United States         Science Advisory       EPASAB-EC-90-021A
             Environmental Protection    Board           September 1990
             Agency           (A-101)
             	/'/ ^ • ' -	
?/EPA      The Report Of
             The Ecology And Welfare
                                          PROTECTION
             Relative Risk
             Reduction Project

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                              NOTICE


     This report has been written as part of the activities of the
Science  Advisory   Board,   a   public  advisory  group  providing
extramural scientific information and advice to the Administrator
and other officials  of  the U.S.  Environmental Protection Agency.
The Board is structured to provide a balanced expert assessment of
scientific matters  related to problems facing the Agency.   This
report has  not been  reviewed for  approval  by the  Agency;  and,
hence, the contents  of this report do not necessarily represent the
views and policies of the Environmental  Protection Agency or other
agencies in  the Federal Government.   Mention of trade  names  or
commercial products does not constitute a recommendation for use.

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                             ABSTRACT

     The Ecology  and Welfare  Subcommittee  of the  Relative Risk
Reduction Strategies Committee (RRRSC)  of the U.S.  Environmental
Protection  Agency's Science  Advisory  Board  (SAB)  reviewed  the
ecological  and welfare  components  of  the  Agency's  1987  report
entitled   "Unfinished   Business:   A   Comparative  Analysis   of
Environmental  Problems".   The  Subcommittee  was critical  of  the
original EPA ranking of  environmental  problem areas  that mixed
sources, receptors,  media,  and  specific  regulatory obligations,
since this  categorization reflected EPA programmatic  interests more
than  it provided a  rational basis for  evaluating  environmental
problems in the United  States.   In  addition,  some ecologically
significant problems that were outside of  EPA's regulatory purview
were  omitted.  The  Subcommittee was also  critical of  the welfare
effects analysis, finding it to be defined too narrowly

     The  Subcommittee  developed alternative methodologies  for
evaluating ecological and welfare risk assessments:  a) aggregation
of  related  EPA environmental  problem areas   into a more limited
number  of  categories and then ranking  those categories;  and b)
disaggregation of the initial EPA environmental problem areas into
environmentally-relevant categories of  stresses  and then ranking
those  categories.    The  ecological  problem  areas  that  were
consistently ranked  the  highest by  the  Subcommittee were habitat
alteration,  global  climate  change,  and  stratospheric  ozone
depletion.

     The Subcommittee developed six major  recommendations from its
review  of  the  Unfinished  Business  report:  a)  formalize  an
extramural   and   continuous   process   for   ecological   risk
prioritization; this process should not be categorized by Agency
programmatic structure but rather by anthropogenic stresses on the
environment; b) invest in development of  formal methodologies for
ecological  risk assessment;  c)  develop  the data bases needed for
improving   future  ecological  risk assessments;  d)  develop  an
appropriate  methodology  for integrating  ecological and economic
time  dimensions;  e) EPA  should give  more consideration to non-
economic  aspects  of ecological values  and  welfare risks;  f)
consider the results from this risk ranking process, including the
1990  risk reduction  study, in  development of  future Agency policy
and in  allocation of financial  resources.

      The Subcommittee reached a strong consensus that  the relative
risk  assessment  process  is a  good  mechanism to formulate public
policy from a scientific  base of data and mechanistic processes and
recommended that  the Agency institutionalize this  approach on  a
regular basis, providing the  trained personnel and scientific data-
bases needed to establish a scientific credibility for the process.

Key Words;   ecological  risk assessment;  risk reduction; welfare
               risk assessment

                                ii

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               U.S.  ENVIRONMENTAL PROTECTION AGENCY
                      SCIENCE ADVISORY BOARD
           RELATIVE  RISK REDUCTION STRATEGIES COMMITTEE

                 Ecology and Welfare Subcommittee
Chairman

Dr. William Cooper, Chairman, Zoology Department, Michigan State
     University, East Lansing, Michigan

Members

Dr. Yorum Cohen, Associate Professor of Chemical Engineering,
     University of California at Los Angeles, Los Angeles,
     California

Dr. Steven Eisenreich, Professor of Environmental Engineering,
     University of Minnesota, Minneapolis, Minnesota

Dr. Mark Harwell,  Director,  Global Environmental  Programs, Cornell
     University, Ithaca, New York

Dr. Dean Haynes, Professor of Entomology, Michigan State
     University, East Lansing, Michigan

Dr. Robert Huggett, Director, Virginia Institute of Marine Science,
     College of William and Mary, Seaford, Virginia

Dr. Ronald Olsen,  Professor of Microbiology and Associate Vice
     President for Research, University of Michigan Medical
     School, Ann Arbor, Michigan

Dr. David Reichle, Associate Director of Bioroedical and
     Environmental Sciences, Oak Ridge National Laboratory,
     Oak Ridge, Tennessee

Dr. June Lindstedt-Siva, Manager of Environmental Science, ARCO,
     Los Angeles,  California

Science Advisory Board Staff

Mr. Robert Flaak,  Acting Assistant Director, U.S. EPA, Science
     Advisory Board, Washington, DC
                               iii

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                        TABLE OF CONTENTS

1.0  EXECUTIVE SUMMARY  	    1

2.0  INTRODUCTION 	    5
     2.1  Background	    5
     2.2  Charge to the Ecology and Welfare Subcommittee  .  .    6
     2.3  Format of this Report	    6

3.0  ENVIRONMENTAL PROBLEM AREAS  	    9
     3.1  Limitations of EPA List of  Environmental  Problem
          Areas	    9
     3.2  Ranking of Aggregated Environmental Problem Areas  .   12
          3.2.1     Air Quality	12
          3.2.2     Surface Water	14
          3.2.3     Soil	14
          3.2.4     Habitat Alterations 	   14
          3.2.5     Groundwater	15
          3.2.6     Waste Sites	15
          3.2.7     Accidental Releases 	   15
          3.2.8     New Chemicals and New Technology  ....   15

4.0  ALTERNATIVE MODEL	16
     4.1  Summary of the Disaggregation Approach  	   16
     4.2  List of Environmental Stresses  Considered by the
          Subcommittee  	   17
     4.3  Ecological Risk Evaluations 	   17
          4.3.1     Ecosystem/Stress Response Matrix  ....   17
          4.3.2     Environmental Stress Rankings by Scale  .   20
          4.3.3     Environmental Stress Rankings by Medium .   22
          4.3.4     Ecological Recovery Times 	   22
     4.4  Summary of Ecological Risks 	   25

5.0  WELFARE RISK ANALYSIS	28
     5.1  Background	28
     5.2  Subcommittee Findings 	   28
          5.2.1     Critique of Appendix IV	29
          5.2.2     Sustainability	30
          5.2.3     willingness to Pay	31
          5.2.4     Multiplier Concept  	   32
     5.3  Welfare Risk Paradigm	33
          5.3.1     Ecological Quality  	   33
          5.3.2     Resource Sustainability 	   33
          5.3.3     Direct Effects - Economics  	   34
          5.3.4     Direct Effects - Non-Economic 	   34
     5.4  Welfare Risk Rankings of the Subcommittee	34

6.0  UPDATES ON RISK CATEGORIES	37
     6.1  Criteria and Toxic Air Pollutants	38
     6.2  Radiation from Sources Other than Indoor Radon  . .   39
     6.3  Stratospheric Ozone Depletion 	   40

                                iv

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     6.4  Global Climate Change 	  42
     6.5  Direct and Indirect Point Source Discharges to
          Surface Waters  	  45
     6.6  Non-Point Source Discharges to Surface Waters
          Plus In-Place Toxics in Sediments 	  46
     6.7  Contaminated Sludge 	  48
     6.8  Physical Alteration of Aquatic Habitats 	  49
     6.9  Active Hazardous Waste Sites  	  50
     6.10 Inactive Hazardous Waste Sites  	  51
     6.11 Municipal and Industrial Non-Hazardous Waste
          Sites	53
     6.12 Alteration and Disturbance of Terrestrial
          Habitats	55
     6.13 Accidental Releases of Toxics 	  56
     6.14 Oil Spills	57
     6.15 Underground Storage Tanks 	  58
     6.16 Groundwater Contamination 	  59
     6.17 Pesticides	60
     6.18 New Toxic Chemicals (Non-Pesticides)  	  61
     6.19 Biotechnology	62
     6.20 Plastic in the Marine Environment	65
     6.21 Biological Depletion and Extinctions  	  66
     6.22 Introduction of Biologic Species  	  67

7.0  RECOMMENDATIONS AND CONCLUSIONS  	  68

     REFERENCES CITED 	  71

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                          LIST OF TABLES
Table I        Developing a Hierarchy of Relative Risk ....  2
Table II       Assessing Welfare Risks 	  3
Table III      Original EPA List of Environmental
                    Problems	10
Table IV       Classification of Problem Areas Relative
                    to Size, Hazard, and Exposure  	 13
Table V        Ecological Risk Matrix	18
Table VI       List of Ecosystem Types	19
Table VII      Ranking of Ecological Risks Characterized
                    by Scale of Stress	21
Table VIII     Summary of Ecological Risk Rankings
                    (From Tables VII, IX, & X)	23
Table IX       Ranking of Ecological Risks Characterized
                    by Medium	24
Table X        Time for Ecological Recovery	26
Table XI       Integrated Welfare Rankings 	 36
                                VI

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                      1.0 EXECUTIVE SUMMARY
     This is the report of the Ecology and Welfare Subcommittee of
the Relative  Risk Reduction Strategies  Committee  (RRRSC)  of the
U.S.  Environmental  Protection Agency's  Science Advisory Board
(SAB) .   As  part  of the  overall  activities  of the  RRRSC,  the
Subcommittee reviewed the Agency's 1987 report entitled  "Unfinished
Business: A Comparative Analysis of Environmental Problems" (EPA,
1987a,b,c), hereinafter  referred to  as Unfinished  Business,  in
order to provide a peer-review  and update of  that document, develop
alternative methodologies for evaluating ecological  and welfare
risk assessments,  and combine  ecological and welfare rankings of
relative risk into a  single aggregate ranking.

     The   Subcommittee   members   were   unanimous   in   their
dissatisfaction with  the  original EPA list  of problem areas that
mixed   sources,   receptors,   media,   and   specific  regulatory
obligations (see Table III, page 10).   In the  Subcommittee's view,
this categorization  reflects EPA programmatic interests far more
than  it  provides  a  rational  basis   for   evaluating  national
environmental problems.   In addition, the Subcommittee identified
some significant environmental problems that were outside of EPA's
regulatory purview and that had been  excluded from the original
list of problem  areas (e.g.,  habitat alteration and depletion of
species).

     The Subcommittee strongly endorses the  use of a matrix of
ecological stress types  versus  ecosystem  types as  developed by
Harwell and Kelly (1986)  (see Table  VI,  page 19).  We utilized our
evaluations   of  the  intensity   of   potential   effects,   the
uncertainties of these estimates, the type of ecological responses,
and the time scales  for recovery following  removal  of the stress
as diagnostic parameters.  Once the  hierarchy  of relative risk was
established,  we aggregated the problem areas as to scale of stress
(local,  regional,   biosphere),   transport   media  (air,  water,
terrestrial),   and  recovery   time  (years,    decades,  centuries/
indefinite) (see Table I, next page).

     The ecological problem areas that we consistently ranked the
highest  were habitat  alteration ,  global  climate  chance,  and

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        Table I - Developing a Hierarchy of
                       Relative Risk
      Diagnostic Parameters
 Aggregated Problem Areas
    Intensity of Potential Effect*
    Uncertainties of these Estimates
    Type of Ecological Responses
    Time Scale for Recovery
        Following Removal of Stress
 Scale of Stress (local, regional
   biosphere)
 Transport Media (air, water,
   terrestrial)
• Recovery Time (years, decades,
   centuries/Indefinite)
stratospheric ozone depletion (see Table VIII, page 23) .  The time-
space dimensionality of all  three are similar.   The  ecological
impacts are locally, regionally, and globally distributed, and the
recovery times  are estimated to  be  up to centuries.   Ecological
systems are well adapted to recover from many types of stresses as
long  as  the  impacted  areas  are  patchy  in  distribution  and
asynchronous  in  time.    This  allows  for  genome  refugia  that
constitute sources  for recolonization  once the  stress is removed.
Loss  or disturbance  of  natural  habitats increases  the rate  of
biological  depletion, which  is  the  other problem  area of  high
concern.   The extinction  of  biologic  species  is an  irreversible
event  with  unknown,   but  long-term  impacts.   It  is  virtually
impossible to ensure  the survivorship  of  a species  if its habitat
cannot be protected.

     The Subcommittee ranked the problem areas of airborne toxics.
toxics  in  surface  waters,  and pesticides and herbicides  in the
second highest category of relative risk (see Table VIII, page 23).
We gave emphasis to toxic substances  (heavy metals  and organics)
that are transported  by air and water and may be bioaccumulated in
ecological  food chains.    Generally,  these stresses  do not cause
irreversible impacts, but they  do deplete  the  quality  of the
ecological  resources  and definitely interfere with the human uses
of specific populations.  The rapid transport processes in air and
the  large  number  of  point  and  non-point discharges  to surface
waters  generate local and regional  impacts.    The  recovery times
after the  sources  are removed are measured in multiple decades.

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     The Subcommittee discussed in depth the assessment of welfare
risks.  We felt that  the traditional practice  of discounting the
values of  impacts  in time makes no sense ecologically.  We defined
four  types  of  welfare  impacts:  ecological  quality,  resource
sustainabilitv.  direct  effects-economic,  and  direct effects-non
economic  (Table  II).  The ecological  impacts are mediated through
ecological processes  and, therefore,  the welfare  and ecological
rankings are similar.  The resource sustainability impacts involve
changes in the environment  that are irreversible or of very long
duration  relative to  human perspective.   Again,  the impacts are
often mediated through  ecological  processes and,  therefore, the
welfare rankings  are a  sub-set  of  the long-duration ecological
effects (this  includes the issue  of groundwater contamination).

         Table II - Assessing Welfare  Risks
  Types of Welfare Impacts
Ranked
        Definition
    Ecological Quality
        Indirect impacts on human* that result
        from a reduced quality of an
        environmental resource and decreased
        human utility (Reversible)
    Resource Sustainability
  yes
Irreversible losses of ecosystem
structure and functions, such as loss
of critical habitat or species extinctions
    Direct Effects - Economic
  no
Direct physical changes that cause
adverse economic Impacts on humans
other than health effects
    Direct Ef f ects-Non Economic
  yes
Primarily Involves social nuisances such
as odors, noise, and reduced visibility
     The  direct effects-economic risks could not be ranked as  the
data needed to perform a credible benefit/risk  analysis are  not
available.    The  Subcommittee  did  rank the direct  effects-non
economic   risks.     These  involve   noise,  odor,   vistas,   and
psychological  impacts that are not easily quantified and  for which
no environmental standards exist.

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     We  recognize that  the authority  to  implement  programs  to
address  the  environmental  problems   of   greatest  concern  is
distributed widely across  the  federal  and  state governments and,
thus, beyond the mandate of the U.S. EPA.  The Agency, however, is
the only Federal agency whose primary mission is to  "speak for the
environment."  The Agency must take an aggressive leadership role
in demonstrating to other governmental institutions the risks and
benefits of sound environmental planning and management.

     The  Subcommittee developed  six  major recommendations that
result from our review of the Unfinished Business report and from
our  present  evaluation  of  the environmental problems  that were
identified in Unfinished Business:

     a)    Formalize   an  extramural  and continuous  process  for
ecological  risk  prioritization;  this  process  should  not  be
categorized  by  Agency  programmatic  structure  but  rather  by
anthropogenic stresses on the environment.

     b)    Invest  in  development  of   formal  methodologies  for
ecological risk assessment.

     c)    Develop the  data bases needed  for  improving   future
ecological risk assessments.

     d)    Develop  an  appropriate methodology   for  integrating
ecological and economic  time dimensions.

     e)  EPA should give more consideration  to non-economic aspects
of ecological values  and welfare  risks.

     f)   Consider the results  from  this   risk  ranking process,
including the 1990 risk  reduction study, in development of  future
Agency policy and in  allocation of financial resources.

     The  Subcommittee  developed  a  strong consensus  that the
relative risk assessment process  is a  good mechanism  to formulate
public  policy  from  a  scientific base  of data  and mechanistic
processes.   We  recommend  that the Agency institutionalize this
approach on a regular basis, and provide the trained personnel and
scientific data-bases needed to establish a scientific credibility
for  the process.

