United States Policy, Planning, August 1989 Environmental Protection And Evaluation Agency (PM-220) cjrEPA Comparing Risks And Setting Environmental Priorities Overview Of Three Regional Projects Printed on Recycled Paper ------- Comparing Risks and Setting Environmental Priorities Overview of Three Regional Projects U.S. Environmental Protection Agency Office of Policy, Planning and Evaluation Washington, D.C. 20460 1989 ------- yt0,T<>* i&z) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, O C 20460 DEC 7 1389 0"tct Of r»C AOMlNllTfliTOfl MEMORANDUM SUBJECT: "Comparing Risks and Setting Environmental Priorities" It is my pleasure to present you with the attached new report, "Comparing Risks and Setting Environmental Priorities: Overview of Three Regional Projects." These projects represent a major attempt by EPA and state agencies to assess the seriousness of environmental problems based on the effects they have on human health and the environment. The projects demonstrate innovative approaches to managing these problems. The report documents the process and compares the results of the first year of two-year pilot Comparative Risk Projects in EPA's Regions 1, 3, and 10. The projects combine the leadership of Regional senior managers with the technical expertise of professional Regional staff. The projects use estimates of risk as a common measure for comparing and setting priorities among environmental problems within and across media. We will continue to refine and use these rankings of environmental problems as we develop an Agency-wide risk-based strategic plan. While the rankings are generally consistent across Regions, there were some important differences in risk for certain problems, pointing to areas where Regional priorities may differ from national priorities. In addition, causes of risk sometimes vary across Regions. These findings indicate the need foe planning to account for geographic distinctions. Ths results of these projects will be used to guide the choices of thsss three Regions in EPA's strategic planninc process. I encourage other Regions and National Programs to use these projects as a model in analyzing and developing their owr goals and strategic choices. TO: FROM: Attachment ------- ------- EPA Headquarters: Assistant Administrators Deputy Assistant Administrators Program Office Directors Program Office Deputy Directors EPA Regions t Regional Administrators Deputy Regional Administrators Associate Regional Administrators Division Directors ------- ------- FOR INFORMATION ON COMPARATIVE RISK WORK IN OTHER REGIONS AND STATES, CONTACT: REGIONS Alice Jenik USEPA - Region II Jacob K. Javitz Federal Building 26 Federal Plaza New York, NY 10278 (212) 264-3052 Cory Berish USEPA - Region IV 345 Courtland Street, N.E. Atlanta, GA 30365 (404) 347-7109 John Hoglund USEPA - Region V 230 South Dearborn Street Chicago, IL 60605 (312) 353-6324 Gerald Carney USEPA - Region VI 14 45 Ross Avenue Dallas, TX 75202-2733 (214) 655-6570 Jackie Ferguson USEPA - Region VII 72 6 Minnesota Avenue Kansas City, KS 66101 (913) 551-7363 Don Johnson USEPA - Region VIII 999 18th Street, Suite 500 Denver, CO 80202-2405 (303) 293-1456 Janis Gomes USEPA - Region IX 75 Hawthorne San Francisco, CA 94105 (415) 744-1623 Keith Hinman USEPA - Region X 1200 Sixth Avenue Seattle, WA 98101 (206) 553-4044 STATES Kate Kramer CDOH 4210 E. 11th Avenue RM 350 Denver, CO 80220 (303) 331-4436 Phil Miller Department of Ecology Abbot Raphael Hall Mailstop PV-11 Olympia, WA 98504-8711 (206) 459-6282 Doug Kievit-Kylar Office of the Secretary Agy. of Natural Resources 103 S. Main Street Waterbury, VT 05676 (802) 229-4438 Jean Thompson Office of the Secretary Department of Environmental Quality P.O. Box 82263 Baton Rouge, LA 70884 (504) 765-0720 Bill Rustem Public Sector Consultants 300 S. Washington Square Suite 401 Lansing, MI 48933 (517) 484-4954 Bob Lieberman Office of Research & Planning Illinos Dept. of Energy and Natural Resources 325 W. Adams Springfield, IL 62704 (217) 785-0124 ------- -2- States (continued) Chuch Shulock Assistant Secretary, CAL-EPA 555 Capital Mall, Suite 235 P.O. Box 2815 Sacramento, CA 95812 (916) 324-8124 Paul Hoff Environmental Analysis Office Minnesota Pollution Control Agency 520 Lafayette Road, N. St Paul, MN 55155 Alan Jones Center for Global Studies 4800 Research Forest Drive The Woodlands, TX 77381 (713) 363-7913 Jan Miller, Bruce Slater Utah DEQ 288 North 1460 West Salt Lake, UT 84114 (801) 538-6121 Karl Wilkins Maine DEP Statehouse, Station 17 Augusta, ME 04333 (207) 289-2811 Steven Nicholas RM 200, Seattle Municipal Bid. 600 Fourth Ave Seattle, WA 98194 (206) 684-8377 Suharjo Haditirto DOH, Environmental Planning 500 Ala Maona Blvd.; Ste 250 Honolulu, HI 96813 (80.8) 586-4337 ------- Preface "N "Our main mission at EPA is to protect human health and the environment. As EPA employees will attest, that is not easy. Because there are so many different kinds of environmental and health risks—different pollutants from different sources entering different media—it is sometimes very difficult to tell which problems are the most serious and thus which demand the most attention. Comparative risk analysis helps us accomplish our mission by suggesting where our efforts can do the most good." William K. Reiliy, EPA Administrator The report was prepared by the Office of Policy, Planning and Evaluation (OPPE) of the Environmental Protection Agency (EPA). It documents the results of the first year of three Comparative Risk Projects sponsored on a demonstration basis in EPA's Regions 1 (Boston), 3 (Philadelphia), and 10 (Seattle), The projects are a collaborative effort between participating Regions and OPPE's Geographic Integration Branch at EPA Headquarters in Washington, D.C. The projects use risk information in an integrated approach to identify and to assess environmental issues, to set priorities among these issues, and to develop appropriate strategies to manage these problems. EPA initiated these two-year projects in 1987 to pursue new approaches to environmental management and policy. These three Regions participated, not because they have unusual environmental problems, but because they wanted to explore better ways to manage environmental problems in their areas. The decision-making body of each Comparative Risk Project consisted of a Steering Committee made up mainly of senior Regional staff. Three technical work groups of professional staff from the Region evaluated the risk information and developed the initial rankings of issues. OPPE provided administrative, technical, analytical, and financial support. i ------- For further information on these Comparative Risk Projects contact the Regulatory Integration Division (PM-220), Office of Policy Analysis in the Office of Policy, Planning and Evaluation, U.S. Environmental Protection Agency, Washington, DC 20460, or the appropriate Region: U.S. Environmental Protection Agency Region 1 - Planning and Management Division John F. Kennedy Federal Building (PPC-2300) Boston, MA 02203 US. Environmental Protection Agency Region 3 - Environmental Services Division 841 Chestnut Street (3ES43) Philadelphia, PA 19107 U.S. Environmental Protection Agency Region 10 - Management Division 1200 Sixth Avenue (MD-102) Seattle, WA 98101 ii ------- Acknowledgements Numerous individuals contributed their time and effort to this report. They are: Catherine S. Tunis, Geographic Integration Branch Frederick W. Allen, Deputy Director, Regulatory Integration Division Arthur Koines, Chief, Geographic Integration Branch Michael Drysdale, Geographic Integration Branch James Hemby, Office of Air and Radiation, formerly with the Geographic