level" for radon). Although both private homes and public facilities were monitored,
we considered only samples from private homes. For each sampling site, results of either a
canister test, an alpha track test, or both were available. In the cases where both tests had been
performed, the results were averaged together. This procedure of averaging the results of a short
term and a longer term test is not ideal. In general, the longer term test results should be more
accurate. However, the number of longer term tests was quite small for many reservations and
we wanted to use as large a data set as possible. There was no consistent difference between the
short and the longer term test results. All samples for each reservation were averaged together
to arrive at a representative level for the reservation. We assumed that the specific homes that
have been monitored for radon on a reservation are representative of all the houses on the
reservation.
For risk calculations, we used the smaller data set because it included information about
the average radon levels observed. However, no data were available in this data set for four
reservations. For these four reservations, we proceeded as follows:
o Three of the reservations had no samples exceeding 4 pci/1 (Bad River, Potawatomi,
Red Cliff). These reservations were assumed to experience radon concentrations at the
state average level of 1.7 pci/1.
o For the Mole Lake reservation, it was assumed that the 31% of samples registering
concentrations greater than 4 pci/1 were at concentrations of 8 pci/1, and the remainder of
the samples were at 1.7 pci/1.
The radon data are summarized in a table at the end of this paper. The estimated
weighted average radon concentration in residences on Wisconsin reservations is 5.8 pci/1, well
above the state average of 1.7 pci/1. The other Region 5 states average between 2.2 and 2.5, with
the exception of Michigan at 1.1.
Human Health Risks:
A great deal of evidence has shown radon to produce lung cancer in humans. We
calculated risks by using a simple model of radon potency (ignoring the interaction between
B-80
-------
radon and smoking, and ignoring a back-calculation procedure for total lung cancer deaths). The
excess lifetime cancer risk associated with EPA's action level of 4 pci/1 is 1.7 x 10'3. Applying
this approach to the radon data for Wisconsin reservations, the excess risk varies in degree from
reservation to reservation. The weighted average cancer risk is very high at 2.5 x 10'3. The
residents of the Stockbridge-Munsee, Menominee, Mole Lake, and Lac du Flambeau reservations
appear to face the greatest risks.
Ecological Risks:
There are no ecological risks associated with indoor radon.
Social and Economic Damages:
Health care costs and lost wages associated with lung cancer are expected to be
significant. EPA recommends remediation of homes where radon concentrations exceed 4 pci/1.
Remediation can involve a variety of measures ranging from simple improved ventilation to
ventilation with air-to-air heat exchangers to sub-slab ventilation. Remediation costs might
typically be in the range of $500 - $2,500 per household, depending on the complexity of
remediation. Assuming remediation would be undertaken in about 750 houses (the estimated
number of Indian residences with concentrations exceeding 4 pci/1), total remediation costs could
reach over $375,000 in one-time costs. It should be noted that since remediation reduces health
risks associated with exposure to radon gas, the residents of a remediated house will experience
decreased health risks. That is, residents will bear either the full calculated health risks and
health care costs and lost wages (if no remediation occurs), or the remediation costs plus
somewhat reduced health risks.
B-81
-------
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B-82
-------
General References
U.S. Department of the Interior, Bureau of Indian Affairs. Fact Sheets on each Tribe, covering
people and area, employment, resource availability and development, health, housing, etc.
Great Lakes Indian Fish and Wildlife Commission. Treaty Resource Manual. 1991.
U.S. Environmental Protection Agency, Great Lakes National Program Office. Great Lakes Basin
Risk Characterization Study. Preliminary. 29 April, 1991.
Menominee Indian Tribe of Wisconsin. "Demographic Report."
Menominee Indian Tribe of Wisconsin. "Historical Summary."
Planning Department. Package of material on Menominee Tribe, covering infrastructure,
employment, and health statistics.
U.S. Department of Commerce. 1990 Census Population Data for American Indian Reservations
with Populations exceeding 1,000. Press release. 11 July, 1991.
U.S. Environmental Protection Agency, Region 5. Comparative Risk Project Results.
U.S. Environmental Protection Agency. Integrated Risk Information System and Risk Assistant
software for information on health effects of toxic substances and assistance in risk calculations.
B-83
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