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                         2.0 INTRODUCTION
2.1  Background

     In  its  1988 report  on  research strategies  for  the 1990's,
"Future  Risk",  the Science  Advisory Board recommended  that the
concept of risk reduction be used more broadly  in  EPA  (SAB, 1988).
As a follow-up to that report,  EPA Administrator William K. Reilly
requested that the  SAB bring its technical expertise to the task
of developing risk reduction  strategic options that will assist him
in  assessing possible  Agency  activities.   In response  to  this
request,  the SAB  formed  the Relative Risk  Reduction Strategies
Committee (RRRSC).

     A major portion of the RRRSC's work involves  consideration of
the 1987 EPA report "Unfinished Business:  A Comparative Assessment
of Environmental  Problems"  (EPA, 1987a,b,c).  This EPA document
reports on the findings of EPA senior staff who  evaluated more than
two  dozen  environmental   problems  in  terms  of   their  relative
environmental risks.   These problems were evaluated  within four
broad categories: cancer  risk, non-cancer health  risk, ecological
risk, and welfare risk.

     To   evaluate  these   issues,   the   RRRSC    formed   three
subcommittees.    The   Human  Health  Subcommittee   was formed  to
evaluate the  cancer and non-cancer health risks;  the Ecology and
Welfare  Subcommittee  was  formed  to  evaluate  the ecological and
welfare risks; and  the Strategic Options  Subcommittee was formed
to develop and evaluate risk reduction  strategies. The charge to
the SAB, through its RRRSC and  three associated subcommittees, was
to:

     a)  Provide  a  critical  review  of the "Unfinished Business"
report that reflects any significant  new information that bears on
the evaluation of the  risks associated with specific environmental
problems.

     b)  Provide,  to the  extent possible, merged evaluations of
cancer and non-cancer risks (i.e., health  risks) and of ecological
and welfare risks  (i.e.,  environmental risks).

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     c) Provide optional strategies for reducing major risks.

     d) Develop a long-term strategy for improving the methodology
for assessing and ranking risks to human health and the environment
and for assessing the alternative strategies that can reduce risks.

2.2  Charge to the Ecology and Wai far* aMbC9HunitttT

     This  document  was  prepared  by the  Ecology  and  Welfare
Subcommittee,  a  subcommittee  of  the  Relative  Risk  Reduction
Strategies Committee (RRRSC) of the U.S.  Environmental Protection
Agency's  (EPA) Science  Advisory  Board (SAB).  The  tasks taken on
by this Subcommittee were:  a)  to provide  a  peer review  of the
procedures  utilized  and  the  rankings  obtained  from  the  EPA
activities  in  1986-87  that  led  to the  EPA  report  entitled
"Unfinished Business:   A  Comparative  Assessment of Environmental
Problems";  b)  to  update  the  background  papers  presented  in
"Appendix III  -  Ecological Risk Work Group"  (of  the "Unfinished
Business" report) and re-evaluate the  ecological rankings based on
this new  information;  c)  to critique  the  procedures presented in
"Appendix  IV  -  Welfare  Risk Work Group"  (of the  "Unfinished
Business"  report) and  to  develop  an  alternative approach for
evaluating  welfare risks,  if possible;  and d)  to  combine the
ecological  and welfare rankings  of relative risk into  a single
aggregate ranking that could then be compared with the human health
rankings.

2.3  Format of this Report

     In addition  to  an Executive Summary,  an Introduction,  and a
list of cited References, this report contains five major sections.

     Section 3.0. Environmental Problem Areas, represents a further
aggregation of the programmatic  areas into eight general areas of
environmental  problems.   The Subcommittee members were unanimous
in their dissatisfaction with  the  original EPA list of problem
areas that mixed sources, receptors, media, and specific regulatory
obligations.    This  categorization  reflects  EPA  programmatic
interests more than it provides  a  rational basis  for evaluating
environmental  problems in  the United States.   In  addition,  it
omitted some problems of ecological  significance that were outside
of EPA's  regulatory purview.

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     As a first step beyond the 1986 procedures carried out by EPA,
the  Subcommittee  examined  the  original  31  EPA categories  of
environmental problem areas.  Some  of these were combined when we
felt there were no differences in ecological  risk  (e.g., municipal
and industrial non-hazardous waste sites); others were added when
an important ecological  risk was not covered in the 1987 EPA report
(e.g., alteration  and disturbance  of terrestrial  habitats).   The
second step was to combine the list of problem area categories into
eight functional groups  and to rank their relative  impacts in terms
of  the  potential  severity of the hazard  and spatial  extent  of
effects.

     Section 4.0. Ecological Risk Assessment Model, presents a very
different model  for producing ecological  risk  assessment.   This
approach follows that developed by  Harwell  and Kelly  (1986), which
was included  in Appendix III of the Unfinished Business report.
This model starts with the basic scientific understanding of stress
agents and ecological responses across the variety  of anthropogenic
activities, affecting the ecological  systems of the United States.
Several different scenarios  of risk rankings were  investigated.
These included the rankings based  on scale of stress  (ecosystem,
regional,  biosphere),   the   transport   media  (air,  water,   or
terrestrial),  and the  ecological recovery time  (years,  decades,
centuries, or nonrecovery time).  These detailed rankings provided
the basis  for a  summary ranking of  environmental  stresses  with
respect to ecological risk.

     Section 5.0.  Welfare Risk  Analysis,  critiques  the "Appendix
IV - Welfare Risk Assessment" and presents an  alternative paradigm.
Four classes  of welfare  impacts were identified:   Ecologically
Mediated; Resource Sustainability; Direct Effects - Economic;  and
Direct Effects -  Non-economic.   Rankings were produced for three
of  these  classes  of welfare effects.   The "Direct Effects  -
Economic" category requires specific economic data  that were not
available to the  Subcommittee.   Thus,  no attempt  was made by the
Subcommittee to develop an economic ranking.   A summary of welfare
risk rankings combining the aspects of the other three categories
was developed.

     Section 6.0,  Updates on  Risk  Categories, contains critiques
of the problem  areas, providing additional information to update
these topics.

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     Section 7.0.  Recommendations and Conclusions,  presents  six
major recommendations developed by the Subcommittee to assist the
Agency's capability to assess environmental risks.
                                 8

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                 3.0 ENVIRONMENTAL PROBLEM AREX8
3«1  Limitations of EPA List of Environmei

     The Subcommittee was asked to address the EPA-specified list
of the thirty-one environmental problem areas  (initially developed
for the EPA Comparative Risk Project - see Table III, page 10) in
order  for  its  results  to be  comparable with  other evaluations
(i.e., Human Health and Strategic Options  Subcommittees).  However,
it was clear to  the Subcommittee that the  listed  problem areas were
not categorized  in parallel,  and  that  the criteria for selecting
the items on the list were not primarily related  to potential types
of  environmental stresses.   Specifically,  these  listed  problem
areas are much more attuned to programmatic considerations within
EPA than  they are to  actual  environmental problems  in  the real
world.    For  instance,   waste sites  are  separated  into  four
categories  (active hazardous  sites,  inactive  hazardous Superfund
sites, non-hazardous municipal sites, and non-hazardous industrial
sites) ;  each category  is divided  based  more  on  how they  are
regulated within EPA than on the types of stresses they may impose
on the environment.  Furthermore,  the EPA list of problem areas is
inconsistent  with respect  to  the   level of  resolution of  the
classification.  For example,  one category includes all inputs to
estuaries,  coastal waters,  and oceans from all sources,  whereas
another  category consists only of  accidental  releases  from  oil
spills.

     Consequently,   individual  categories   of   the  thirty-one
environmental problem areas often contained many different types
of environmental stresses. For example,  EPA Environmental Problem
Area  1  includes  "criteria pollutants",  i.e.,   those  pollutants
identified  in  the Clean Air  Act  for which National  Ambient  Air
Quality  Standards  (NAAQS)  are  required (specifically,  sulfur
dioxide,  nitrogen  oxides,  ozone,   carbon  monoxide,  lead,  and
particulates).   The  types of  ecological  stresses associated with
this single  category vary widely,  from local-scale deposition of
a heavy metal, for which the primary concern  is ecological routes
to humans, to the  transboundary-scale problem of acid deposition,
which has  the  potential for  significant ecological  effects on
freshwater and terrestrial ecosystems involving pH stress, aluminum

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            Table III -  Original EPA  List of
               Environmental Problems
 1 - Criteria air pollutants from mobile & stationary sources; acid deposition
 2 - Hazardous/toxic air pollutants
 3 - Other air pollutants, (e.g., flourldes, total reduced sulfur)
 4 - Radon (Indoor pollution only)
 5 - Indoor air pollution (other than radon)
 6 - Radiation (other than radon)
 7 - Substances suspected of depleting stratospheric ozone layer
 8 - Carbon dioxide and global warming
 9 - Direct point-source discharges to surface waters - Industrial sources
10 - Indirect point-source discharges to surface waters - POTW's
11 - Non-point source discharges to surface water plus In-place
     toxics In sediments
12 - Contaminated sludge (Includes  municipal and scrubber sludges)
13 - Discharges to estuaries, coastal waters, and oceans from all sources
14 - Discharges to wetlands from all sources
15 - Drinking water at the tap (Includes chemicals, lead from
     pipe, biological contaminants, radiation, etc)
16- Active hazardous waste sites (Includes hazardous waste
     tanks, Inputs to groundwater and other media)
17 - Inactive hazardous waste sites (Includes Superfund, Inputs
     to groundwater and other media)
18 - Municipal non-hazardous waste sites (Inputs to groundwater & other media)
19 - Industrial non-hazardous waste sites (Includes utilities)
20 - Mining wastes  (e.g., oil and gas extraction wastes)
21 - Accidental releases of toxics (all media)
22 - Accidental releases from oil spills
23 - Releases from  storage tanks (Includes product & petroleum tanks)
24 - Other groundwater contamination (septic tanks, road salt, Injection wells)
25 - Pesticide residues on food eaten by humans or wildlife
26 - Application of pesticides (Includes risk to pesticide workers as
    consumers who apply pesticides)
27 - Other pesticide risks (leaching, run-off, air deposition from spraying)
28 - New toxic chemicals
29 - Biotechnology  (environmental releases of genetically altered organisms)
30 - Consumer product exposure
31 - Worker exposure to chemicals
Modified from: EPA Report "Unfinished Business: A Comparative Assessment
             of Environmental Problems" pages 10-11. (EPA, 1987a).
                                 10

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toxicity, changes  in  redox  potential,  enhanced susceptibility to
disease and pest infestations,  differential effects on competitive
interactions  in  ecological communities,  and  a host  of  other
problems.  Thus,  the  relative  risks to the environment from this
single category  would entail an amalgamation  of quite disparate
stresses,  spanning:   a)  many  spatial   scales  of the extent  of
exposure; b)  many different  levels of hazard to  ecological systems,
and c) many different  modes  of action for toxicity or other impacts
on ecological  systems.   It is inappropriate  to  assign  a single
level  of risk  to such  a  diversity of  environmental  stresses.
Moreover,  a  single value  assigned to  such  a broad  category  of
stresses does not provide  the  decision-maker with information on
the relative  importance  of the diversity of  stresses within the
category, unnecessarily losing much useful information that could
be derived from the environmental risk ranking process.

     Another difficulty with the  EPA problem area classification
is that  many  individual  types  of  environmental stresses  from
anthropogenic activities were categorized into more than one of the
thirty-one  environmental problem  areas.   As  one  example,  the
potential ecological impacts from xenobiotic organic chemicals that
are  toxic to biota  could be  associated  with the  EPA-listed
environmental problem areas 1,  2, 3,  9, 10, 11,  12, 16, 17, 18, 19,
20, 21,  22,  23,  24,  25,  27,  and  28  (see  Table III, page 10).
Because of this considerable degree of redundancy for a single type
of environmental stress across  the  EPA  categories  of environmental
problem  areas,  relative  ranking of  environmental risks  would  be
impossible without knowing the relative distribution across the
problem areas of the magnitudes of  the  stress.  Following the same
example,  if  it were determined that xenobiotic organic chemicals
are a major risk to the environment, do  all nineteen of the above
listed problem areas  rank high?

     We  decided  that  alternate approaches to  environmental risk
ranking  are  required.  Two tacks  were  taken:  1) aggregation  of
related EPA environmental problem areas into  a  more limited number
of categories,  followed  by ranking  of  those  categories  based on
Subcommittee-developed  criteria;   and  2)  disaggregation of  the
initial  EPA  environmental  problem areas, with addition  of other
stresses of  concern,  into  environmentally-relevant  categories of
stresses,  followed by  ranking of  the  new  categories  based  on
Subcommittee-developed criteria.  The first approach, discussed in
the following sections, has  the advantage of being directly related

                                11

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to the EPA list being considered by the Human Health and Strategic
Options Subcommittees.   The  second  approach,  detailed in Chapter
4, has  the advantage of allowing  examination of  relative risk
rankings established with regard to spatial scale, transport media,
or other criteria,  thereby preserving the considerable information
and expertise used to evaluate environmental risks.



     Although the  ranking  in the Unfinished  Business  report was
provided for all of the thirty-one problem areas,  it appears that
the differentiation in the ranking among various problem areas was
not  clearly  substantiated.     Consequently,   the  Subcommittee
aggregated the  problem areas into groups  based on the following
considerations:

     a)   the spatial extent of the area subjected to the stress;
     b)   the importance of the ecosystem that is actually affected
          within the stressed area;
     c)   the potential for the problem to cause ecological effects
          and the ecological response;
     d)   the intensity of exposure; and
     e)   the temporal dimension of both effects and the potential
          ecological recovery.

     Factors a)  and b)  were classified as global,  regional,  or
local in scale.   A higher priority was given  to  areas under the
global classification.   Factor  c) was  classified  as either high,
medium,  low,   or  unknown.    Finally,  factors d)  and  e)  were
classified as high, medium,  or  low.   For both factors c)  and d),
a higher priority was given to problem areas that were classified
as high.  The classification of  the problem areas according to the
above factors is given in Table IV  (see page 13).   The rationale
for the grouping of problem areas is given below, with the original
number of  the  related EPA environmental  problem  in parentheses.
Note that  some  problem areas (4,5,6,15,24,26,30 and  31)  are not
included since we did not consider them ecologically significant.

3.2.1     Air Quality  (Environmental Problems  1-3,7,8)

     Although one might be tempted to separate global warming (8)
and stratospheric  ozone  (7)  from criteria air pollutants (1) and
hazardous  air pollutants (2),  the fact  remains   that all of the

                                12

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  Table IV - Classification of Problem Areas
     Relative to Size, Hazard, and Exposure
Aggregated
Problem Areas
Air Quality
Surface Water
Soil
Phys. Alteration
Groundwater
Waste Sites
Accident. Release
New Chemicals &
New Technology
Original a
Problem Areas
1,2,3,7,8
9,10,11,20
12,25,27
13,14,20
23,29
16,17,18.19
21,22
28,29
Size
Global
Glob/Reg
Regional
Local
Local
Local
Local
?
b
Hazard
High
High
High
Low-HI
Low
Low
?
?
Exposure
High
High
High
N/A
Low
Low
Low/Hi
?
a This column lists the original problem areas as numbered in the
  "Unfinished Business Document: A Comparative Assessment of
  Environmental Problems". Note that problem areas 4,5,6,15,24,26,
  30 and 31 were not considered as having an ecological impact.
b Defined as the inherent ability to cause harm.
  N/A « Not applicable for this problem area
  ? » Unknown
                          13

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above are closely linked to emissions (3) from chemical processes,
energy  generation,   and non-stationary  sources.   For  example,
hydrocarbons  play   an   important   part   in  the  generation  of
atmospheric ozone and hydrogen peroxide as well as the generation
of sulfates and, thus,  acid rain.   Burning of fossil  fuels leads
not  only to the  increase  in  carbon dioxide levels  that affect
global warming but also  to the emission of non-methane hydrocarbons
that play an important  role in controlling the levels of criteria
pollutants.  Thus,  from the point of view of sources,  air quality
is a rational grouping that encompasses problem areas 1,2,3,7,& 8.

3.2.2     Surface Water (Environmental Problems 9-11.20)

     Environmental  problem  areas   9-11  include  direct  (9)  and
indirect  (10)  point and  non-point  (11)  discharges  to  surface
waters.  Problem area 20 (mining wastes) can also be considered as
a potential  contributor to surface water  contamination.   Thus,
areas 9-11 and a component of area  20 are best grouped under the
surface water category.