Integration Branch Keith Hinman, Geographic Integration Branch Mark Mahoney, Region 1 Lane Nothman, Region 10 Eva P. Ring, Geographic Integration Branch Jeri Weiss, Region 1 Patricia Wilbur, Region 3 Thanks to all of the participants in each of the Regional Comparative Risk Projects, both EPA staff and consultants. They have and are giving their best to these projects, and have made possible the advances in knowledge gained from them. Appendix F lists the participants of each Regional project. iii Coordinator: Reviewers: ------- Contents Preface i Acknowledgements iii Contents iv Tables vi Figures vii Executive Summary viii L Introduction l A. Comparative Risk Projects Address Major Challenges in Environmental Management 3 B. Objectives of the Office of Policy, Planning and Evaluation 6 IX Analytical Approach to Ranking by Risk 9 A. The Projects were Designed to Meet Regional Needs 9 B. Each Region First Defined the Set of Environmental Problems 10 Q Each Project Set Common Analytical Ground Rules 16 D. Each Project Analyzed Risks and Developed Rankings 20 HI Process and Participants 25 A. Getting Started 25 B. Establishing the Analytical Framework 28 C Analyzing and Ranking the Problems 31 D. Developing Solutions to Environmental Problems 35 R Senior Management Approval and Documenting the Work 36 iv ------- IV. Major Products and Benefits of Year One 38 A. Substantive Findings . . . 38 Ranking Results for Each Region 38 Findings for Major Problem Areas 42 Differences Across Regions . . 52 Project Results Compared with Results from Unfinished Business . . 58 Summary of Findings, and Comparison with Current EPA Control Efforts 62 Level of Confidence in Ranking Results . . 65 B. Project Benefits 68 V. Lessons for Future Projects 72 A. Possible Resource Savings 72 B. Issues Involving Project Design 73 VL Next Steps 79 A. Implementing the Analytical Findings in the Regions 79 B. Work by OPPE . . 82 VII. Conclusions 84 Appendix A. Definitions of Problems For Comparative Risk Assessment A-i Appendix B. Combining Different Types of Risk b-i Appendix C. Successful Methodological Innovations. C-i Appendix D. list of Acronyms D-i Appendix E. Supplementary Reading E-i Appendix F. Regional Project Participants F-i v ------- Tables Table 1: Problem Areas Analyzed in the Regional Comparative Risk Projects ... 12 Table 2: Summary of Findings for Major Problem Areas. Rankings by Region . . 43 Table 3: Problem Areas with Variations in Ranks by Region 53 vi ------- Figures Figure 1: Regional Comparative Risk Projects 1 Figure 2: Ranking of Problem Areas by Region 1 39 Figure 3: Ranking of Problem Areas by Region 3 40 Figure 4: Ranking of Problem Areas by Region 10 41 vii ------- Executive Summary Making environmental choices will never be easy. Which are the most serious problems? How do they vary across the nation? What are the best ways to attack them? Comparative Risk Projects seek to answer such questions by using estimates of risk as a common measure for comparing and setting priorities among environmental problems. Introduction Senior managers in three Environmental Protection Agency (EPA) Regions were interested in starting Comparative Risk Projects to help them make more informed environmental decisions. These managers also wanted to use the Comparative Risk Projects to identify Regional priorities that differ from national priorities and to provide analytical support for increasing Agency flexibility to address them. In a broader sense, the projects are intended to improve the way EPA sets environmental priorities by identifying, comparing and reducing risks to human health and the environment. EPA's Office of Policy, Planning and Evaluation (OPPE) and EPA's Regional Offices in Boston (Region 1), Philadelphia (Region 3), and Seattle (Region 10) began these projects in late 1987 as two-year demonstrations. This report summarizes the results of the first year's work. Process The projects first identified and carefully defined a list of eighteen to twenty-four of the most important environmental problems facing each Region. The projects then analyzed the risks posed by each problem, aiming to rank the problems in terms of their relative risks. Technical work groups, with representatives from each of the Regional viii ------- Program Offices, performed the bulk of the project analysis. In each Region, one work group analyzed the human health risks associated with environmental problems, and another work group analyzed the ecological risks. Region 3 also had a work group to analyze economic welfare risks. The work groups — together with OPPE analysts and contractor support — carefully developed comparative risk analysis methodologies and a plan for assessing each type of risk associated with each problem, then assembled available data on the problems. In assessing, comparing, and ranking the problems, participants combined the evaluation of data with professional judgment. Distinct rankings were produced in each Region for human health risk, for ecological risk, and, in Region 3, for welfare risk. Thus, it is possible for a problem, e.g., indoor radon, to rank high for human health risk, but low for ecological risk, and medium/high for welfare risk. Findings The relative rankings of problems are, with a few important exceptions, generally consistent across the three geographically separate Regions participating in the project. Differences in definitions and methods between the Regions account for most of the ranking differences. In a few instances, differences in rankings are because of significant geographic variations in the degree to which problems cause risks in different Regions. These differences reflect: o higher health risks from Criteria Air Pollutants in Regions with higher ambient concentrations of these pollutants; o higher ecological damages from Acid Deposition in the eastern Regions where precipitation is significantly acidic; and ix ------- o higher health risks from Industrial Point Sources and Non-Point Discharges to Surface Waters in the Regions where there are greater concentrations of industrial dischargers and where a higher fraction of the population relies on surface water as a source of drinking water. PROBLEMS THAT WERE RANKED CONSISTENTLY BY ALL THREE REGIONS High Health Risks Indoor radon Indoor air pollution other than radon Pesticides (primarily residues on food) Drinking water contamination High Ecological Risks Physical modification of habitats Nonpoint source discharges to surface waters Low Health Risks Low Ecological Risks Underground storage tanks Active hazardous waste (RCRA) sites Active hazardous waste(RCRA) sites Non-hazardous (solid) waste sites Radiation other than radon Abandoned hazardous waste (CERCLA) Underground storage tanks sites Non-hazardous (solid) waste sites Note; ft list of all problem areas analyzed by the Regions Is presented in Table 1 beginning on page 12, and full definitions for each problem are presented in Appendix A. Even where the relative risk rankings are similar, the causes of the risk sometimes were different across Regions. These differences in the causes of risk indicate the need for differing solutions. The Regional rankings, again with a few important exceptions, compare well with those developed in 1987 at the national level in EPA's Unfinished Business project. X ------- At the aggregated level at which this analysis was conducted, the relative residual risk associated with most environmental problems does not differ much across the areas studied. For example, indoor air pollution consistently causes greater health risks than hazardous waste sites, whether one is concerned with New England, the Middle Atlantic region or the Pacific Northwest. Such consistent findings should play an important roje in setting national environmental priorities. If we performed an analysis on smaller geographic areas or on more narrowly defined environmental problems, geographic distinctions in risk would become much more important. At an extreme, say at the community level, the health risks from an uncontrolled hazardous waste site to the specific individuals living in its immediate vicinity may well exceed those from indoor air pollution. The analysis that supports the rankings may be even more valuable than the rankings themselves. This analysis shows which components of risk ~ pollutants, source types, potency, pathways, or exposure — contribute the bulk of the risk for each problem area. The analysis also shows where the causes of risk vary across Regions even where the relative rankings of the problems may be similar. This knowledge is key to identifying opportunities for reducing risks and makes it easier for Regions to target programs efficiently at the portions of problems causing particularly high risks. The Regional rankings sometimes contrast very sharply with the relative levels of Regional resources devoted to these different problem areas. Each of the three highest health risk areas — radon, indoor air pollution and pesticide residues — are the subject of minimal Regional program efforts. Regional programs addressing the two highest ecological risk areas — habitat modification and non-point sources -- are larger, but still small. By contrast, two of the low-risk problem areas — active and abandoned hazardous waste sites (RCRA and CERCLA sites, respectively) — are the subject of major Regional programs. Underground storage tanks (USTs) are the subject of moderate Regional programs. Program resources devoted to solid waste and to radiation other than radon, like their risks, are small. ------- Why is there a discrepancy between the level of risk that a problem poses and the level of attention it gets from EPA? Resource levels tend to be more closely aligned with how serious EPA perceived these environmental problems to be in the past, rather than with the risks they pose now. The Agency's priorities also tend to align more closely with public opinion and its embodiment in legal mandates than with risk. The findings of these projects suggest that priorities for EPA action should depend more on the magnitude of current risks as well as on a broad set of factors that affect our ability to manage a risk such as public opinion, statutory mandates, cost and technical feasibility. Relative residual risks also provide no indication of how much risks would increase if current controls were dismantled or if current program enforcement efforts were reduced. While the first year analysis helps point out which problems are most serious, further analysis is needed to identify specific program changes. Next Steps In the long run, these projects are intended to improve the way EPA and state and local environmental agencies set priorities. Each participating Region has taken a slightly different path in using the Comparative Risk analyses to affect resource allocation. The three Regions have begun to analyze the risk management factors (public perception, available resources, control costs, availability of control technology, and legal authority) for each of their environmental problems and develop initiatives and shift resources to address these problems. Some initiatives are being implemented, relying either on discretionary Regional resources or on flexibility obtained through negotiating with national program offices at EPA Headquarters on activities the Regions will accomplish. State governments are also showing an interest in Comparative Risk analysis. Pennsylvania began a Comparative Risk Project simultaneously with the three Regions. ------- Since then, Colorado, Vermont, and Washington have also begun projects, and other states are considering projects. The projects have increased the Regions' ability to do risk-based planning and management. The participating Regional staffs are now better trained in the use of risk information and have a better understanding of risks in their program areas as well as in other program areas. Managers better understand Regional environmental problems and potential new directions they might take. As the Regional projects move into their second year, activities are expected to shift from risk assessment to developing effective risk management solutions. The first year's risk findings will lead to discussions about priorities. More initiatives based on the risk findings will be developed, analyzed and implemented. More flexibility to shift resources and activities to implement risk-based priorities will be sought. Risk-based approaches will be investigated for guiding Regional and Headquarters planning and management systems. xiii ------- ------- I. Introduction What are the most serious environmental risks facing different regions of our country today? What are the most effective and cost-efficient ways to address the problems that cause these risks? How can EPA communicate information about these risks to the public? To try to answer these and other challenging questions, EPA is sponsoring three Regional studies called "Comparative Risk Projects". Region 1 (Boston), Region 3 (Philadelphia), and Region 10 (Seattle) (see Figure 1) have completed the first year of their projects, and, encouraged by their findings and progress, are now in their second year. This report summarizes the objectives, the process, analytic methodologies, issues, and results of the first year of these projects, and plans for using the project results. Figure 1: Regional Comparative Risk Projects Region 10 Region 1 Region 3 1 ------- In recent years, the Office of Policy Analysis (OPA) within the Office of Policy, Planning and Evaluation (OPPE) at EPA Headquarters has conducted and supported a series of projects aimed at better integrating risk analysis into environmental priority- setting and decision-making at EPA The Comparative Risk Projects team this OP A experience with Regional expertise about local environmental problems in an organized framework to set risk-based priorities and deal with environmental problems most effectively. Estimates of risk are the common measure for comparing problems and setting priorities. Grounded in the concepts of risk assessment and risk management, Comparative Risk Projects use estimates of risk — the probability of adverse effects ~ as a common measure for comparing and setting priorities among environmental issues. These issues involve different pollutants, sources, and exposure pathways that may affect human health, ecosystems, and financial resources. In the past ten years we have learned about hundreds of chemicals present in our environment that pose some risks of causing cancer or other adverse health effects. Comparing the risks to help set priorities allows environmental managers to focus limited resources to achieve the greatest reduction in risk for a given cost of control. The projects are also intended to involve local participants in the Regions in managing and conducting the projects, ensuring that issues of greatest local concern are adequately addressed. During the first year of the projects, all three Regions identified, analyzed, compared, and ranked the risks posed by major environmental problems facing each particular Region. For each problem, project participants assessed the current risks posed to human health and to Regional ecosystems. Region 3 also assessed the welfare losses associated with each problem area. The second step of the projects, already started, is to develop and analyze initiatives to mitigate these environmental problems in order to answer the Regions analyzed risks to human health, ecosystems, and economic welfare. 