3.2.3     Soil (Environmental Problems 12.25.26)

     Problem areas  25 and 26 consider pesticides.  Since pesticides
are applied onto the  soil environment, the direct effect  is on soil
and  vegetation.   Subsequently, the  movement and accumulation of
pesticides through the  food chain are  important, and there can be
a significant  effect on  wildlife.   Contaminated  sludge  that is
disposed of or treated  in the soil  environment leads  to a direct
contamination of the soil  environment  and subsequent migration to
other systems (e.g.,  groundwater) .  Thus, from the viewpoint of the
environmental medium that  is directly  affected, Items 12, 25, and
26 should be classified as a single  category*

3.2.4     ffflfritflt Alterations  (Envirqnfflfrntfl1 Problems 13»14.20)

     Environmental problem areas 13 and 14 consider the  physical
alteration of aquatic habitats and are therefore grouped together.
Problem  area 20, which  is concerned with mining wastes,  could be
partially in this category given that mining activities  and mining
waste can  lead to  physical habitat  alteration.  Thus, regardless
of the affected media,  habitat  alteration should be considered as
a single group.

                                14

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3.2.5     Qroundvatar (Bnv^rpnm^ptal Problems 23.29)

     Problem areas 23 and  29  consider  release from storage tanks
and other  groundwater contamination sources.   Since groundvater
protection  is  the focus,  groundwater  should be the  category of
concern.

3.2.6     Waste Sites (BnvjT9nffl?Trtfll Problem Areas 16-19)

     Environmental problem areas 16-19 involve various  types of
waste sites and, thus, should be grouped under the same category.

3.2.7     Accidental Releases (Environmental Problem Areas 21.22)

     Accidental releases of toxics (21) and  oil  spills  (22)  are
both  in  the  category  of  accidental releases  and  should  be
considered under the same class.

3.2.8     New chemicals and New Technology (Environmental Problem
          Areas 28.29)

     Biotechnology  (29)  and the  category  of new  chemicals  (28)
represent new ventures that are designed  for the introduction of
new materials or chemicals.  Since there is a lack of information
regarding  the  potential effects from  these unknown  sources of
potential contaminants, problem  areas  28 and 29 are grouped into
a single problem area.  It  is important to note that although this
area was ranked lowest in priority, this was largely because of the
lack of knowledge about  this potential future problem area which
at  present hinders  a rational  ranking.   However,  in  order to
minimize future pollution  problems, an effort must be maintained
to  identify  potential ecological impacts that  may be associated
with new chemicals and processes whether chemical or biological.
                                15

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                     4.0 ALTERNATIVE MODEL
4.1  ymnparv of the Disacrcrreqation Approach
     The second approach that the Subcommittee used to improve the
environmental   risk    assessment   methodology   involved   the
disaggregation  of  the  EPA  environmental  problem  areas  into
environmentally relevant  stresses.   The Subcommittee  decided to
adopt the  approach developed by the  original  panel  of  outside
ecological experts convened during the initial EPA Comparative Risk
Project.  This panel met in October,  1986, and prepared a separate
report  (Harwell and Kelly, 1986;  also included in Appendix III of
the  "Unfinished  Business" Report (EPA,  1987b) ) that  detailed a
methodology  for  ecological   risk ranking.    Specifically,  that
original panel: 1)  considered the EPA list  of thirty-one problem
areas and  eliminated  areas  with no ecological  relevance (e.g.,
Problem  Area 4,  indoor  exposure to  radon);  2)   identified  and
categorized  specific  types  of  environmental  stresses  associated
with each environmental  problem area on the EPA list; 3) identified
additional environmental stresses that were not included in the EPA
list, including items  that may not presently be within EPA purview
for  regulation  or management; 4) developed a  list of ecological
systems categorized with respect to the nature of stress responses
or recovery; 5) developed  a matrix of environmental stresses versus
ecosystem  types,   with  each  cell  in  the  matrix containing an
evaluation of the  potential and magnitude of ecological effects and
recovery; and 6) utilizing this matrix and a set  of panel-developed
criteria discussed below,  ranked the list of environmental stresses
with respect to potential environmental risks.

     The  present  Subcommittee  adapted  the  previous  panel's
methodology   as   follows:  1)  modified  the   panel's  list  of
environmental stresses  with minor wording changes in the names of
a  few categories  (e.g.,  substitution of  hazardous in  place of
toxic)  and  the addition  of  one category (species depletion); 2)
reevaluated the potential ecological risk from each environmental
stress  (differentiated  across scales of stress  [local to global])
and  modified the  similar  matrix from the previous panel's report,
with attention  to new information or understanding not available
at the  time of  the 1986 deliberations; 3)  developed a new matrix

                                16

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of ecological risks  of  the environmental stresses differentiated
by transport medium (air, water, and terrestrial);  and 4) collapsed
these two  ecological risk  matrices  into a synthesis  ranking of
relative ecological risks from environmental stresses.

4.2  List of Environmental Stresses Considered by t^fif SMfrC^HUBJttTT

     The Subcommittee began with the list of environmental stresses
presented in Harwell and Kelly (1986).  The list was reconsidered
with respect to the need for wording changes as well as any missing
environmental stresses  that should be  added.  A revised list was
prepared by the Subcommittee;  this list can be directly related to
the original EPA list of thirty-one problem areas using the matrix
in  Table  V   (see  page   18).     This  matrix   indicates  those
environmental stresses  that were  not included in  the  EPA list of
problem  areas,  as  well as a few problem areas  that had  been
combined by EPA in the Unfinished Business Report.  The matrix also
separates the environmental stress agents by source.

4.3  Ecological Risk Evaluations

4.3.1     Ecosvstem/Stress  Response Matrix

     The panel of ecological experts  convened in 1986  (Harwell and
Kelly,  1986)  categorized ecosystems of interest  into ecosystem
types based on the potential for differences in ecosystem responses
or recovery from stress. This list of ecosystem types was accepted
by the Subcommittee without revision (Table VI,  see page 19).

     The potential for  ecological effects from each environmental
stress were estimated by  the  original  panel  of  experts using the
following factors  (Harwell  and Kelly, 1986):

     1)   The potential  intensity of ecological effects, evaluated
as high, medium, low, or no effect; this expert judgment estimation
was based in part on the background information provided by EPA to
the panel, but was primarily based on the expertise and experience
of the ecological panel.

     2)   The  nature of  the  ecological effect from  each specific
environmental stress,  categorized as:   a) potential  effects on
biotic  community structure, such  as alterations in  the trophic
structure,  changes in  species  diversity  or richness, or other

                                17

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         Table VI - List of Ecosystem Types
   Freshwater Ecosystems

   - buffered lakes
   - unbuffered lakes
   - buffered streams
   - unbuffered streams

   Terrestrial Ecosystems

   - coniferous forests
   - deciduous forests
   - grassland  ecosystems
   - desert & semi-arid ecosystems
   - alpine and tundra ecosystems
Marine and Estuarine Ecosystems

- coastal ecosystems
- open ocean ecosystems
- estuaries
Wetland Ecosystems

- buffered freshwater Isolated wetlands
- unbuffered freshwater Isolated wetlands
- freshwater flowing wetlands
- saltwater wetlands
community-level indicators of disturbance; b) potential effects on
ecological  processes,   such  as  changes  in  rates  of  primary
production, nutrient cycling,  decomposition,  and  other important
ecological processes;  c) potential effects  on individual species
of  particular direct  importance  to  humans,  e.g.,  species  with
particular aesthetic or economic value,  or endangered or threatened
species; and  d)  the potential for the  ecosystem to  function as a
vector for routes of exposure  to humans of chemicals or organisms
having potential health-effects  concerns.

     3) The degree of certainty associated with these estimations,
differentiating   those   circumstances  where   the   data   and
understanding are  sufficient for certain or probable  projections
to be made versus the situation of either poorly understood stress-
response  relationships  or  of  highly  infrequent  occurrence  of
adverse responses;  and

     4) The probable time scale for  recovery to  occur following
cessation of  the stress, estimated as  years,  decades,  centuries,
or indefinite time  for recovery.
                                19

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     In the original ecological  panel's  ranking,  a matrix of the
environmental stress agents  versus  ecosystem types was developed
with expert judgment on  each of  these four factors (intensity of
potential effects,  type of ecological response, uncertainties about
the estimate, and time scale for ecological recovery)  (Table 4 in
Harwell  and Kelly,  1986).   The  present  Subcommittee  did  not
reexamine every element in this matrix.  Rather, the Subcommittee
examined  the summary ranking (Table  7  in  Appendix  III  of  the
"Unfinished Business" Report) of the ecological stresses divided
by  spatial  scale  that  was developed  based  on  the  detailed
ecosystem/stress matrix.  The Subcommittee evaluated these rankings
with respect to  whether or not  the  Subcommittee  agreed with the
existing  ranking,  or  if new  information or understanding should
result in changes to the ranking.  The Subcommittee also expanded
the  ranking to  include a  category  of  low-impact effects  (not
included  in the original summary ranking).

4.3.2     Environmental Stress Rankings by Scale

     The  results  of  the  reevaluation by  the Subcommittee  are
presented  in Table VII   (see  page  21) .  This matrix  of rankings
separates the relative ecological importance of  each environmental
stress by the  scale of  the stresses  (biosphere/global; regional;
or ecosystem/local).  The Subcommittee changed this stress matrix
only modestly compared to the initial summary ranking in the 1986
report.   Specific  changes to be noted include:  1)  elevating the
issue  of  depletion of  stratospheric  ozone  from CFCs  and other
anthropogenic  chemicals   from   the  category  of  "unknown  but
potentially very  important"  to the  category of "high ecological
effects"; this elevation of concern  is because of the acquisition
in the  intervening three years  of  considerable information about
stratospheric  ozone  depletion   in   response  to  CFCs,  including
evidence, from data from Antarctica, of exceptionally intense ozone
hole  development  in  the austral  springs  of  1987 and  1989;  2)
addition  of  depletion of biotic  resources  to the "high" category
for regional scales because of an enhanced  concern for large-scale
human activities such as tropical deforestation; 3) decreasing the
importance  of  oil  and petroleum products  at the ecosystem level
from  "high"  to  "medium  ecological  importance"  to   reflect  a
moderated concern  about the ecological  effects of oil inputs to
the  environment;  4) addition of the category of "low  ecological
importance", to which were added stresses  of radionuclides, solid
wastes, and thermal pollution; this  addition was  done to  indicate

                                20

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that  these issues,  while of  limited concern  ecologically,  are
nevertheless  not   completely   free  of  potential  for  adverse
ecological  effects;   5)   changing  the  issues  of  groundwater
contamination and chlorination products from the "unknown" category
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deliberate release  of  genetically engineered  organisms,  in which
most  inputs  to  the  environment would  likely  have little  or no
effect, but the potential exists for some types of inputs to have
very  important  effects;  environmental stresses  in this category
would require case-by-case evaluation to  determine potential risks
to the environment.
4*3*3     Envir^fiifl^fltal stress Rankings by
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transport  media  (air,  water,  or  terrestrial).    That  is,  the
ecological risk ranking by spatial scale, discussed above,  was next
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agent rather than by spatial scale.   A new matrix of ecological
risk  rankings  (Table  IX,   see page  24)  was prepared  by  the
Subcommittee,  with the same elements  as  in the previous matrix.
This provides information about the relative ecological risks that
may be relevant to major  divisions within EPA.

4.3.4     Ecological Recovery Times

     The  ranking  of potential  effects  on ecosystems  from  the
ecological  stresses included   attention to the issue of  recovery

                                22

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times.  If a stress was considered to cause a very long-term effect
on an ecosystem, then  it  would  be  ranked higher than a stress to
which the ecosystem could recover more rapidly.  The Subcommittee
decided that  this information,   if  made more  explicit,  would be
useful to decision makers  in evaluating policy options, especially
if combined  with an estimate of the time scales that  could be
involved in implementing options.  Consequently, an ecological risk
ranking matrix was developed by the Subcommittee that indicates the
time for ecological recovery upon elimination of the stress (Table
X, see page 26).  This primarily relates to intrinsic time scales
of ecological  and biogeochemical systems.  For, instance,  a long
time for  recovery  from habitat  alteration is  indicated,  as major
changes to habitat structures  like  soils or  mature  tree  stands
require considerable time for the system to be reestablished at a
former state.  Other time lags for restoration of the environment
relate more to the societal  delays  in implementing control options
as well as the time for the stress to be  eliminated once the option
was implemented.   For  example,  there may  be a delay in recovery
from stratospheric ozone  depletion effects,  in part  because the
residence times in the  atmosphere of some CFCs  may be a century or
longer, so that  controls  implemented immediately may  not  become
effective for decades,  and in part because of delays in eliminating
CFC production and  emissions in all countries  around  the  world.
The combination of these factors (time lags intrinsic to stresses
involving  physical  systems,  time  lags  intrinsic to  ecological
responses to stress,  and time lags for implementation of societal
controls)  provides a rough estimate of the time scales that could
be involved in addressing and solving  each particular ecological
stress.

4.4

     The final ecological  risk ranking prepared  by the Subcommittee
is a synthesis of the  above matrices.   This ranking is provided
(Table  VIII,  see  page  23)  to  give  a  single  list  of  the
environmental  stresses, numbered in order of decreasing potential
ecological   risks.      The    synthesis   rankings  were   derived
qualitatively using expert judgment rather than a numerical metric
based on the more detailed risk matrices discussed previously, as
the Subcommittee decided  that any  specific quantitative or semi-
quantitative methodology for combining risks assigned across scales
and  media  (e.g.,  adding  the   total   number   of  cells  with  H
designations for each  stress)  would  not be not defensible with

                                25

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Table X - Time for Ecological Recovery
                       Increasing Recovery Tim*
Environmental Stress
i
j
•
a
«
1
(
i
!
l
t
m
9
•
5
m
1
1. Global Climate
Habitat Alteration
Stratospheric Ozone
Biological Depletion
2. Herbicides/Pesticides
3. Toxics In Surface Waters
Acid Deposition
Airborne Toxics
4. Nutrients
BOD
Turbidity
5. OH
Groundwater
6. Radlonuclldes
Acid Inputs to Surface Waters
Solid Wastes
Thermal Pollution
In some cases, High Risk:
Deliberate Release of
Genetically-engineered
organisms
Introduced Species
Short
(Years)








X
X
X
X



X
X
X

Medium
(Decades)

X


X
X
X
X





X
X


X
X
Long
(Centuries)
X
X
X
X








X




X
X
                    26

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present ecological  risk assessment  capabilities.    However,  the
synthesis ranking developed by the Subcommittee is not arbitrary,
but, rather,  is based  on  criteria of the  intensity,  magnitude,
duration,  and recovery prospects for each stress.  The Subcommittee
feels strongly that  a  concerted and continuous effort  by the Agency
to improve ecological  risk  assessment methodologies is warranted.

     The synthesis ranking in Table VIII (see page 23)  represents
the consensus  of the  Subcommittee and  illustrates  the  increased
concern given by  the  Subcommittee  to  those  issues of  largest
potential  spatial  extent  and  longest  potential recovery times.
Consequently, the environmental issues  of  global  climate change,
habitat alteration,  stratospheric ozone depletion,  and biological
depletion are ranked very high, because of the pervasive extent of
these environmental  stresses and the diversity of resultant impacts
on ecological systems at species,  community,  and  process.levels.
It is notable that not until the middle grouping of environmental
stresses  (2 and  3)  do toxic  chemical  stresses become ranked with
respect to  ecological risks.   It  should also be noted  that for
rankings 3-6, more than  one environmental stress is listed, as the
Subcommittee could not distinguish the ecological risks among the
stresses  listed  within a single  number  category.   The  last
category,  high risks  in some cases, is not ranked numerically, as
the potential exists in  infrequent  occasions  for these stresses to
cause  significant  adverse  ecological   effects   if  improperly
regulated, but under  other circumstances these stresses may cause
essentially no ecological effects.

     Finally, the Subcommittee recognizes that the highest ranked
ecological risks  do not reflect the present  emphasis within EPA
and,  indeed,  include  some  aspects  not  presently  within  the
legislative mandate of  the Agency  (especially issues of habitat
alteration,  for  which EPA's role  is  mostly  limited to  wetlands
ecosystems) .  Nevertheless, the Subcommittee believes  the synthesis
ranking of  ecological risks  represents  the  ecological  issues of
greatest potential danger to the environment of the United States
and of the Earth.
                                27

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                    5.0 WELFARE RISK XNXLYSIS
5.1  Background

     The  Subcommittee  was  charged  with three  specific  tasks
regarding welfare risks:  1) evaluate Appendix IV of the Unfinished
Business Report  (EPA,  1987c)  entitled "Welfare Risk Work Group";
2) develop a welfare  risk evaluation paradigm that is compatible
with the  ecological risk  evaluation system; and 3)  combine the
ecological and welfare  rankings into a combined priority array.

     The Subcommittee  is composed of  environmental  chemists and
ecologists.  There are no economists  on the Subcommittee, although
several were  consulted.   In the  Subcommittees view,  we  cannot
engineer the time lags in the geochemical  and ecological feed-back
loops.   Economic analyses should always reflect  a planning horizon
long enough to capture  all effects of the issue under study.  For
ecological issues, the  time frame may have to extend for hundreds
of years and many generations of humans.   If  one wishes to combine
ecological and welfare  impacts into an aggregate priority ranking
system, the methodology currently being utilized by the Agency to
quantify  economic  impacts  roust;   be  modified  to  resolve  this
discontinuity.
5.2  subco™1^ fc^ee Findings

     The  Subcommittee  finds: a)  that the EPA's  welfare effects
analysis  contained  in Appendix  IV,  Welfare  Risk Work  Group  of
Unfinished Business (EPA, 1987c) , was defined too narrowly within
the array of possible analytical alternatives and was too limited
to  economics;  b) that  many of the assumptions of  the economic
analyses  used  by EPA give  insufficient attention  to the current
state of scientific understanding; and c)  that some of the details
of  the economic  analyses presented  in the  Unfinished Business
document   were  incomplete   or  inappropriate   for  addressing
env i r onmenta 1 pr ob 1 ems .

     The  Subcommittee  began  the welfare ranking evaluation  by
redefining  welfare  effects  to  be  all  effects  on humans  and
societies, excluding human  health effects, that  may result from

                                28

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environmenta1 orob1ems.   Thus, welfare risk was expanded to include
all aspects of the  quality  of human life as interacting with the
environment.   These welfare  effects  may be  indirect  or direct.
Indirect  welfare  effects  include  those  effects  mediated  by
ecological systems; i.e., effects  on  humans caused by changes to
the natural environment.  These ecologically-mediated effects may
be  further  divided  into   impacts  that  involve  irreversible
alterations to the environment, and therefore,  fundamentally affect
resource sustainability  (e.g., loss of biodiversity, depletion of
soils, elimination of  habitats), and those alterations that are not
permanent  but, nevertheless,  have  an  impact on  parts of  the
environment that humans care about  (e.g., reduction in fisheries,
eutrophication  of  lakes,  reduced  growth  of  commercial  trees).
Direct welfare effects   include  those that have  direct economic
importance (e.g.,  building damage from acid deposition) and those
that are non-economic (e.g.,  presence  of  excessive  noise or odors,
reduced visibility, or  other  reductions  in the quality of life).

     The Subcommittee finds that the ranking for ecological risks
discussed  previously  and  for  welfare  risks  associated  with
ecologically-mediated  impacts are essentially  the  same.    The
welfare risks associated with sustainable resources were evaluated
by the Subcommittee.  The welfare risk ranking  for  direct economic
effects  was   not   developed   by  the  Subcommittee  because  of
insufficient data.  The ability of science to contribute  to the
ranking  of  non-economic effects  is  still  developing  and  the
Subcommittee made  an initial attempt at this ranking.  Finally, the
Subcommittee  developed   an  overall welfare  risk  ranking  scheme
considering all four aspects of welfare risks.

5.2.1     Critique cf Appendix IV

     The welfare effects analysis in Appendix  IV (EPA, 1987c) was
based on a very small amount of information that was available to
the Agency.  The analysts appeared to limit their  concern to only
a few of the services  produced by ecosystems, and ignored the more
complex and long-term interconnectedness of all living things on
earth.  It is imperative that the Agency adopt a broader and more
inclusive view  of ecosystem services and work to integrate this
view with economic analyses of environmental problems.
                                29

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5.2.2     attainability

     It  has   long  been   recognized  that   short-term  profit
maximization  is a  misguided  objective.    Economic analyses  of
environmental issues must take a long-term view with the ultimate
goal of  sustaining  life supporting ecosystem  functions.   In the
long  run,  irreversible   resource  damage   will   undermine  the
sustainability of the ecosystem and  therefore,  the quality of life
and the sustainability of human society itself.

     The  procedure  of  "...ranking  future  effects  lower  than
present, all else being held constant" (page 1-2,  EPA,  1987c),  is
not scientifically sound for ecological risks.   There are several
compelling  reasons  why   the   economic   discounting  theory  is
inappropriate  for  ecological   issues.    First,  the  concept  of
discounting values of ecological resources at some fractional rate
per year is inconsistent with  the "stewardship responsibilities"
(page 6-10, EPA,  1937c) emanating  from the  public  trust doctrine
approach to most environmental legislation.

     The concept and  application  of  discounting   needs further
examination.   In particular,  use of positive  discount  rates has
serious implications for intergenerational equity when applied to
long-time  frame problems.    Recognizing  the inability  of future
generations to  "vote"  in  current  capital markets  and   influence
interest  rates,  suggests  that  this   is  more  than an  economic
problem.   We  need to  address  the  scientific  and  ethical issues
associated  with  "sustainable"  social  activity.     For  inter-
generational issues it may  be appropriate  to adopt a zero discount
rate.

     Moreover,  discounting future  environmental  problems greatly
devalues the importance of  large-scale  and long-term environmental
problems.  Ecological systems have  intrinsic time lags,   such that
the adverse response from a stress is  delayed to the future.  This
is a basic characteristic of ecosystems that must be central to an
ecological risk assessment paradigm.   For  example,  applying the
discounting theory to  the  issue of  global climate  change led the
EPA welfare report to treat this as  a medium level problem because
the effects would not be felt until the middle of the next century.
Yet desirable and effective control and mitigation activities for
climate  change effects must begin much  sooner,  because  of the
inherent time  lags  in global responses.   The costs of .mitigation

                                30

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are usually not constant over time, often increasing geometrically
because of the spatial dimensionality of the transport mechanisms.

     Finally,  the applications  of  discount  rates  to  costs  and
benefits associated with the environment incorrectly implies that
ecological services can be readily exchanged, both now and in the
future,  as fundable  commodities.   Ecological  resources  provide
streams  of benefits  over time, and may therefore,  be considered
environmental  capital   analogous  to   physical  capital   (e.g.,
equipment  and  technology)  and human  capital  (e.g.,  knowledge and
skills).   Environmental  capital  and  the life-support services it
provides,  are  not,  however, necessarily substitutable  for other
forms of capital, and should not be  discouraged as  if they could
be bought  or sold like machinery or housing.

5.2.3     Willingness to Pay

     Most   economic   techniques   employed   in   environmental
assessments, management, and policy  formulation are based on the
assumption  that  individuals' tastes   and  preferences  are  the
appropriate  basis  of  economic  value.    This  premise  allows
economists to use market prices,  which reflect these preferences,
to estimate value.  When services provided by ecosystems  are not
traded on  markets, economists use alternative criteria of value,
such as individuals'   stated or implied willingness to pay for the
preservation of  an ecosystem  service  (or willingness  to accept
compensation of its loss).

     When it is applied to the valuation of ecosystem services, the
assumption that value derives  from  individual preferences may be
inconsistent with fundamental ecological principles.  Individuals
may enjoy the benefits of these services without any knowledge of
their existence,  thus their preferences may  imply values  that do
not reflect the ecological  importance  of  natural systems  and the
services they provide to humans.

     In addition, value  criteria may be problematic.   The use of
willingness to pay implies  that  values assigned by  an individual
are constrained by his or her affluence.  This may be inconsistent
with property rights vested  in public trusteeship and with public
rights of  access to  unimpaired  natural  resources  reflected in
Federal statutes: An Environmental Bill of Rights.
                                31

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     The basic  "services" provided  by the  ecosystem,  including
supply of  clean air  and  water,  food  chain  maintenance,  weather
control,   provision  of  genetic  diversity,  etc.,  represent  the
support system that all  humans depend on.   These resources need to
be protected from overexploitation.   Yet in managing the ecosystem
as  scarce  resources,  too  much emphasis  has  been  placed  on
willingness-to-pay   as   inferred  from  individual   actions   or
statements.  We  need to recognize that the services provided by the
ecosystem  are  complex and long  term.  We need to  develop  more
complete descriptions of the  ecology-economics  interface.  Not all
of these connections can be valued in dollar  terms.  Nevertheless,
information  about  these   connections and  services   need  to  be
presented  in a  form appropriate for analysis by  environmental
decision  makers.    These  representations  may not  fit into  the
traditional benefit-cost  framework.   Either  that  framework needs
to be expanded,  or the information, should be  presented in a manner
parallel to the benefit-cost framework.

     Furthermore, the reality  of "willingness  to  pay" is usually
not realized  until the right  to access is  removed  or seriously
threatened.   This is true in general for scarce  resources,  but
presents a severe problem  for environmental  issues.  By the point
in  time   at which  this  is   realized, it may  be  too late  or
excessively expensive to provide  for  the interconnectedness of the
environmental response.   Consequently, societal demands  for  the
expenditure  of  funds to  protect a   threatened resource  are  much
greater than to maintain an unthreatened one.

5.2.4     Multiplier Concept

     Economic impact analyses  normally include secondary impacts
that affect the supporting economic infrastructure.  When economic
analyses are utilized to justify  economic development, multipliers
are standard procedures.   If they are utilized on the development
side of the analysis, they must  be  utilized on the environmental
side as  well.   When the  James  River in  Virginia was  closed to
commercial   and   recreational   fishing    because   of   Kepone
contamination,  the   impacts   included the  losses  to  trucking
companies, fishing lure manufacturers, outboard motor  repair shops,
etc.  Thus, the  real costs are far greater than the direct monetary
value of the  fish harvest.  If economic analyses are included in
welfare impact  assessments,  the  real costs should be utilized to
illustrate the true  benefits of  environmental  stewardship.  Then,

                                32

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the benefits  of  major control and mitigation  efforts would more
often exceed the costs of program implementation.

5.3  Welfare Riafc Paradigm

     We propose an alternative welfare impact classification scheme
that  is  intellectually consistent with  ecological  functions and
time scales.  As defined above, the specific welfare impacts fall
into four classes:

          a)   Ecological quality
          b)   Resource sustainability
          c)   Direct effects - economic
          d)   Direct effects - non-economic

These are discussed  in further detail below  (See  also Table II,
page 3).

5.3.1     Ecological Quality

     This class  of effects are  indirect impacts on  humans that
result  from a reduced  quality of  an environmental  resource  or
decreased human utility, but  which  do not permanently impair the
ecological  structure and function of  the resource.   For example,
sublethal concentrations  of  PCBs  in Great  Lakes  salmon do not
impair  the  growth,  survivorship,   or reproduction  of  the  fish
stocks.   Yet a risk assessment action  level  of  2 ppm prohibits the
sale of  these fish  in  interstate  commerce, and public concerns
about these  contaminants in fish adversely affect the sport-fishing
industry.  Similarly, the recent Exxon Valdez oil spill in Prince
William  Sound,   Alaska,  produced  a  reduction  in  the  breeding
populations  of certain  sea  birds,   sea  otters,  and  intertidal
organisms.  But this  is expected to be a temporary loss  in resource
that will not threaten the  long-term  integrity of  the ecosystem.
Sublethal  accumulations  of  toxic  substances  and  intermittent
perturbations of the ecosystem structure  and function characterize
this category.

5.3.2     Resource attainability

     This category of welfare impacts involve irreversible losses
of ecosystem structure and functions.   These can involve losses of
                                33

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critical habitats  or species extinctions  resulting  from anthro-
pogenic activities. Wetlands destruction, soil erosion, conversion
of  tropical  rainforests  to  agriculture,  and  rising  sea  levels
illustrate these types of impacts.   Sustained  acute- or chronic-
exposure  levels  of  toxic  substances   to critical  classes  of
organisms can  also impair ecosystem functions.   Persistent non-
point agricultural inputs of herbicides into surface waters could
inhibit primary  productivity.    Increased UV-B radiation  from a
depleted stratospheric ozone  layer could  reduce algal productivity
in marine ecosystems.

5.3.3     Direct Effects - Economics

     This category involves  direct  physical  changes  that cause
adverse  economic  impacts  on  humans   (excluding  human  health
effects).   The monetary damages  to stone  structures resulting from
acid  rain,   the  loss  in  property  value  of houses with  radon
contamination, and loss of surface water contaminated  by industrial
effluents as an agricultural irrigation source are examples  of
direct physical effects  that have a  clear economic value.   These
are the effects that are usually  included  in environmental impact
analyses.

5.3.4     Direct Effects - Non-Economic

     This category of welfare  effects primarily  involves  social
nuisances.   Odors,  noise,  and  reduced  visibility  result  from
sensory modalities that  affect  the perception of  quality  of the
environment  but may or may not affect human health.  The courts
have upheld social  nuisance cases as legitimate examples of welfare
disbenefits.  There are no generally accepted standards that define
an acceptable  environmental  quality,  but liability is determined
on  a case-by-case  basis.   Odors from  animal  feedlots,  reduced
visibility in certain urban areas, and noise from truck traffic on
expressways  are documented examples of these social perceptions.

5.4  Welfare Risk  Rankings of the S^frcfrfflinit'tx

     The rankings  for welfare effects are  based on differing data
bases.   "Ecologically Mediated"  welfare  functions  are  based on
impacts on basic  population  and ecosystem processes.  Therefore,
we determined that ecologically-mediated  welfare risk rankings are
identical to those produced for the ecological effects, section.

                                34

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     The   welfare  risk   effects   associated   with  ecological
sustainable issues  involves  impacts on the  environment  that are
irreversible or of  long  duration compared to human perspectives.
The  Subcommittee  considered time  to  recovery  as  an  explicit
component of the rankings which are presented in Table XI  (see page
36) .

     The welfare  function  associated with the  "Direct Effects -
Economic" class of responses can be directly calculated by monetary
damages.  These data were not available to the Subcommittee, so no
rankings were possible for this welfare risk category.

     The  "Direct Effects  -   Non-Economic"  welfare  effects  were
ranked  by  the  Subcommittee  using expert judgment,  as  no other
analytical methodology presently exists.   We agreed that negative
impacts associated with sensory modalities (sound, sight,  or smell)
should be  included.  We  held diverse opinions  on whether and how
human  perceptions  and  feelings,   such   as  fear,  anxiety,  and
unrealized expectations,  should be included.

     The integrated welfare rankings are contained in  Table XI (see
page 36).
                                35

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     Table XI - Integrated Welfare Rankings*
RANKING
 WELFARE ISSUE
RECOVERY TIME
 HIGH:
Global Climate
UV-B Ozone Depletion
Habitat Alteration
Biologic Endangered/Extinct
     L
     L
     L
     L
 MEDIUM:
Acid Deposition
Airborne Toxics
Toxics in Surface Waters
Pesticides and Herbicides
Nutrients
Groundwater
     M
     M
     M
     M

     M
 LOW:
Acid Inputs to Surface Waters
BOD
Oil
Turbidity
Solid Waste (non-hazardous)
Radionuclides
Chlorination
Thermal Pollution
 IN SOME
 CASES,
 HIGH RISK:
Deliberate Release of Genetic
  Engineered Organisms
Introduced Species
 a For Categories I, II, IV - Based on non-direct economic Issues
 Recovery Time is given as long-term, or centuries (L); medium-term,
 or decades (M); or short-term, or years (S).
                              36

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                  6.0  UPDATES  ON RISK CATEGORIES
     The   Subcommittee   reviewed  the   original  EPA  .list   of
environmental problems (Table III, see page 10)) with the goal of
modifying the list if,  in our view, the list was either incomplete
or duplicative from an ecological  risk perspective.   We made the
following modifications.

     Problem  areas  18   and  19,  municipal and industrial  non-
hazardous waste sites, were combined.  Our review of the literature
led  to  the  conclusion   that   the ecological   impacts  are  not
significantly different.

     The  original EPA  list included  only one  type of  habitat
alteration, specifically areas 13 & 14, which dealt with discharges
(alteration) to aquatic habitats.  The Subcommittee believes that
ecological impacts caused by alteration of terrestrial habitats are
certainly  as  significant as alteration  of aquatic  habitats  and
should be  considered in  this  report,  even though  regulation of
activities  that  cause such  alteration   is  not presently  an  EPA
responsibility.     The  Subcommittee  also   considered  habitat
disturbance to  be a  potentially significant  ecological  impact.
Even  though  not  an  irreversible  physical  alteration,  habitat
disturbance by human activities (e.g., overflights,  human and dog
access to beaches)  can cause habitat abandonment or restricted use.