2 ------- question: "What can we do about these problems?" The third step in the projects is to integrate the risk and initiatives analyses into Regional and national management systems, taking effective action on the projects' findings. The projects will improve current budgeting and planning decisions. These projects have been designed to build on and improve current EPA budgeting and planning processes. The Regions are aiming to establish solid, analytically-based Regional priorities for use in traditional Agency proceedings to bring resource allocation more in line with the Regions' high risk priorities. The Regions will do this at three levels: 1. at the Regional Office level, by allocating the limited amounts of discretionary resources they have available; 2. with Headquarters offices, through discussions formulating the Agency's national budget, and in negotiating commitments about the work to be accomplished once EPA's resources have been appropriated; and 3. with states during negotiations about what they will accomplish with EPA grants and in discussions about how the states use their own appropriated funds. Colorado, Pennsylvania, Vermont, and Washington, are also currently conducting comparative risk projects with EPA assistance. All but Pennsylvania have just recently started. This report focuses on the three Regional projects, but will present useful observations from the state projects. A. Comparative Risk Projects Address Major Challenges in Environmental Management Improving the Regions' processes for setting priorities will help them, and EPA 3 ------- as a whole, to address several challenges in environmental management. First, environmental decision-making is becoming more decentralized. In the early 1970's, at the time of the first nationwide public concern about the environment, pollution problems were obvious. Cities were blanketed with soot, untreated sewage was discharged into rivers, and dangerous pesticides were building up in the food chain. The Nation's response was strong and straightforward. Federal laws were passed to protect the air, the water, and the land, requiring minimum levels of pollution control by all sources of the pollutant in question. Today, nearly two decades of progress have generally provided the Nation with a good foundation of environmental protection. Some remaining environmental problems require uniform national or global programs. But others are very site-specific, requiring tailored controls at the Regional, state or local level for effective mitigation. Even some national problems may be strongly affected by local conditions such as land use patterns, the proximity of populations or sensitive environments to environmental hazards, or by meteorology, hydrology, and even personal preferences. These may be best addressed by local solutions. Regional, state and local offices will more and more frequently be making the basic decisions about which environmental problems deserve governmental attention and what the nature of that attention should be. The second challenge is the need to understand all the environmental problems facing our Nation, and to set priorities for management. Instead of the obvious pollution problems of the past, today we are confronted with much more insidious problems, often involving toxic chemicals. With advances in measurement techniques, we can detect toxic chemicals nearly anywhere: in food, in drinking water, and in household products. Public Some problems are affected by local conditions and require tailored local solutions. 4 ------- fear and scientific uncertainty about them has, at times, led to near hysteria. Public concern has, swung quickly from problems involving one "chemical of the month" to the next, DDT, asbestos, PCB's, dioxin, EDB. This leads to an increasing emphasis on risk analysis, the systematic evaluation of available information on the hazards, pathways, exposure and dose-response relationships related to problem areas. The evaluation of this information is supplemented by informed professional judgment where necessary. The analysis takes place within a consistent methodological framework with common groundrules for comparison of different problem areas. If environmental policy-making is to be anything other than reactive, we must use risk analysis to judge the relative importance of different risks. Risk analysis allows us to make rational comparisons between very different types of environmental problems — it is the best common denominator that we have. Once we have established risk-based priorities, they can be incorporated into a long-term planning framework to establish The third challenge in environmental management is one that These projects • js cornmon throughout government: concern for the Federal help managers work with deficit and tight budgets. Environmental programs remain limited budgets. overwhelmingly popular with the public, but even popular government programs are under budget pressure. Environmental managers must be sure to buy the most environmental protection possible with the resources available. This adds up to a need to set environmental priorities carefully. Agency managers must choose which environmental problems they will tackle, and then do it in the most Risk analysis is the best common denominator for making rational comparisons. effective programs. 5 ------- Managers must set priorities carefully. effective and efficient manner. The problems must be looked at in a systematic and integrated way to determine which are most in need of attention. And programs should be carefully designed to obtain maximum environmental results. In addition to measuring progress administratively by the number of permits issued, enforcement actions taken, or sources inspected, programs can gauge progress by measures of the ultimate goals -- to reduce damages to human health and the environment. B. Objectives of the Office of Policy, Planning and Evaluation The objective of these Comparative Risk Projects is to help participating Regions improve the way they set their priorities. A major share of the project benefits will accrue to the participating Regions. But we also expect national benefits. The projects will demonstrate a new, systematic way of setting risk-based priorities that can be widely adopted. The entire Nation will benefit to the extent that the input from the three Regions improves national environmental priorities. The specific objectives of OPPE in supporting these Regional projects are as follows: First, we want to demonstrate that comparative risk analysis can help substantially in environmental priority setting, and to learn which approaches work well. We hope additional EPA Regional Offices and states will do Comparative Risk Projects, and we would like to develop a general model for conducting them most successfully. ^Project, conducted at EPA Headquarters, produced the report Unfinished Business: A Comparative Assessment Of Environmental Problems in February, 1987. It ranked thirty-one environmental problems in terms of their A second OPPE objective is a better understanding of how Projects show risks in Recnnns nf the mnntrv rliffp.r frnm in risks vip.wp.rl in an 6 ------- total nationwide risks, and has provided substantial guidance to EPA in establishing national priorities. We now wish to acquire a more precise geographic understanding of these risks. Which problems are common to all or most regions? Which are of primary concern in only