     The Subcommittee  added biological  depletion to  the  list of
environmental problem areas.  This category includes depletion of
natural populations because of over-harvesting as well as species
extinction.   Introduction of species  was also added to the list,
on the basis  that exotic species  may disrupt  natural communities
and ecosystems.

       The Subcommittee reviewed the Background Papers written by
EPA  in  1987  and  reevaluated   them in  light  of  more  recent
information.  These background papers were prepared by EPA in order
to provide additional insights concerning the environmental problem
areas.  These were included  in Appendix III of Unfinished Business
(EPA,  1987b).   The  following  sections  reflect  the Subcommittee
discussion of these  environmental  problem areas.  EPA summarized

                                37

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its ranking of environmental problems areas into six groups, with
Group 1 problems having the highest impact and Group 6 the lowest
impact.   The  EPA group  ranking and  our adjective  ranking  are
included  in  each section,  generally at  the  end.    Our rankings
follow the scheme given in Table VIII on page 23: (e.g., HHH > HH
> H > M > L)  where HHH - Highest Risk; HH * Higher Risk; H » High
Risk; M = Medium Risk; and L - Low Risk.

6.1  Criteria and Toxic Air Pollutants

     The ecological impacts of ozone and acid deposition are well
documented, and significant data bases on  both the extent of ozone
levels and acid deposition now exist  (HAS, 1989; NAPAP, 1989; EPA,
1988) .  The overview of ozone and acid deposition provided in EPA
(1987b)  is detailed and  represents  a reasonable summary  of  the
state of the art in 1986.  Since then there have been a number of
studies  (e.g.,  NAPAP,  1987)  that have suggested  that hydrogen
peroxide  is  also an  oxidant  that may  lead  to damage  to  trees.
Gaseous hydrogen peroxide is formed by photochemical reactions in
the  atmosphere,  and  its  chemistry  is  interlinked  with that of
ozone.   In addition,  the photochemical reactions of non-methane
hydrocarbons (NMHC), nitrogen oxides, ozone, and hydrogen peroxide
are linked and  affect the atmospheric concentrations of nitrogen
oxides,  ozone,  hydrogen peroxide, and the formation of airborne
strong acids.  Ozone and hydrogen peroxide are important oxidants
that lead to  the formation of nitric and sulfuric acids in rain and
cloud droplets from precursor nitrogen oxides and sulfur dioxide.

      The direct  ecological risks of all  toxic air  pollutants on
vegetative covers are not clearly established.  However, there is
little doubt that various toxic air  pollutants can  accumulate in
plants and animals through the food chain  (Travis and Arms, 1988).
Thus, effects on wildlife from bioaccumulation may be particularly
significant.   It is possible that some toxic air pollutants may be
precursors to chemicals that may be toxic to plants.  However, much
work  is  needed in this  area  in order to document  exposures and
elucidate uptake mechanisms and  associated ecological effects.

     Although toxic air pollutants were ranked by EPA as Group 4,
some chlorinated hydrocarbons play an important role  in atmospheric
photochemistry.   Thus,  while one can argue that  the  important
direct ecological  stresses are  ozone  and acid rain, the factors
controlling  the generation of those  stresses  are  closely linked

                                38

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and inseparable.  Nitrogen  oxides  are  also a factor in acid rain
formation as well as visibility reduction.  Since solar radiation
is an  important factor that affects the  generation of ozone and
hydrogen peroxide in the atmosphere, greenhouse gases and ozone can

affect solar radiation and in turn  photochemical reactions.  Thus,
problem areas 1,2,7, and 8 are intertwined.

     Our ranking of this  issue  varies  with the scale considered.
At ecosystem  and regional levels,  airborne  toxics  are high (HH)
risk, but at  the biosphere  level,  that risk drops to medium (M).
Acid deposition  is  ranked at high  (H)  risk at both ecosystem and
regional levels.

6.2  Radiation from Sources other  than Indoor Radon

     This category includes environmental  exposure to ionizing and
non-ionizing  radiation  (beyond natural  radiation).    Increased
radiation from stratospheric ozone depletion or medical exposures
is not included here.

     There  have  not  been  important  changes  in  either  the
information base, risk assessment,  or public  perception concerning
radiation hazards to ecological systems since publication of the
Unfinished  Business   report.    An  extensive  knowledge  base,
conservative  standards,   and a highly-regulated  industry  have
reduced environmental  risks.  Nuclear  industry practice is ALARA
(as low as reasonably achievable) for high-level wastes, oftentimes
well below regulatory guidelines.

     The largest sources of radiation are  natural  cosmic and earth
background radiations, followed by routine medical  and diagnostic
exposures  to  humans   but  not  the  environment.    Anthropogenic
environmental  exposures  primarily  result  from  residual weapons
testing fallout and  industrial releases (including  medical wastes).
Nuclear industry sources  include uranium mill tailings, enrichment
and  processing,  spent fuel  (fission products and  transuranics),
low-level operations, and research by-products.

     This  problem  area  is  characterized  by a  well-developed
historic  (and  aging)  literature  with  a  we11-developed  risk
methodology,  and extensive  standards  development and regulatory
oversight.   Environmental transport mechanisms and pathways are

                                39

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known;  biological/ecological  effects  are  organismally  based.
Current public  concern  is  over environmental  contamination and
perceived  human  health  risks,  with  contaminant  concern  over
environmental movement  and  remediation.   Ecological  effects are
minimal under current practice.  Regulatory philosophy holds that
protecting humans protects  the environment,  based on the general
greater radiosensitivity for humans than for other biota.

     The  Subcommittee  estimates that  ecological  risks  of  these
sources are  minor under  current practices,  with  relatively low
uncertainty  and  number of  unknowns.    Thus,  we disagree  with
Unfinished  Business  statements  of   uncertainty  for  ionizing
radiations.  Non-ionizing UV-B radiations are not addressed here
(see Stratospheric Ozone Depletion,  Section 6.3), and non-ionizing
electromagnetic radiations  have minimal (and  localized,  if any)
environmental effects.

     The Subcommittee agrees that the low ecological risk ranking
is appropriate.

6.3  stratospheric Ozone Depletion

     The  issue  of stratospheric ozone  depletion (problem area 7)
was reasonably  represented  in  the  issue  paper in  the EPA report,
although  a  number  of  developments   have   taken  place  in  the
intervening three years.  It is  still true that the main cause of
present and projected stratospheric ozone depletion is attributable
to production and release of chlorofluorocarbons  (CFCs)  (EPA and
UNEP, 1986; Hoffman,  1987).   Worldwide  emissions  of CFCs remain
substantial,  but  there  has   been   considerable  progress  in
establishing  future  limits internationally  on CFC  production,
beginning with the Montreal  Protocols of 1987 and continuing to the
commitments made  by  Europe and the  U.S.  in  1989 to phase out
virtually  all  CFC production  in the  next   few decades  (Wigley,
1988).  Consequently,  projections of future CFC emissions would be
reduced from projections made  three years ago  (Lashof and Tirpak,
1989; Smith and Tirpak,  1989).   On the  other  hand, not all nations
have  made  these phase-out commitments,  and  substantial inputs to
the atmosphere  will continue for some  time.   Further, there is a
significant time-lag between cessation of emissions and reductions
in atmospheric, especially stratospheric, concentrations.  Indeed,
residence  times  for  CFCs  are  typically measured in  decades or
longer, and stratospheric concentrations will continue to increase

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because of atmospheric dynamics even if all emissions were to cease
immediately (Lashof and Tirpak, 1989; Smith and Tirpak, 1989).

     Over  the  past  three  years,   there  is  also  an  improved
understanding of  the atmospheric chemistry of CFOstratospheric
ozone interactions.  For instance, the experience of  the very large
stratospheric ozone  depletion event over Antarctica  in  1987 and
1989  has  shown how  CFCs,  interacting  with  stratospheric  ice
crystals and with sunlight as it  first reaches the stratosphere in
the austral spring,  can very rapidly deplete stratospheric ozone
(Stolarski, 1988;  Rowland,  1988; Shea,  1989).   This ozone-hole
phenomenon did  not appear  in the earlier  models  of  atmospheric
chemistry,  but  has  now  been  seen  as  well  over the  Arctic.
Furthermore, estimations of columnar ozone depletion over the last
15 years or so now exceed 5%  for northern mid-latitudes,  somewhat
larger than the original EPA issue paper suggested.  Consequently,
there has been an increased sense of urgency added to this issue.
This urgency has been responsible for the progress noted above on
regulating global emissions of CFC's.

     With respect to potential effects of enhanced UV-B radiation
on biological systems at the  surface of Earth,  there continues to
be a very inadequate data base to evaluate effects.  We can state
with confidence that UV-B, in general, is biologically important,
as  it  is  strongly absorbed  by  biologically  critical  compounds
(e.g., DNA), and,  thus, like ionizing radiation,  has  the generic
potential  for  deleterious  effects  on   biota   (Worrest,  1985).
Experimental data on UV-B  effects show sensitivity for many marine
planktonic and  larval species,  and there  is a general consensus
that enhanced UV-B could lead  to adverse consequences on marine and
coastal  ecosystems  (Worrest, 1985;  Hoffman,   1987).    However,
experimental data on  UV-B  effects on most terrestrial plants are
lacking; for example, how enhanced UV-B would affect the trees in
a tropical rain  forest is  essentially unknown.   For crop plants,
about 200 cultivars have been  tested, for which  about one-third are
insensitive, and another third very sensitive, but experiments have
not been conducted  for many important crops (e.g.,  work has been
done on only a  very limited number  of cultivars of rice).  Thus,
assessing the potential biological consequences of  increased UV-B
is difficult at present,  although a research effort to obtain UV-
B dose  response data for  plants  of ecological  or agricultural
importance  would  reduce  those  uncertainties  readily and  with
limited expense.

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     Secondary and  indirect  effects  of increased UV-B are poorly
known? examples  of potential indirect  effects  include increased
susceptibility  to  disease   or  pests  by  terrestrial  plants.
Similarly, little is known about interactions of  enhanced UV-B with
other  concurrent  stresses,  such  as water  stress  from  climate
change.    Again,  an   experimental  program  could  reduce  these
uncertainties considerably.

     The  EPA  ecological  workgroup  ranked  stratospheric  ozone
depletion  as  being of  very  high  concern.   We  concur  with this
ranking because:  1) the mechanisms for  adverse biological effects
are common across biota;  2) the stress will be globally distributed
and, therefore,  something  to which  virtually all  ecosystems and
agricultural systems will be exposed;  3)  the time-frames  for the
stress on  the environment  are long (decades  to  centuries);  4)  it
is  not possible  to mitigate against  the ecological  effects  of
increased  UV-B; and 5)  it  may be difficult to adapt agricultural
systems to enhanced UV-B at the same time adjustments  are  to be
made for climate change  stresses.

6.4  Global Climate Change

     The issue of concern here relates to anthropogenic emissions
to  the  atmosphere  of  gases  that  have  radiatively  important
properties (i.e., they absorb light at wavelengths that control the
Earth's thermal balance).  Continuous rate of these emissions are
expected to lead  to a greenhouse response, with projected global
climate change  to occur over the  next  few decades at magnitudes
previously seen  only  over geological time frames  (Bolin  et al.,
1986) .  The EPA issue "CO2  and global warming" (problem area 8) is
more properly labeled "issues of global climate change",  because
C02 is only about  half  of  the present  contributor to equilibrium
temperature changes among anthropogenic emissions,  and because the
stresses   on  the   environment  of  ecological  and  agricultural
significance  are   not   limited  to  warming  (e.g.,  changes  in
precipitation  often  may  be  more  important  than  changes  in
temperature).

     Anthropogenic  sources of radiatively  important gases include
C02, primarily  from combustion  of  fossil  fuels,  but  also from
deforestation   and   cement   production;  CH4,    primarily   from
agricultural  production, especially from livestock and  in rice
paddies; N20, primarily from agricultural releases,  especially from

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bacterial action on  fertilizers;  and CFCs,  the sane compounds of
central concern to stratospheric ozone depletion (Keeling et al.,
1982; Bolin et al.,  1986;  Bolle et al.,  1986; Lashof and Tirpak,
1989;  Smith and Tirpak,  1989).   Insofar  as CFC  emissions  are
limited for ozone-depletion reasons, this will make a significant
difference to the eventual magnitudes and rates of climate change
over the next several decades (Wigley, 1988).  On the other hand,
even with  complete elimination of  CFCs,  C02  production globally
will continue to increase,  with the greatest growth in emissions
attributable to developing countries  (Lashof and Tirpak, 1989).

     Present  best  estimates of  globally  averaged  temperature
increases  at  equilibrium  are   between   1.5   and   4.5'C  for  an
effectively doubled  CO2 atmosphere  (i.e., with total radiatively
important gas concentrations increased to the  level equivalent to
doubling of C02 if that were the only radiatively important gas)
(NAS  (1979,  1983,  1987); Smith and Tirpak (1989);  Bolin  et  al.
(1986); MacCracken  and  Luther   (1985)).  While these numbers  are
useful for comparisons to paleoecological records or to compare the
relative effects of alternate strategies for  controlling greenhouse
effects, a  globally- and annually-averaged temperature increase
does not  capture the important  stresses  from an  ecological or
agricultural effects perspective.  Issues of spatial and temporal
scale  are  critical,  as are  issues of changes in  the frequency,
intensity,  or  duration  of  extreme events  (as  opposed  simply to
changes in averages).  That is,  what will have most importance to
causing  biological  effects will  be  climatic  extremes,  and  a
shifting climate,  even with  unchanged relative  variances,  will
likely lead to an  increase  in extreme events.  Moreover, whereas
the physical stresses of global  climate change will be distributed
globally (albeit not uniformly), the biological and human effects
will occur at local  and  regional  scales  and must be evaluated at
that scale  (Harwell et al., 1985a).

     The  present  scientific  consensus emerging  is that  global
climate change will  occur  in the next few decades; there is less
agreement that climate change has already occurred (data support
temperature  increases in  the   last  few decades  for the  entire
planet, but not  for the United States,  for example)  (Hansen and
Lebedeff,  1988;  Hanson et  al.,  1989; Jones  and  Parker,  1990).
Further,  even if  climate  change  is accepted  as  occurring at
present, there is   no consensus that such change can be causally
attributable to anthropogenic emissions or other human activities

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(e.g., Kerr, 1989).  Nevertheless, that climate change will occur
is widely,  although not universally supported  in the scientific
community.  How much climate will change, in what regions, and at
what  rate,  are issues  of  much less agreement,  and considerable
uncertainties  remain in  projections.    How general  circulation
models treat cloud  formation, atmospheric-ocean interactions, and
biological  feedbacks  (e.g.,  changes  in rates  of biogenic  gas
production, changes in  albedo,  and rates of evapotranspiration),
are  issues in  need of  considerable scientific  research (e.g.,
Robock,  1983;  Dickinson,  1986;  Hansen  et  al.,  1984;  Brpecker,
1987) .

     On the biological effects side, it is clear that temperature
is  not  the only,   or  often  even  the most   important,  stress
associated with global climate change.  Precipitation changes, in
intensity, location, and timing,  are much  more likely to affect,
for example, agricultural production than are increases in growing
season temperatures for many regions of the world (Parry et al.,
1988a,b).   Changing water relations, and the  effects of climate
change on hydrologic cycles,  could have a major  impact on regional
water  balances of  the  continents.   Other issues  of ecological
importance include sea-level  rise,  presently projected to be about
0.3  -  1.0 meter by the middle of  the  next  century,  from thermal
expansion of the oceans  (Smith and Tirpak, 1989;  Lashof and Tirpak,
1989).   Sea-level rise would have  major consequences on coastal
ecosystems, including wetlands, estuaries, and spawning grounds for
fisheries.  Other physical  stresses associated with global climate
change  may include changes   in  the  frequency  and  intensity of
storms, shifts  in ocean currents  and upwelling areas, and shifts
in the intra-tropical convergence zone and in patterns of monsoonal
development, among  others.

     Estimating biological effects can be done  by using a  range of
analytical  methodologies  to  relate  changes  in  the  physical
environment  with  crop   productivity  as  well   as  ecosystem
distribution.  Available methods include historical analogs (e.g.,
Stommel  and Stommel, 1979);  statistical models (e.g.,  Uchijima,
1981); physiological experiments (e.g., Uchijima,  1982); life zone
classifications   (e.g.,   Emanuel  et  al.,  1985);  paleoecological
records  (e.g.,  Davis and Botkin,  1985); simulation models (e.g.,
Harwell  et  al.,  1985b),  and  expert  judgment.   For  example,
physiologically  based  crop   simulation models can  be  used to
estimate how changes in climate will affect phenology  and  yield of

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particular crops  at specific locations.   Equilibrium ecological
effects  can  be  estimated  from paleoecological  analogs  and  by
examining bioclimatic life zone  shifts,  with associated changes in
the distributions of biomes.  But much research on effects remains
to be done, including some experimental (e.g., how crop yields or
ecosystem  productivity  would change  in combinations of altered
climate  and  enriched C02  - see  review  in  Idso,  1989) ,  and other
more theoretical research (e.g., model development and sensitivity
analyses).

     Effects of global  climate  change  are only broadly estimated
at present.  This  is an area of particular  importance and relevance
to EPA.  Indeed,  in the  growing  national program on global climate
change, effects issues appear to be given insufficient attention,
yet  it  is  the effects  on  ecological,  agricultural,  and human
systems  that are  of real concern and that must  be understood in
order for policy  options  to be  properly evaluated.   The issue of
global climate change was  given the  highest ranking by the EPA
ecological workgroup.  We concur with that ranking because: 1) the
potential for biological effects is so  large and ubiquitous since
the physical climate has  such an important control on ecological
systems as well as crop productivity; 2) the time-lags built into
atmospheric, oceanic,  and  biospheric   systems are so  long  that
actions today will have consequences for decades  to come; 3) it is
not possible  to  mitigate  against  climate change  occurring  from
gases that have already been emitted to the  atmosphere; 4) it is
possible  to mitigate against  the  effects   of  climate  change,
especially for agricultural and  societal systems,  but a much better
understanding of the spatial and temporal distribution of climate
change and a  much better understanding of the environmental and
human  effects  of  climate  change  are essential  before  proper
mitigation can be designed;  and 5)  with appropriate attention by
EPA  to  biological  effects  issues,  a  critically  important  but
otherwise insufficiently addressed facet of the global  change issue
can be significantly advanced.

6.5  Direct and Indirect Point Source Discharges  to Surface Waters

     Direct and indirect point source discharges  commonly refer to
the discharge of pollutants to  surface waters from publicly-owned
waste treatment facilities (POTW)  (15,000)  and industrial outfalls
(24,000)   (EPA,  1987b).   These  discharges  are regulated  by EPA
through a permit  system (National Pollutant Discharge Elimination

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System, NPDES) that allows release of both conventional and toxic
pollutants at specified levels.  Dischargers are clustered in the
eastern and midwest regions,  where human and industrial activities
dependent on aquatic resources are most dense (EPA, 1987b).  Many
industrial operations  contribute to the  load  reaching municipal
waste treatment facilities, and therefore,  are indirect dischargers
to aquatic systems.  Waste  treatment facilities discharge mainly
to  rivers   (except  in   coastal  zones)   experiencing  seasonal
fluctuations  in  flow.   Low  flow in receiving  water  (e.g.,  late
summer; drought  periods)  often  leads  to high  concentrations  in
water and potentially deleterious impacts on the  aquatic ecosystem.
Conventional  pollutants  of  major  concern  are  BOD  (biochemical
oxygen  demand),  suspended  solids   (SS),  and   nutrients  (P  in
freshwaters; N in estuarine waters).  The  latter lead to excessive
growth of undesirable algae and  aquatic plants.  Toxic pollutants
include trace metals (e.g., Cu,  Cd,  Cr, Hg) and organic compounds
(PCBs, phenols, etc.).   Most current requirements for controlling
discharges are technology-based  rather than  water quality-based,
although  there   is  a  trend  toward  more  water-quality-based
regulations.

     Although  strategies  to  limit  discharge  of  conventional
pollutants are  improving,  removal  of  toxic chemicals  requires a
fully-implemented industrial pre-treatment program.  Point-source
discharges also  include  combined sewer  overflows.   Many  of the
industrialized cities of the eastern and central states are moving
to separate municipal waste and  urban runoff.

     We recommend that  a  wider variety  of  chemicals than presently
are regulated be monitored in both discharges and receiving waters.
In addition,  a clear  understanding  of the ecological  impact  of
municipal and  industrial discharges  is badly  needed.   EPA ranked
this issue in Group 3.

6.6  Non-Point Source  Discharges to Surface  Waters Plus In-Place
Toxics in Sediments

     The  EPA  document  (EPA,   1987b)  states  that  "the  major
ecological    risk   from    non-point    sources    is    ...agri-
cultural. ..erosion".  Non-point source pollutant inputs to surface
waters, however,  also  include erosion from  other sources (e.g.,
silviculture,   mining),   groundwater   transport,   atmospheric
deposition, urban runoff,  and resuspension/recycling of in-place

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pollutants.  The best known of these inputs is erosion of surface
soils resulting from land disturbance by agriculture, development,
and natural processes  (e.g.,  hurricanes;  flooding).  Groundwater
contaminated by pollution activities on land may contribute to the
pollutant  load of  nearby surface  waters.    In  Switzerland  and
Germany, there are  many  examples  of surface waters contaminating
local  groundwaters  through  bank  infiltration.   The problem  of
atmospheric deposition of toxic elements and chemicals to aquatic
ecosystems has been emphasized by  the role the atmospheric pathway
plays  in the  Great  Lakes.  In general, the  processes leading to
removal  of contaminants  from the  atmosphere  and  the  air-water
exchange of volatile species  are  not  well understood (Eisenreich
et al., 1981;  Strachan and Eisenreich, 1988).   The importance of
atmospheric deposition to pollution inputs in other aquatic systems
such as Chesapeake Bay needs to be studied.

     The most severe problems associated with in-place pollutants
occur  in bay  and harbors that have received extensive  inputs of
particle-reactive  organic compounds  and  toxic  metals.    These
pollutants continue to recycle in the ecosystem by natural (e.g.,
bioturbation; winds) and anthropogenic processes  (e.g.,  dredging;
ship traffic; continued inputs) for decades and longer.   Examples
of areas where in-place pollutants are a particular problem are New
Bedford  Harbor,  Waukegon  Harbor, Fox  River/Green  Bay,  Toronto
Harbor, Los Angeles  Bight, and Long Island Sound.   However, rivers,
lakes,  estuaries,  and coastal  waters where sediment deposition
accumulates,  and  near  urban/industrial  centers,  have  bottom
sediments with measurable quantities  of  toxic  metals and organic
compounds.  Even at low concentrations,  some  chemicals  may move
into benthic organisms  and concentrate in the food  chain.  Although
most  interest  has  been in protecting health of  humans  consuming
fish from contaminated areas,  more attention must  be placed on the
interaction of benthic organisms with in-place pollutants.

     Control of non-point sources of  pollutant inputs to surface
waters may be difficult and expensive.  In the case of atmospheric
transport and deposition of pollutants, sources are often diffuse,
distant,  and  uncontrolled  or  unidentified.   The  Subcommittee
expands  the  scope  of  concern  beyond the  Unfinished  Business
document to include the  above and agrees with a  Group  3 or high
ranking.   For  the  special  case  of  pollutant  emission to  the
atmosphere,  and  then   transport  over   long   distances  before
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deposition, the Subcommittee ranks this problem high on a regional
scale, and medium on a global scale.
6.7  77in^pinate
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     The Subcommittee agrees with the basic risk ranking for sludge
of low to medium, depending on the area being exposed.  Localized
impact can  be much  greater (e.g., the  12  Mile Dump  Site),  but
relative to such issues  as global climate  change,  it  does  not
warrant a high ranking.

6.8  Physical Alteration of Aquatic Habitats

     Although current environmental laws require  mitigation  and
enforcement to compensate for wetland destruction for some federal
programs, a majority  of  the  habitat  loss  in the United States
results  from  currently  unregulated  activities  or  processes.
Channelization   and   drainage   for   agricultural   production,
impoundments  of  total wetlands  for private  use,  erosion-caused
sedimentation  of   stream  habitats,   destruction   of   riparian
communities  by  animal grazing, and bulkheading and  filling  for
shoreline development  are  all  prime examples of poorly regulated
activities leading to wetland destruction.

     Many of these  activities  are associated  with  agricultural
practices throughout  the  country  or  with  coastal  developments
associated with urban expansion.  Activities on public lands should
be required to abide by sound environmental practices, independent
of which agency has the administrative responsibility.

     Although the  impacts  of  any  single  activity  are  local,  the
activities are common  throughout  the country and the impacts  are
cumulative.   The aggregate impacts amount to an unacceptable loss
of ecological resources, and the irreversible nature of the impacts
on biological  diversity and  ecological  productivity  requires  a
major programmatic emphasis across all governmental organizations.

     Several  specific activities warrant  special  attention.
Draining and filling of isolated freshwater wetlands by agriculture
should demand the same regulations as those required of the Federal
Department  of  Transportation.    Public construction  grants  that
support  infrastructure development  (e.g.,  roads, sewers,  water
supplies, and power networks) should not provide support in coastal
areas characterized by tidal marshes and coastal estuaries.  Local
zoning ordinances cannot be expected to  protect priority aquatic
habitats  once the   infrastructure  is  constructed.    Commercial
fisheries operations using throw nets or trawls physically impact
benthic  habitats.    These  activities  should be  restricted  from

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critical areas.  Animal grazing needs to be regulated on riverine
communities along rivers, streams, and pocket wetlands.

     A viable  aquatic  habitat includes a  diverse  and productive
terrestrial  community   adjacent   to   the  land-water  boundary.
Sedimentation  control  is likewise  required to  protect  riverine
habitats.   EPA should adopt  and  enforce  a  watershed management
paradigm for aquatic habitat protection.  This regulatory approach
should  be  implemented  by  all  federal  organizations that  have
managerial responsibilities for public lands.

     The Unfinished Business report ranks this irreversible trend
in habitat  destruction  in  Group  2.   For the above  reasons,  we
concur with this emphasis on aquatic habitat loss.

6.9  Active Hazardous Waste Sites

     The Unfinished  Business  report ranks active hazardous waste
sites in Category 6  (low risk).  The Subcommittee challenges this
conclusion based on  future  trends and  not on current data.  This
category  includes  the  operations of incinerators,  land disposal
facilities, recycling units, and other chemical/physical/biological
treatment technologies.

     The locations of  these operations are usually a function of
source location and can be  found  in a wide array of environmental
settings.   These  facilities require the transportation,  storage,
transformation, and  disposal  of  a  great variety  of  organic and
inorganic toxic  substances  and pathogens.   These  materials come
from  chemical  industries,  defense industries,  municipalities,
medical industries, and  agribusiness.

     The  assumptions in  the Unfinished Business Report  are that
active hazardous waste  sites are currently regulated by RCRA/CERCLA
and,  therefore,  are or  will  be  well  designed,  constructed, and
managed.  Environmental  releases  of vapors to the atmosphere and
leachates to the surface and groundwaters are expected to   be low,
and  the effects limited to local  impacts.   These  are  the same
assumptions  that  were  made for the last  generation of permitted
hazardous waste sites with obvious shortcomings.  These sites were
permitted by State and Federal agencies with the full expectation
that the technologies would  be adequate to protect the  environment.
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     Active hazardous waste sites are not environmentally benign,
and there   still exists a number of  important scientific issues
that  are  not   well   understood and  documented  that  produce
significant uncertainties about  many  of these technologies.   The
perception that leachates only migrate slowly through the saturated
zone of the soil has been challenged by recent research at the  Oak
Ridge National Laboratory.   Episodic events  of heavy rains produce
rapid horizontal migration  of toxicants through  the  unsaturated
zone, resulting  in increased  loadings to surface  wetlands.   Clay
liners and clay  caps on  landfills with backup leachate collection
systems are designed to prevent and  remove leachates.  It took two
decades for the failures of our last  generation  of  landfills to
present  themselves.    Few,  if  any,  of  the  new generation  of
engineered landfills have been operating long enough  to document
the real performance with field data.   Usually the weakest link is
the management after a  routine pattern of operation has developed.

     The  controversies  surrounding  incinerators are  far  from
resolved.  The chemistry of  combustion associated with large-scale
incinerators receiving a feedstock flow of variable quality is not
well known.  It was only in  the last decade  that we associated the
formation of chlorinated dioxins with thermal treatment.  Many of
the residuals from incinerators  are discharged directly into the
atmosphere, which increases the spatial scale of dispersion.

     The EPA Unfinished  Business Report characterizes the impacts
as  localized  and potentially  reversible over a  10-year  period.
This conclusion is not  supportable.  The wide distribution of sites
produce a  cumulative pattern  whose impacts are not  local.   The
reversibility of impacts from resilient toxic compounds in soils
and groundwater  requires far more than 10 years.

     We recommend that this category be given the same rank (i.e.
Group 5) as the other toxic  waste stream categories instead of the
Group 6 ranking  given to it in Unfinished Business.

6.10 Inactive Hazardous Waste  sites

     Past disposal practices  for hazardous  waste  often met legal
requirements at the time, but  the resulting  contaminated soils and
groundwater and  air emissions  have become a major concern for the
present and future.  The primary focus of  this concern is on the
substances released from these sites that could impact humans via

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surface water, groundwater, or air.  Less attention has been paid
to the ecological impacts of such releases.

     At the time Unfinished Business was written  (EPA, 1987a,b,c),
there were 888 sites on the National Priority List  (NPL).  Ground-
water contamination was found at approximately 75%  of those sites,
surface water contamination at 45%.  A survey of 540 sites listed
the 15 most  frequently observed chemicals  as  TCE,  lead,  toluene,
chromium  and compounds,  benzene,  chloroform, PCBs,  tetrachlor-
ethane,  trichloroethane,  zinc  and compounds, arsenic,  cadmium,
phenol, ethylbenzene, and xylene (EPA, 1987a).  There are now 1,175
NPL sites, and EPA estimates that there will be more than 2,100 by
the year 2000 (Lucero and Moertl, 1989).

     Hazardous  wastes  account  for  approximately  20%  of  all
industrial wastes and  are  produced by  virtually  every  type  of
manufacturer (Paisecki and Davis, 1987).  Further, chemicals in the
waste do not  remain  fixed where they  are deposited.  Some wastes
have  appreciable  vapor  pressure  or  are  gaseous  at  ambient
temperatures  (e.g.,  vinyl chloride trapped in PVC  processes)  and
will diffuse  through fill,  appearing  in  ambient  air at the site.
Chemicals  can  often   leach  into  underlying  aquifers  and  be
transported  via  groundwater flow.  Contaminated groundwater may
eventually feed surface waters, contaminating streams and lakes or,
possibly, nearshore  marine habitats (Peirce and Vesilind, 1981).

     Nearly all chemicals found at inactive waste  sites are toxic
and known to have chronic or acute effects  on organisms.  However,
there are limited data  on the concentration of the substances and
the exposures that animals and plants experience.  Although there
is little information  on  ecological effects at Superfund sites, a
survey  estimated that  6% of the  NPL sites  are  likely  to  have
significant damage to natural resources such that natural resource
damage awards are likely to be sought under CERCLA  (EPA, 1987a,b).

     There could be significant ecological impacts  if toxic and
persistent chemicals (e.g., PCBs) contaminate  sediments in aquatic
habitats  (e.g., harbors,  wetlands).  This scenario sets the stage
for long-term exposure  of organisms, particularly  the benthos.

     Hazardous waste generators  are facing  a shortage of existing
landfill capacity, which has a projected lifespan of 10 to  15 years
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unless something is done to decrease the amount of waste  (Nelson-
Horchler, 1988).

     EPA  placed this  category  in Group  5.   The  Subcommittee
currently ranks the ecological risk from inactive hazardous waste
sites as medium (M) because ecological impacts tend to be localized
in the  immediate vicinity of  the  site.   However, the number of
known sites  and their potential to release  toxic and persistent
compounds into the environment  are of sufficient concern to warrant
close and continuing attention to this problem from an ecological
as well as human health perspective.

6.11 Municipal and Industrial Non-Hazardous Waste Sites

     Some non-hazardous waste  landfills contain only municipal or
industrial wastes,  and some contain  wastes  contributed  by both
groups,  in varying amounts.  The Subcommittee believes that, from
an ecological  standpoint,  these  waste  sites should be considered
together.  Non-hazardous waste landfills will eventually generate
leachate  and gaseous releases  (Charnley  et  al.,  1988;  Webster,
1988).   Releases from these landfills may be to  the atmosphere,
soils, groundwater, and surface water.   Potential effects are to
biota as well as human health.

     Inputs  to  municipal  waste sites  include paper,  yard wastes,
food, plastics, metals,  glass,  textiles, wood, and a miscellaneous
category that can include chlorinated organics (e.g.,  from cleaning
fluids)  and  aromatics (e.g., from paints and  household products).
(Webster, 1988;  Franklin  Associates,  1988).   Releases from these
landfills   may  vary,  but Wood  and  Porter  (1986)  identified 77
chemicals known to be  released  from municipal waste landfills,
including methane,  benzene,  toluene, vinyl  chloride,  trichloro-
ethylene, and methylethyIketone.