limited geographic areas? Are there any problems not of high risk nationally, but major concerns in specific regions? Are there problems that can be abated more effectively by adjusting a national strategy to local conditions? A picture of the variation of risks across the country will give EPA important information on which programs and priorities should be uniform nationally and which should be targeted geographically. Regions will have the analytical tools to participate more effectively in developing better national and local management strategies. comparative risk analysis helps OPPE and Regional participants to identify new or growing environmental problems. Finally, the understanding of which environmental problems are most serious and why helps EPA communicate this understanding to its constituencies: Congress, industry, state and local governments, and the public. This enhanced communication should help build a consensus regarding how society will address its environmental concerns. In a separate effort, EPA is evaluating the current Agency budget, planning, and management systems and developing a strategic planning proposal to help the Agency set Comparative risk analysis helps professionals understand problems better. A third OPPE objective is to promote knowledge of the principles of risk assessment and risk management and use of risk analysis throughout EPA. In addition to understanding problems and setting priorities, risk analysis can alert managers and staff to the problems of shifting risks across media. For example, some water treatment technologies will shift pollutants from water to air. The comprehensive review of environmental problems through 7 ------- risk-based priorities, link budget and planning systems, and improve ways of measuring environmental progress. The knowledge gained from these demonstration Comparative Risk Projects will enhance this process. The experience of Regional participants in these projects creates an environment where risk analysis is understood as a method for solving environmental problems. The project results help identify the most serious environmental problems and how they differ across the Nation. The projects serve as a model for setting risk-based priorities through the use of risk analysis, developing effective solutions to environmental problems based on an understanding of the factors causing the problem, and finding a way to implement those solutions. 8 ------- IL Analytical Approach to Ranking by Risk The primary objective in the first year of these projects for each Region was to develop a comparative ranking of the risks posed by the major environmental problems in the Region. The basic approach was to define the list of problems to be compared, to develop methods to analyze the risks posed by the problems, to collect and analyze relevant data, and to rank the problems using this data and the participants' best professional judgments. A- The Projects were Designed to Meet Regional Needs A major concern in designing the projects was to meet the perceived needs of each Region. Although Headquarters' Office of Policy Analysis supplied contract funds and provided guidance based on their experience with Integrated Environmental Management Projects and with Unfinished Business, each Region directed its own project. OPPE presented an analytical and process framework to each of the Regions, that the project participants then adapted to address what they identified as their project goals and priorities. There were differences in how the Regions defined the environmental problems * T they would compare, in what sorts of risks they investigated, in how the risk analyses were conducted, and in the extent to which risk management issues were considered in the first year. It was important to find an appropriate balance between competing objectives of: a) the desires of each Region, and b) a substantial consistency of approach and definitions so the three projects could be compared, both with each other and with Unfinished Business. On the other hand, to the extent the Regional approaches differ, we now have a broader base of experience with which to advise future sponsors of such projects about methodological choices. ------- The projects followed a generally consistent approach. The three Regional projects followed a generally consistent approach, with numerous small variations. In this section, we will note these variations, assess them, and point out where we believe differing conclusions across the Regions are a function of different methods, as opposed to real differences in risk. B. Each Region First Defined the Set of Environmental Problems The first task, defining the problems, required several important decisions. Problems were defined to match BP A programs. There are many ways to divide up the universe of all environmental problems. One might choose to divide by pollutants (e.g., benzene, microbials, cadmium), by sources (e.g., automobiles, power plants, USTs), by media (e.g., air, surface water), by geographical region (e.g., Alaska, Puget Sound, the Cascades), or by other factors. Each Region decided that the most useful scheme was to define the problem areas to correspond to major EPA programs. This produced a mixture of problems defined as pollutants, sources and media. EPA's air programs tend to divide by pollutant class (criteria air pollutants, air toxics, radon, etc.), the waste programs divide by source type (CERCLA sites, RCRA sites, USTs, etc.), but the water programs divide by both source type (industrial point sources, publicly-owned treatment works (POTWs), nonpoint sources), and media (wetlands, groundwater, drinking water). By defining the problems in this way, the Regions made it easy to translate the results of a ranking into implications for programs. Second, each Region chose to start with the list from Unfinished Business, for which thirty-one problem areas corresponding roughly with national EPA program areas had been defined, and then make modifications. 10 ------- The projects studied a comprehensive list of problems. Third, each Region made an effort to define a list of problems that was comprehensive, to match all the environmental risks the Region might feasibly address. The Regions dropped from the Unfinished Business list several problems that were not likely to be faced at the Regional level, e.g., global warming, ozone depletion, worker exposure to chemicals. The Regions did keep on the list other problems for which Regional Offices operate minimal or no control programs, because they judged that these control programs might be expanded, e.g., indoor air pollution, acid deposition, pesticides. The result was a list of about twenty problems for each Region, a number manageable for analysis and ranking. Fourth, the Regions decided whether or not they wanted to define the problems mutually exclusively. Some environmental risks might plausibly be included in any of several problem areas. For example, if a Superfund site contaminates groundwater used for drinking, the resulting health risk could be counted as a CERCLA site problem, a groundwater problem, a drinking water problem, or as all three sorts of problems. The same risk is covered by multiple EPA programs. When faced by overlaps like this, Regions 1 and 10 decided that it was acceptable to count the same risk in multiple problem areas. Region 3 decided, instead, that a risk should be counted in only one problem area, and that the problem areas should be mutually exclusive. The list of problem areas to be analyzed and ranked for each Region is shown below in Table 1. Most are defined consistently with what one would expect from the