     Industrial   non-hazardous  waste   sites  usually   contain
substances specific to  a  particular  operation and may be located
on an industrial facility  site or  at  a site that combines wastes
from  a  number  of  different industrial  contributors.   Examples
include  wastes  from  building demolition,   phosphate  fertilizer
manufacturing, or oil-drilling operations.   Landfarming has been
extensively  used for some  of  these  wastes  (Huddleston  et al.,
1982).
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     It is  not possible to predict  how long it will  take  for a
particular  landfill  to stabilize to  the point where  it  will no
longer produce and release products.   However, Charnley  et al.
(1988) cite a  report by Pohland et al.  (1983)  which describes 5
stages in the life  of a landfill.  Each stage yields characteristic
compounds that are released to the air or to leachate.

     Stage  1.   Initial Adjustment - This stage occurs after the
refuse is placed in  the  landfill  until it has absorbed moisture.
Little, if any  leachate is formed during this stage,   stegen et al.
(1987) estimated that this stage takes 6-18 months.

     Stage  2.    Transition  -  During this  stage the  refuse has
absorbed  moisture  and  begins  to  form  leachate.    Microbial
degradation changes from aerobic to anaerobic.

     Stage 3.   Acid Formation - Anaerobic degradation continues and
volatile organic acids reach their highest concentration.  The pH
declines rapidly.

     Stage  4.   Methane Fermentation  -  The  intermediate products
formed in stage 3 are converted to methane and CO2.   The pH of the
refuse is buffered by a bicarbonate system.  The  amount of leachate
decreases, but the amount of gas produced increases.

     Stage 5.  Final Maturation - Microbial action is  limited due
to decreased availability of nutrients.  Gas production ceases and
oxygen and oxidized species  slowly reappear.   Compounds resistant
to  microbial   digestion  are converted to  humic-like substances
capable of complexing with and mobilizing heavy metals.  When the
rate of change within  the waste becomes negligible, the landfill
is considered  stabilized.

     Releases from landfills that contain only municipal wastes and
those  that contain  both municipal  and industrial  non-hazardous
waste  are indistinguishable,  unless  the site  is  dominated  by a
particular  industrial  waste.   For most sites,  the quantities of
lignin-containing  wastes, chlorinated hydrocarbons and aromatics
from municipal wastes are so large that chemicals derived  from the
industrial   wastes  cannot  be  detected  against  this background
(Webster, 1988).
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     The Subcommittee agrees with ranking the ecological risks from
non-hazardous waste sites as Medium (M) (or Group 5) on the basis
that the impacts are largely local.  Releases are generally of low
concentration.  The long-term nature of the releases  and the number
of  and    distribution  of  sites,  however,  warrant  continuing
attention to this issue.

6.12 Alteration and Disturbance of Terrestrial Hftfritfrt*

     This topic was not addressed or ranked in the EPA Unfinished
Business report.  The Subcommittee feels that it is an important,
ubiquitous   ecological   problem  contributing  toward   loss  of
biological diversity and therefore should be considered.

     As human populations and their support systems expand, natural
habitats and the populations they-support are disturbed, altered,
or destroyed.  There is a consensus among ecologists that species
extinctions are now occurring at unprecedented rates  (Wilson, 1988;
Wright, 1990).  The major cause of species loss is destruction of
natural  habitats.    The most  significant and  publicized losses
currently are the results  of  conversion of tropical  forests to
agriculture in Latin America and Southeast Asia.  However, natural
habitat  losses  are occurring everywhere,  even  in industrialized
countries with strict environmental regulation.  For example, oak
woodlands and chaparral are  rapidly  being  converted  to housing
tracts and avocado orchards  in southern California mountains.  Most
native prairies and  grasslands  in  the United States have already
been converted to agriculture.

     Habitats can be altered,  converted, or disturbed with varying
ecological impacts. Conversion of a habitat results in irreversible
loss; e.g., a forest is converted to a housing tract, and survival
of  native  plant  and animal populations  is no longer  possible.
Partial  alteration of  a habitat  (e.g.,  road  construction)  can
result in shifts in diversity and abundance of natural populations,
but may allow survival of the  ecosystems.   Habitat disturbance may
be  caused  by  human activities  near  natural populations (e.g.,
aircraft overflights) and result  in  abandonment or decreased use
of  the  habitat.     For example,  allowing  public  access  to  a
previously isolated beach causes harbor seals using that beach as
a rest area to abandon  it (Bartholomew, 1967; Woodhouse, 1975).
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     Although the  impacts  of any single activity  are  local,  the
cumulative  result  is major,  and for the  most part,  results  in
irreversible  loss   of   natural   ecosystems,   including  species
extinctions.

     Every effort should be made to preserve native ecosystems in
parks, reserves, and sanctuaries, but this  action  alone will  not
significantly reduce the rate of losses.   An equal effort is needed
to minimize the impacts of development so  that,  to  the  extent
possible  and practical, natural  populations  can  survive.   For
example,  leaving  corridors of natural  habitat through developed
areas allows more native populations to survive (Millar and Ford,
1988) .   More attention  should also be paid  to restoration  and
enhancement of natural  habitats  (Jordan et al.,  1988), including
research  programs to  build the  science base upon which these
activities rely.

     Some types of development are more compatible  with natural
systems than others.  Such projects maintain a large portion of the
property  in  open  space,   permitting   the  survival  of  natural
populations.  Examples  of these are military bases,  oil  fields, and
low-density housing.   These projects should  be planned with the
goal  of  maximizing  the survival of  natural populations while
accomplishing the goals of the project.

     Finally,  sound  environmental   planning  and  management  to
minimize the ecological impacts of development should be a part of
every approved project.  More research  is needed to develop cost-
effective environmental planning and management methods.  Lengthy,
detailed  ecological  studies are not a  realistic  expectation  for
most development projects,  yet accurate, reliable data are needed
for use in planning.

     The  Subcommittee   sees  habitat   alteration   and  loss  of
biological diversity as  a  local,  regional,  and global problem of
increasing importance with  high cumulative  impacts  and, therefore,
high ecological risks.

6.13 Accidental Releases of Toxics

     Over 2,000  accidental releases of toxicants  occur annually
involving some 40  million  pounds of the total.  Only 2.4% of the
events  release  90%  of the  total amounts of  toxicants.   Most of

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these come from fixed  facilities  and occur on land.   Most states
enforce  emergency containment  and  cleanup  procedures  at  large
facilities.

     The EPA Unfinished Business Report downgraded the importance
of persistent toxicants  (PCBs,  Kepone,  dioxins,  etc.)  since they
do not  constitute a  large percentage  of the  total  spills.   A
majority of the materials accidentally released are nonpersistent
organics like TCE and DCE.  Given the above, the low risk ranking
is appropriate.

6.14 Oil Spills

     On average about  11  million  gallons  of oil are spilled each
year; 60% of this amount  is spilled into  marine environments and
40% in inland environments.   Approximately  40% of all oil spilled
is crude oil,  30% diesel and other fuel oils,  and the remaining 30%
other products (EPA,  1987).

     Most experimental and monitoring work has been done on crude
oil spills in the marine environment.  A large body of literature
has been developed since  the  Torrey Canyon spill  in 1967 and the
Santa  Barbara spill  in  1969  (e.g.,  API,  EPA,  USCG Oil  Spill
Conference  Proceedings  1969-1989).    Large  oil  spills,  though
infrequent, can have  significant ecological  impacts.   Spills of
crude oil in the' marine  environment are primarily surface events
rather  than  water-column   events.     The  most  severe  (i.e.,
population-level)  impacts are on organisms that interact with the
water surface  and oiled  shorelines.   Water column  and benthic
populations are affected  far  less,  usually not  at the population
level.   Impacts  of most  oil  spills, even large ones  are in the
"years" category of duration (NRC, 1985) .  This is  likely  to be the
case for most populations affected by the large 1989 Exxon Valdez
spill in Prince William  Sound, Alaska,  as  well (Baker et al.,
1990).   The  exceptions to this are  spills that enter low-energy
habitats where oil penetrates  the sediments and may remain for long
periods.  For example, oil  spills kill adult mangrove trees.  It
may take 20 years to replace  such trees.

     Spill-response techniques can greatly influence the ecological
impacts  of  the  spill.   In  spill  situations  there  is  often  a
conflict  between  the  goal   of  removing  visible oil   from  the
environment and that of  minimizing  the ecological impacts of the

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spill.  There are many examples where harsh and damaging "cleanup"
methods have actually  increased  the overall  impacts of the spill
and prolonged recovery (e.g.,  using heavy equipment  in marshes and
steam cleaning to remove  oil  from  rocks).   We recommend that the
overall  goal  of  spill  responses should  be  to  minimize  the
ecological impacts of  spills  and that  response  methods be chosen
to accomplish this goal and, preferably, planned in advance.  The
importance of site-specific contingency planning and  of streamlined
decision-making  during a  spill  event  cannot  be  overemphasized
(Lindstedt-Siva, 1984).

     More research  is needed  on the fate,  effects, and response
methods for spills of crude oil and products  into inland waterways.
For  some  of  these  products  there  is  significant  potential  for
water-column or benthic, as well as surface,  effects. In addition,
some  of the  response  methods appropriate  for  spills  in marine
environments are not appropriate for inland waterways.

     The Subcommittee  agrees  with  the  overall ranking  of Group 5
or Medium  (M)  for  the impacts  of accidental  oil  spills.   The
rationale  is  that  spilled  oil  degrades,   loses   toxicity,  and
generally does not persist  in a  biologically active state in the
environment   for  many   years   as,   for   example,  chlorinated
hydrocarbons  do.   The most  serious,  longer-term  impacts from
accidental oil  spills have been from spills  of refined products
(more toxic than crude oils)  into  low-energy, confined bodies of
water where the  oil has become incorporated into sediments.

6«15 Underground Storage Tanks

     It has been estimated that from 10% to 25%  of the underground
storage  tanks  (USTs)  in  use  currently are  leaking.    This  may
engender  ecological   risks  not  apparent  to  similar  lack  of
containment for  the same materials stored above ground.  At first
glance,  the   major   potential   for  UST  contamination  of  the
environment would be that associated with contaminated groundwater,
particularly  in  those  rural areas  where potable water is derived
from  shallow  wells.    However,   over  a  long  time period such
contamination  of  groundwater  with  petroleum  products may  be
significant  to  some  surface waters  derived  from contaminated
aquifers where  the  ecological effects  may be more  apparent.  In
cases   of   known  leaking  USTs,   removal   is  required,  with
decontamination  of  the affected  environs at considerable expense

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to the owner of the site.   In cases where a  family business is the
responsible  party,  the costs  of  such remediation may  result in
cessation of business and possible inadequate financial resources
to  implement remediation,  leaving the  problem unsolved.   This
problem, then,  has  serious economic consequences as  well as the
potential for environmental perturbations.   The problem of leaking
USTs  is  widespread  and  perhaps  cumulative  over  the  years,
reflecting lack of comprehension of the problem and its potential
for harm.

     The prevalence of the problem and the impact on small business
and landowners  and  the potential  for  cumulative  effects suggest
that several research areas  need to be developed to ameliorate this
widespread problem.

     Additional  research  should,  be  implemented   towards  the
development  of devices  and  procedures  for  early  detection of
leaking  USTs,   which  will   enable  periodic   inspection  and
certification  of  such tanks.  Such  detection ideally  should be
low-cost and  involve  minimal  perturbation of the  environs of the
tank and the  business activity at  the site.  Reliable devices of
high sensitivity that can be operated by individuals with minimal
technical  skills  should  be  developed   as  an  analog  of  more
sophisticated technology  currently available.

    Research  should  be  implemented  towards  the remediation of
contaminated  soils  near  a  leaking  UST.   Such  research  might be
focused on in-situ remediation, remediation in close proximity to
the contamination site, or  utilizing slurry reactors  in a closed
system.   For  these  alternatives,  developments  in  biotechnology
currently available  for  bioremediation should  be considered and
evaluated to minimize the cost of remediation if prescribed.

    In general, the ecological risk from leaking USTs is low, but
the risk to  humans  may  be high  in  cases where potable  water
supplies are derived  from shallow aquifers down gradient from the
storage tank.  We agree with the ranking of Group 6.

6*16 Groundvater
     Groundwater contamination is perceived by the public to be a
major class of environmental insults.  The EPA Unfinished Business
report  includes  statements  like  "200  contaminants  have  been
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identified" and  "millions of occurrences  are  found nationwide."
The  medium rank  assigned in  the EPA  report was  based on  the
assumption that ecological impacts can only occur when groundwater
discharges to the surface.   The  filtering properties of soil  and
the dilution by  surface waters will  reduce the risk by reducing
exposure concentrations.

     The  filtering  properties  of soil  constitute  a  short-term
buffer.  Eutrophication of freshwater lakes from old septic fields,
selenium toxicity of emerging groundwaters resulting from increased
irrigation, and nitrate inputs into Chesapeake Bay from intensive
agriculture on  the  Eastern Shore are all  examples  of overloaded
filtering capacity.

     The "dilution is the solution to  the pollution" paradigm only
works  for  substances that do  not partition to media  other than
water  and do  not  bioaccumulate.   Nuisance  growth  of  aquatic
macrophytes  due  to   excessive   nutrients  and   the  food-chain
biomagnification  of   persistent  pesticides  are   examples   of
alternative fate-and- transport dynamics.

     Groundwater  contamination  sources  are   very  numerous  and
ubiquitous   (e.g.,    septic   fields,   injection   wells,   land
applications,  material   stockpiles,  pipelines,   and  non-point
sources).      Groundwater  is generally  slow moving and  very
conservative in transformation functions.   There  are very little
data on  groundwater as  a  source  of ecological exposure.   Most of
the exposure will occur in the future.

     The Subcommittee ranked the  ecological risks from groundwater
contamination to be  relatively low.  The major impact would be felt
by human consumers rather than ecological  systems.

6.17 Pesticides

     One  of  the  side  effects of pesticide use  is environmental
contamination.  Pesticides and herbicides  are  the only substances
that are intentionally applied to the  environment because of their
biological toxicity.   Society in general,  and EPA in  particular,
are  aware  of  this,  and pesticide regulation through registration
and  reregistration,  enforcement, and monitoring  is currently of
high priority.
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     The cost of pesticide development has increased dramatically,
and the  number of compounds  restricted or banned  has increased
steadily in the last  20 years.  The use of pesticides in the United
States increased during the 1970's, leveling off at a little over
one billion  pounds of active ingredient since the  mid-  to late-
1970s.  In fact,  the  amount of active ingredient used in the United
States in 1988 was 1.13 billion pounds, about the same as in 1978
(1.11  billion  pounds).    Clearly  the  degree of  environmental
contamination and risk to the  environment depend  on such factors
such as  toxicity of  the  pesticide, application methods,  and its
persistence.    We are  concerned  about this  contamination  and
encourage  EPA to  continue to  develop  environmental  monitoring
methods.

     We  are  also concerned by  the efficiency of  controls given
current  application   practices,  in  particular,   the   overuse  of
pesticides and improper use by unskilled or untrained consumers and
farm workers.   The  different  application approaches  used which
depend on the type of pest,  its  location, and the specific type of
pesticide to be used can  result in much of a pesticide sprayed on
the environment never reaching or impacting its target.

     Research on non-pesticide control needs to be a priority for
EPA.    Pesticides,   by   their   very nature,   are  toxic  to  the
environment,  and pollution prevention  or  non-use  of  pesticides
should be a long-term goal.  We  believe EPA should consider taking
a stronger role  in non-chemical control  of  pests.   Both research
and dissemination of information are needed.

6.18 Nev Toxic Chemicals  (Non-Pesticides)

     Determining the  environmental risk posed by a chemical (s) that
has yet  to be  conceived or produced  is impossible.    The Toxic
Substance Control Act (TSCA) directs EPA to evaluate  the hazards
and  exposures  associated  with  new  industrial  chemicals  and
determine whether the potential risks are acceptable.

     The EPA Unfinished Business background and  reference documents
indicate that approximately one thousand new chemicals have been
developed each year  over  the past  decade.   It is further implied
that half are now in production.  Laboratory toxicity assessments
have been conducted on some of  the new chemicals reviewed by EPA's
Office of Toxic Substances since 1979.  Many do not have adequate

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ecotoxicity data for a "reasoned ecological risk assessment", the
criterion specified in TSCA.

     To compensate, in part, for the  lack of time and resources to
conduct laboratory toxicity  assessments, models have been developed
to estimate a variety of parameters, including bioconcentration,
toxicity,  and  persistence.    Quantitative  structure  activity
relationship (QSAR) models  are examples.  It should be noted that
all models have limitations, and that models are not available to
estimate all parameters and responses for all chemicals.

     As technologies advance and human population increases, it is
logical to assume that new chemicals  will continue to be developed
and  produced.    If past  practices  continue,  too  many  of  these
chemicals will reach  the marketplace with  minimal  or no toxicity
assessment.  The Subcommittee recommends that the Agency carefully
evaluate  its  allocation  of  resources   relative  to  toxicity
evaluations of new chemicals.  Although the Agency  did not rank
this problem area, the  Subcommittee believes that it should rank
as a medium ecological risk.

6.19 Biotechnology

     The  subject  of  biotechnology   includes   a  wide  range  of
disciplines, subject materials, and  intended usage.  For example,
developments  in  this field  range  from   genetically  engineered
microorganisms  for use  as  microbial   pesticides  to plant life
altered to include heterogenetic material from a wide  range of life
forms.   Some of  the  concern associated with  the  utilization of
biotechnology reflects the  manner in which biotechnology products
are derived; many of the developments suggested for biotechnology
utilize recombinant DNA  technology.   Other concerns  focus on the
products  of  biotechnology  and  possible  perturbations  of  the
environment that may result.  The distinction between methods used
and the resulting products has been clearly delineated recently by
the Ecological Society of America (ESA, 1989).  The substance of
this publication is summarized as follows:  "We believe that these
developments should  occur with the  context  of a scientifically-
based  regulatory  policy  that  encourages  innovation  without
compromising sound environmental management."

     Recombinant  DNA technology allows  the potential for complete
description  of  altered  homogenetic  or heterogenetic hereditary

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material that might be included in the deliberate construction of
biological materials with altered properties.  Therefore, risk can
be minimized, if not excluded,  from the perspective of the genetic
material involved.   The primary basis for concern,  then,  is the
behavior of  the altered microorganism, plant,  or animal species
into which  this genetic material  has  been added.   Such altered
species may have the potential for developing ascendant populations
that may alter delicate ecological balances indigenous to a given
environment.  Such perturbations have the potential for overgrowth
of new  species to the  detriment  of  the normal  flora  and fauna.
Concerns for this possible result, then, must be  ameliorated by the
development of acceptable criteria to exclude such outcomes prior
to the dissemination of these biotechnology products.

     Bio-pesticides  are  agents  that  have  been  developed  to
eliminate or diminish pests present in the environment.  They are
usually defined  in terms  of their targets and include microbial,
insect, plant,  and animal  targets.  Their efficacy  is  judged by
their ability to inhibit undesirable life forms and, therefore, are
generally pathogenic for the target organism.  Two outcomes can be
envisaged  from the release  of  such  biotechnology products:   a)
expansion of the host range  (target species) to include organisms
beneficial  to   biological   communities   through  mutations  and
recombinations  subsequent  to release;  and b)  the  ascendancy of
suppressed  populations  subsequent to  the elimination of  a pest
agent that normally limits such overgrowth.  Therefore, two major
concerns are associated with these agents.  The genetic stability
of  the  pesticide   organism  should  be  ascertained,   and  the
consequence of the removal of the pest  from a biological community
should be  evaluated.   These concerns may  best  be addressed on a
case-by-case basis,  reflecting the judgment  of experts familiar
with the particulars of a planned usage.

     Many developments  in  biotechnology  center  on the production
of plant life with altered characteristics.  Here, as above, there
is a  concern for the  possibility that such  plants  might become
dominant to other beneficial life forms in a biological community
and, thus, have long-term detrimental consequences.  However, such
concerns  are also inherent to strain  improvements accomplished
through traditional  plant breeding  technology.   In the case of
biotechnology products and the recombinant DNA technology used for
their development, however,  the biotechnology-derived products are
likely to  be more concisely defined than the  products  of plant

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breeding.  Therefore,  concerns  for biotechnology products should
be congruent with similar concerns associated with the release of
more conventional products.

     One of the major  ecological  concerns  prevalent today is the
accumulation, concentration, and leaching of xenobiotic compounds
into potable water  supplies or  their increased concentrations in
the  atmosphere.    These problems,  to  a large  extent,   are  the
consequence of an industrial society and previous lack of concern
for environmental perturbations by its waste products.  The .use of
genetically  engineered  microorganisms  to   degrade  xenobiotic
compounds is envisaged  as a logical extension of natural processes.
The  beneficiation  of such  natural  processes  through the use of
recombinant DNA technology to produce microorganisms with enhanced
degradative  characteristics  is  the  primary  thrust  of  these
developments.   The usual  object  of  such developments  is  the
enhancement of the  rate at which  natural processes occur and, in
some cases,  an increase in  the range of substrates  that may be
degraded.  For the  safe application of such microorganisms, then,
a primary requisite is  that these  microorganisms not be pathogenic
to humans and other life forms.  Of equal concern  is the manner in
which commercial quantities of such microorganisms may be produced.
Commonly, microorganisms for commercial applications are grown in
nutrient solutions that allow attainment of high population levels
in a short period of time.   There is, therefore, the opportunity
for  growth of  pathogenic  microorganisms  concurrently  with  the
commercial species, and such outcomes  must  be precluded by the
application  of product  standards.   This  concern,  however,  is
focused  on manufacturing  technology and  not the biotechnology
product per se.

     Pivotal  issues  concerning  biotechnology products do  not
include the methods by  that such products are derived per  se.  They
do include the source  of  genetic  material,  the changes that have
been made to such genetic material, properties  of  the host organism
before and after  alteration, the impact of release or escape of
genetically altered organisms on  indigenous  organisms,  and their
dissemination  to  other ecosystems.   To  encourage innovation and
promote economic benefits to society, appropriate policies need to
be developed  to regulate the content and  usage  of biotechnology
products.  In some  cases,  this  may  require the development of new
regulatory  purviews since  these products  lack  precedent  and,
therefore, are inappropriate for some existing  regulatory  policies.

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Regulatory agencies in place  should  take  a proactive role toward
facilitating biotechnology developments by working in concert with
the developers of this technology  and  the end-users.   A case-by-
case policy seems appropriate currently until experience with these
products is acquired.

     The potential risk for biotechnology relates directly to the
product.   Since  products with disparate  properties  and intended
usage are being developed, it does not seem prudent to generalize
concerning inherent risk.  However,  no high-risk products should
be  considered  without exhaustive  review.   For  example,  special
consideration  should  be  given   to  one  possible   product  of
biotechnology,  the genetic alteration of pathogenic species.  With
microbial species, it has been suggested that genetic alterations
resulting in the loss of virulence, but maintenance of colonizing
activity  by pathogens,  might protect some  plant species  from
infection by pathogenic bacteria.   However, it is not possible to
generalize  in   this   regard,  especially  if   all   the   traits
contributing to virulence are poorly  understood.  One may envisage
a genetic event occurring  subsequent to release  of such bacteria
that might introduce new, and possibly more virulent traits, into
an altered microorganism that has retained  its colonizing activity
toward  a  target  plant(s).    Products   beyond  the  foregoing
relationships,  however,  are  likely to  rank low  to moderate risk
depending upon  the information base relevant to the intended usage.
Biological entities,  whose genetic  potential and behavior are well
understood, are  of less  concern  than  those  known to  have been
developed  from organisms  clearly known  to  be  associated  with
undesirable biological activities.

6.20 Plastic in the Marine Environment

     It is common  to  see plastic litter along roads, and on the
beaches  and shorelines  of   our   coastal  environments.    These
materials can exhibit an environmental impact in one of three ways:
aesthetic pollution; toxicity via ingestion; and mortalities from
entrapment  and entanglement.   The  magnitude  of the  aesthetic
problem  is  relatively  easily  quantifiable.    The  number  of
mortalities from  ingestion,  entrapment, or entanglement  is much
more difficult  to estimate accurately.  The EPA Unfinished Business
background documents do a good job  of relating the length of nets,
number of floats,  length of ropes,  number of traps, etc.  in present
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use and the quantities lost from use and,  thus, available to impact
marine and estuarine organisms.

     Impacts can  be severe  for  organisms that  are  particularly
prone to ingest plastics.  Sea turtles  are an important example.
Individuals of  these endangered species  have been shown  to eat
plastics, and deaths have been attributed  to such ingestions.  Sea
birds are also vulnerable.

     Since  accurate estimates of  the  magnitudes of  biological
impacts from plastics in the  marine environment are not available,
it is  difficult  to rank the problem.   However,  since endangered
species are known to be  impacted  and  the effects on fisheries have
the potential to be high,  the Subcommittee concluded that the area
should be ranked as medium.

6.21 Biological Depletion and Extinctions

     This topic was  not a problem  area  specifically  addressed or
ranked  in  the  EPA Unfinished  Business report on ecological risk
reduction.   The  Subcommittee  feels  that  it   is  an  important
ecological problem area and that it should be considered.

     There is a consensus among ecologists that species extinctions
are occurring at unprecedented rates  (Wilson,  1988; Wright, 1990).
Many   species   are  lost  before   they  can  be  described  or
characterized.  Others  are known to  be  threatened or endangered,
and special efforts are  made to protect them.   As human populations
expand,  there  is   increasing  pressure  on  natural  resources,
including species harvested for  food and other uses.

     The  major cause  of  species  extinctions  and decreases  in
natural populations  is  loss or  disturbance  of  natural habitats.
Over-harvesting is an additional cause of population reduction of
commercial and sport species.  When a species is lost completely,
through  extinction,  that   genetic   material,   adapted  to  its
environment, is irreversibly lost.  Similarly, when species become
threatened  or  endangered  or natural  populations  are  greatly
depleted, the gene pool is greatly reduced, possibly limiting the
ability of that species to adapt  to environmental changes.  In the
view  of the  Subcommittee,  this problem  area  ranks  as  a  high
ecological risk.
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6.22 Introduction of Biologic Species

     Ecological communities are collections of biotic species that
have co-evolved clusters of interspecific interactions that impact
on  increased  probability  of  surviving  for  the  participating
species.  These interactions involve ecological processes such as
predation,  competition,  mutualism,  symbiosis,  and  obligatory
physical associations.  Many of these evolutionary associations are
so tightly coupled that small  clusters of species have their fates
inseparably bound together.

     Introductions by natural and anthropogenicly mediated events
have  been  analyzed by  ecologists over  the  years,  as  these
constitute  natural  experiments with  which to test  hypotheses
involving  community  ecology.     Generally,   the   frequency  of
successful  colonizations  of   exotic species   is  low  when  the
recipient  community  is not stressed.   Propagules  and  transient
individuals  are  constantly testing the system to look  for new
opportunities to expand their species domain.   The resistance to
intruders  comes   from  healthy  endemic  populations  with  the
competitive advantages of community co-evolution.

     Even  so,  one of the  most important demonstrable  agents of
ecological change  is the anthropogenic introduction  of biologic
species  into  areas  where  they  did not  evolve.    Intentional
introductions of sport  fishes,  game birds, horticultural varieties
of ornamental plants, and biologic agents chosen to control plant
and animal pests provide thousands of case examples.  In addition,
a  large  number  of  accidental  introductions   have  taken  place
resulting  from the  worldwide network  of  material transport in
agriculture  and  forestry.    Many  of  our  most  important  pest
management problems involve accidental exotic introductions.

     Introductions of  exotic  species have  provided demonstrable
examples of total ecological disruption, such as the sea lamprey -
alewife destruction of fish communities in the Great Lakes.  They
also provide examples of economic improvements with little evidence
of serious ecological impacts,  such as the plantings of brown trout
in rivers and lakes throughout the United States.   The wide array
of ecological  responses to the introductions of  exotic species
requires  that  each  event  be   given  careful evaluation  prior to
implementation.  Since  introductions, if  successful,  are usually
irreversible, proactive evaluations should be mandatory.

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               7.0 RECOMMENDATIONS AND CONCLUSIONS
1.  Formalise an extramural and continuous process for ecological
risk prioritization;  this process  should not b«  categorised by
Agency programmatic structure but rather by anthropogenic stresses
on the environment.

     The 1987 "Unfinished Business11 report represented a pioneering
effort in assessing the relative risks of environmental stressors
and  their prioritization  for  Agency attention.   However,  the
scientific process of relative risk ranking was influenced by the
programmatic  structure  of   the  Agency  which  influenced  the
organizational approach to the  study.  Yet the study  has already
been invaluable in affecting  Agency operations.  We recommend that
the process  of  risk assessment be  continued  as  a  formal working
tool of  the  Agency and that this process also  include external
peers  —  for  breadth of  perspective   as   well  as  scientific
credibility.    It  is  necessary that  this process  continuously
reappraise this nation's environmental issues  and ecological risks
to focus and direct Agency activities.

2.  invest in development  of formal methodologies for ecological
risk assessment.

     Although the  ecological  and welfare risk ranking procedures
used  in  our deliberations  were  a  useful  tool,   these ad  hoc
procedures   represent   only   a  beginning  in  quantifying  and
formalizing  risk  prioritization.   The  process remains largely
nonquantitative.   There  is  need  to  improve  upon  existing risk
ranking techniques and to  evaluate methodologies for comparative
risk analysis.  Programmatic  resources should  be  invested, in both
in-house  and extramural  research  and  development,  to improve
ecological and  environmental risk  evaluation and prioritization
methodologies.     In   addition,   the   overall  concept  of  risk
minimization  (implying both controls and  corrective actions) needs
to be expanded to include  proactive and anticipatory alternatives,
such as prediction and early  detection of impacts, improved design
of environmental management  systems,  and utilization of recovery
processes and self-sustainability of  natural  systems rather than
human intervention and control.

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3.  Develop the data bases needed for improving future •cological
risk assessments.

     Ecological risk assessment is handicapped by the availability
of organized sets of  comparable quantitative data  to support the
risk  evaluation process.      The science  itself  lacks  neither
concepts  or data,  but  is deficient  in systematic  synthesis  of
information  into  useful  formats.      All  information  is  not
necessarily useful.  The risk evaluation methodologies and state-
of-the-art techniques must define the data needs  and data analyses.
Data  bases  supporting   ecological   risk  assessments  must  be
institutionalized and maintained by  the  Agency.   However,  many
useful surveys assessing ecological health are maintained by other
Federal organizations.   These  must be  accessed and used  in the
final   processes   of   relative  risk  evaluation   and   risk
prioritization,  providing  proper  balance  for  risk  reduction
actions.

4.  Develop an appropriate paradigm for  integrating ecological and
economic perspectives and considerations.

     Any  risk  assessment must  be  based upon a  comparison  of
benefits  and costs  resulting  from  hazard reduction.   Not all
environmental attributes and ecological  values can be expressed in
economic terms.  It will  be  necessary to develop  an  entirely new
paradigm for integrating ecological and economic  considerations for
risk assessment. Understanding sustainable development limits for
ecological  systems will  be essential.  Not until  ecological and
economic values of environmental systems can be  unified will it be
possible  to obtain  unbiased  assessments of   ecological  worth,
accurately  to  prioritize stressors and systems at risk,  and  to
begin cost-effective strategies  for risk reduction.

5.  Expand EPA's perspective on ecological values and welfare risk
to include ecological attributes  as veil as economic factors.

     In developing an integrated  ecological/economic paradigm for
environmental risk assessments,  it will be extremely important to
address those  many ecological  attributes for  which  an economic
metric presently does not exist.  The  costs of remediation greatly
exceed  expenditures  to   ensure early  prevention  of  ecological
damage.   To address  the cost/benefit  of environmental actions,
entirely new concepts of ecological attributes as finite resources

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and compounding rather than discounting when choosing alternatives
to environmental protection will be necessary.

6.   Incorporate  the  results  from  this  risk ranking  process/
including the 1990 risk reduction study, in development of future
Agency policy and allocation of financial resources.

     The  1987  "Unfinished  Business11  report  and  this  1990  risk
reduction exercise by the RRRSC have demonstrated the need for new
directions in  ecological  research and applications.   Using risk
assessment  techniques,  these  reports  provide  opportunity  for
renewed focus  for reducing the risk to ecological  systems based
upon scientific information and expert judgment.  The opportunity
now exists to  direct  the  Agency's efforts to those most critical
environmental  problems  where  the greatest risk reduction  can be
obtained.     We  urge   the  Agency   now  to  incorporate   the
recommendations  from  these studies  into  its future  policy  and
administrative operations.
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