titles. In a few cases a problem area receives an unconventional definition, or the definition differs importantly from one Region to another. In some cases these differences have an important influence on the way a Region ranked a problem. In Table 1, we also identify the most important variations across the Regions. Complete definitions of the problem areas for each of the three Regions are in Appendix A. 11 ------- Table 1: Problem Areas Analyzed in the Regional Comparative Risk Projects Basic Problem Area Criteria Air Pollutants Acid Deposition Toxic Air Pollutants Indoor Radon Indoor Air Pollutants Other Than Radon Radiation Other Than Indoor Radon Industrial Point Source Discharges to Surface Waters POTW Discharges to Surface Waters General Definition Effects from six criteria air pollutants: sulfur dioxide, total suspended particulates, carbon monoxide, nitrogen oxides, ozone, and lead. Effects from wet and dry deposition of acidic compounds. Effects from outdoor toxic air pollutants, excluding criteria pollutants. Effects from indoor radon from soil, drinking water, building materials, etc. Effects from all indoor air pollutants excluding radon. Important Variations Across Regions All Regions exclude sulfates, acid deposition. Region 10 in its health ranking excludes particulates < 10 microns. All Regions include effects of sulfates and acid aerosols. Region 10 in its health rankings includes particulates < 10 microns. Region 1 considers asbestos in a separate Problem Area. Effects from naturally occurring and man-made radiation other than radon. Includes both ionizing and non-ionizing radiation. Effects from industrial effluents discharged from "discrete conveyances" such as pipes and outfalls. Effects from discharges from municipal wastewater treatment facilities. Also includes the effects from industrial facilities that discharge to POTWs. Region 1 includes only non-ionizing radiation. Region 10 excludes natural background radiation. Region 3 also includes air emissions from industrial wastewater treatment facilities. Region 3 also includes air emissions from municipal wastewater treatment facilities. ------- Table 1: Problem Areas Analyzed in the Regional Comparative Risk Projects Basic Problem Area General Definition Important Variations Across Regions Nonpoint Source Discharges to Surface Waters Drinking Water Active Hazardous Waste (RCRA) Sites Abandoned Hazardous Waste (Superfund) Sites Effects from pollutants that reach surface waters from sources other than discrete conveyances for effluents. Includes runoff, air deposition, discharge of contaminated ground water, releases from contaminated in-place sediments, etc. Effects from contaminants in drinking water at the tap. Effects from contaminants released into any medium (air, surface water, ground water, soil) by sites covered by RCRA. These are mostly sites actively managing hazardous wastes, but sites recently closed are included also. Includes facilities such as landfills, incinerators, storage units. Effects from contaminants released into any medium by abandoned, inactive hazardous waste sites. Includes sites on the NPL, potentially on the NPL, being addressed by states under similar programs, and any other abandoned sites. Region 1 attributes pollution from sediments to the source type that contaminated the sediments in the first place. Region 3 includes only contaminants not deriving from other problem areas. Region 10 splits problem into public and private systems. ------- Table 1: Problem Areas Analyzed in the Regional Comparative Risk Projects Basic Problem Area Non-Hazardous Waste Sites Underground Storage Tanks Other Ground-Water Contamination General Definition Effects from contaminants released into any medium by sites where non-hazardous waste is managed. Includes municipal solid waste landfills, industrial non-hazardous waste surface impoundments, municipal incinerators, mining waste sites, etc. Effects from contaminants released into any medium by underground storage tanks. Includes mostly gasoline tanks, but also chemical tanks, home heating oil tanks, and chemical storage tanks. Effects from ground-water contamination from sources not covered under other problem areas. Includes such sources as leaching of agricultural chemicals, septic tanks and underground injection wells. Important Variations Across Regions Region 1 splits into separate problem areas for municipal and industrial sites. Region 1 includes all storage tanks. Region 10 includes all storage units. ------- Table 1: Problem Areas Analyzed in the Regional Comparative Risk Projects Basic Problem Area Pesticides Accidental Releases Physical Alteration of Habitats General Definition Effects from pesticides through diverse pathways. Effects from accidental, non-routine releases of hazardous substances. Includes such events as oil spills, chemical plant releases, transportation accidents. Effects from physical activities that change ecological conditions. Excludes pollution or chemical impacts. Includes effects of activities such as dredging, filling wetlands, urbanization, silviculture, dumping of plastics and other litter. Important Variations Across Regions Region 1 has separate problem areas for pesticide residues on food and pesticide application. Region 3 includes residues on food and rista to applicators together. Region 10 has separate problem areas for application of pesticides and other pesticide risks (including residues, leaching, runoff, household use, etc.). Region 3 has no separate problem area for this, instead including accidental releases with routine releases under other problem areas. Region 3 and Region 10 both have separate problem areas for aquatic and terrestrial habitats. Region 1 has only a single problem area: Wetlands/Habitat Loss. In addition, Region 1 included several problem areas that had no counterparts in the other Regions: o Discharges to Estuaries, Coastal Waters, and Oceans from All Sources o Lead o Asbestos o Lakes, Ponds, Impoundments ------- C Each Project Set Common Analytical Ground Rules All three Regions (as well as Unfinished Business preceding them) adopted several important ground rules to structure the ranking of environmental problems. Projects compared ultimate effects, or risks. First, the Regions decided to analyze and compare environmental problems in terms of the ultimate effects (which we will call "risks") that they entail. The ultimate effects we are interested in are the final impacts to humans and the environment caused by a type of pollution: the number and types of human disease cases, the extent of ecological damage, and the amount of economic losses. EPA's authorizing statutes specify these ultimate impacts as the reason for the Agency's existence and the reason we try to mitigate environmental pollution. The Agency's mandate is to protect human health and the environment. We do not install scrubbers on electric power plants to reduce SOz emissions or to meet ambient air quality standards; we do it so that fewer people will get sick, fewer lakes will suffer ecological damage from acidification, and fewer outdoor materials will be damaged by airborne acids, needing repair or replacement. Projects analyzed residual risks-- those remaining given current controls. Second, the Regions focused on assessing the residual risks associated with each problem area. By residual risks we mean the risks that remain given current levels of controls in place and current levels of non-compliance with regulatory requirements. The Regions did not assess: 1) risks that have been abated, or risks as they would have been in the absence of control actions; or 2) risks that will be abated, or risks as they will be after current requirements are implemented and met. The Regions focused on residual risks because of an interest in what more they should do about environmental problems. They wanted to assume current controls as 16 ------- the base, ask what risks remain, and what they can do to further reduce them. This has several implications for interpreting the risk ranking results: o A problem area might be ranked as low risk for either of two quite different reasons: a) it is inherently low risk, or b) it is inherently high risk, but a successful control program has reduced it to current low levels. Because a problem area is low risk does not mean the control program to deal with it is unimportant. . o The rankings suggest areas of high remaining risk that might be addressed by additional control efforts, but provide no suggestion about where we might relax our current controls. Residual risks provide a guide to problem areas most in need of further efforts (more investment). They provide no indication of how much risks would increase if current controls were dismantled or if current enforcement efforts were reduced (part of what one should know when considering disinvestment). The4 analysis that supports the rankings will provide some clues, but additional risk analysis is needed to identify specific program changes. o A problem area can appear to be high risk now even though existing laws, and regulations will reduce it to low risk when they are fully implemented. For the above reasons, the risk ranking results cannot be translated directly into priorities for a Region. More important in this regard, though, is the third ground rule: in ranking the problem areas, the Regions have considered assessment was carefully only the risks associated with them. The Regions sought to keep separated from the risk ranking separate from consideration of other attributes risk management. that may be equally important in determining what we should do about the problems. These items such as cost, technical feasibility , of controls, public opinion, politics, and statutory mandates, are 17 ------- what we call risk management factors. Risk assessment has been carefully separated from risk management. Most of the Regions' work in the first year of these projects involves risk assessment only. In the first year, the Regions have asked only how serious each problem is in terms of the risks it presently poses. The answers — a list of problems ranked from most serious to least serious based on the risks that remain in spite of current controls ~ do not provide a complete guide to setting environmental priorities. We might find that a high risk problem should nevertheless be of low priority for Regional action because of lack of statutory authority, e.g., indoor air pollution. Or perhaps a lower risk problem deserves attention because of intense public concern, e.g., hazardous waste sites. The risk rankings do not provide a guide to selecting specific Regional projects to invest in or disinvest from. Evaluation of those options depends on more than the residual risk inherent in the problem area. Specifically, to assess any project proposal one would like to know the amount of risk it will abate (or the amount by which risk will increase, in the case of a disinvestment proposal), and its cost (or its cost savings, in the case of a disinvestment). The benefits and costs of any specific project proposal will not necessarily match the inherent riskiness of the problem area that it addresses. There may be a particularly good investment opportunity to reduce risks in a low residual risk problem area. There may be current EPA program activities aimed at a high risk problem area that could be cut back without any appreciable increase in risk. But there probably is a correlation between high residual risk problem areas and good investment opportunities, and between low residual risk problem areas and good disinvestment opportunities. Our risk rankings provide a rough guide to where to begin to look for investment and disinvestment opportunities. Specific budget shifts should depend on the analysis that supports the rankings as well as The risk rankings are a rough guide for resource shifts. Afore analysis is needed. 18 ------- on a different sort of analysis than has been completed thus far in the Comparative Risk Projects. Risk should play a principal role in setting priorities. And Priority-setting environmental. protection should be directed at reducing must balance risk and other demonstrated risks. But other factors, called risk management concerns. factors, are also important, and setting priorities must involve balancing numerous concerns. Where then does risk management — determining what EPA should do about environmental problems — come into these projects? In Regions 1 and 10, risk management has been addressed in the first year by separate risk management work groups that functioned independently of the risk ranking process. , These work groups developed ways of combining other factors with risk. Regions 1 and 10 have also begun the process of developing and analyzing strategies to respond to the environmental problems. Region 3 already had in place its Measurable Environmental Results Initiatives (MERITs) program, through which they could solicit and evaluate initiatives to address environmental problems, so they devoted staff time that could have been used for a risk management work group to analyzing welfare risk. Although the final ranking of problem areas was not completed until after the deadline for submitting MERITs, much of the information and analysis that went into the rankings also prompted some FY '88 MERITs. Each Region developed successful proposals for new projects and resource shifts based on the first year's risk management analyses. Many of these initiatives are now being implemented. In all three Regions, risk management is a main focus in the second year of the projects. Ail three Regions plan to integrate risk analysis and risk management to identify and analyze strategies for addressing risk (especially in the higher-ranked problem areas) in the most effective and cost-efficient manner, and incorporate All three Regions are analyzing risk management. 19 ------- these strategies into their operations. The Regions will move towards institutionalizing the comparative risk approach and findings into the Regions' decision-making. D. Each Project Analyzed Risks and Developed Rankings The Regions wanted to rank their environmental problem areas in terms of the severity of their ultimate effects, or risks. To do so, they considered the following types of risk: to human health, to ecological systems, and to economic welfare. Health risk: cases of human disease or injury caused by the environmental problem. The health effects ranged from cancer (e.g., lung cancer from indoor radon) to learning disabilities (from lead) to gastrointestinal disease (from pathogens in drinking water) to angina pain (from carbon monoxide) to numerous other non- cancer effects. Ecological risk: damage to the structure and function of natural ecosystems caused by the environmental problem. Some examples include: eutrophication of water bodies from nutrients in nonpoint source runoff, loss of species' range, breeding grounds and other effects from physical modification of habitat, and forests with reduced growth rates and increased susceptibility to pests due to exposure to high levels of ozone. Welfare risk: economic losses to human activities caused by the environmental problem. Examples include increased maintenance expenses for buildings and other materials exposed to acid deposition, reduced recreational use of water bodies polluted by industrial dischargers, costs of replacing or treating drinking water supplies contaminated by hazardous waste site leachate, and 20 ------- costs of treatment and lost productivity for individuals suffering adverse health effects. Also included under welfare risks are intangible damages, such as the adverse effects of odors or reduced visibility associated with air pollution, and the value of having the option to use currently unused resources in the future. Region 3 considered all three types of risks, producing three rankings. Regions 1 and 10 considered only health and ecological risks, developing two rankings of their problem areas. These two Regions are conducting analyses of welfare risks in the second year of their projects. Most environmental statutes clearly prescribe protection of human health and the environment as goals, but are much less explicit about protection of economic values. Regions 1 and 10 decided in the first year of the project to devote their resources to getting an early start on risk management concerns instead of evaluating welfare risks. occurring for nearly all the problem areas — risks in all three categories were attributed to the problem area. There was no effort to decide which type of risk was most important Some gray areas that fell between these three types of risk were resolved during the course of the analysis. Region 3 gave substantial thought to establishing a boundary between health and welfare risks. The health effects themselves due to environmental pollutants were counted as health risks, but costs of treating these diseases and productivity lost because of illness were counted as welfare losses. This did not represent double-counting risks, but simply that an environmental problem can simultaneously cause multiple types of risk. Environmental problems can cause several types of risk. Environmental problems may cause multiple types of risk. For example, elevated levels of ozone can cause human health damage (increased asthmatic attacks), ecological damage (reduced rates of growth of many plant species) and welfare damage (accelerated deterioration of rubber products). In such cases ~ 21 ------- The risks were analyzed by two or three separate work groups, one for each type of risk. Regions 1 and 10 established health and ecological work groups for risk analysis, while Region 3 established health, ecological and welfare work groups. Distinct rankings for each type of risk were produced in each Region. Thus, a problem, e.g. indoor radon, could rank high for human health risk, but low for ecological risk, and medium/high for The Regions considered combining the separate health, ecological, and, in Region 3, welfare rankings into a single aggregate risk ranking. Each Region decided not to do so. They believed there was no sound analytical or scientific basis for deciding which type of risk is most important. This was thought to be a policy question distinct from risk analysis that would require considerably more thought and discussion. It is, however, possible to compare how a specific problem area ranks across the different varieties of risk. Each work group in a Region, with very few exceptions, dealt with problem areas that were defined identically. Each work group used the same analytical ground rules, and each had a clear specification of the boundaries of the type of risk they considered. There have been other opportunities for EPA Regions to express their opinions on which environmental problems are most pressing, but the Comparative Risk Projects are unique in that they seek to generate a priority ranking in a systematic, objective, and data-driven way. The projects aimed to generate as much quantitative data on risks as possible, but faced some inevitable constraints: Separate work groups analyzed each type of risk and developed a ranking. welfare risk. The Regions did not combine their separate rankings. 22 ------- o Considerable staff time and budget resources were expended on these projects. It would have been impossible to marshall enough resources to complete a full quantitative risk assessment on each problem area before comparing and ranking them. Full risk, assessment, in which data on emissions and ambient concentrations are collected, exposures are modeled, and ultimate impacts are projected, is very costly. o Even if resources had been unlimited, risk analysis is an uncertain process. Subjective interpretation of the results of any risk analysis is always necessary, weighing the strength of the data base used and the validity of the assumptions made. estimates and assessments. To stretch our resources, we relied extensively on . risk analyses that had already been done for other purposes prior to the Regional Comparative Risk Projects, and adjusted them to suit our needs. The work done on Unfinished Business was particularly helpful. In many cases, we extrapolated from existing analyses that covered only part of what we were interested in -- only some of the pollutants of concern, only some of the Region, or only some of the damage pathways encompassed by a problem area. For example, for each of the three Regions, a contractor modeled the Regional health risks from about twenty toxic air pollutants. But there are far more than twenty The projects supplemented data with expert judgement in an objective manner. We used the expert judgment of EPA Regional staff knowledgeable about local environmental problems to evaluate available data and analyses. We decided to quantify our results to the extent available data and time allowed, to recognize the universal; need to supplement the data with judgment, to make the judgments in an objective and consistent manner, and to address significant gaps in data through future refinement of the 23 ------- in total. The health work group in each Region then had to decide whether the twenty modeled pollutants constituted a large or a small fraction of the total risks. The Regions relied on the judgment of their air program staffs and expert consultants, and on information in Unfinished Business to make this decision, and adjusted upward the risk estimate for the fraction of the problem studied to represent the entire problem. In addition to the modeled data on air toxics, each Region accumulated differing amounts of monitored data on several toxic air pollutants. Each work group then made judgments about how to combine very incomplete monitoring data with somewhat more complete, but less accurate, modeled data. As might be expected, the ultimate decisions on how to interpret such diverse data varied across Regions. Regional work groups often relied on analyses that had been done for other geographic areas and adjusted them to fit the Region. They made qualitative adjustments to estimates of different quality in order to make them more comparable, e.g., where one analysis was based on highly conservative, worst-case assumptions while another analysis was based on more realistic assumptions. In many cases, there were simply data gaps that a work group had to fill by using their professional judgment. In sum, the rankings should be viewed more as the informed judgment of each EPA Region's professional staff, based on quantitative data to the extent possible, than as the results of a scientific risk assessment. No scientific group has done a peer review of the Regional results or analyses, because the results are fundamentally not science. But they are not simply opinion either. The Regions collected large amounts of data and conducted extensive analyses. They took great pains to make their judgments, where necessary, in a systematic and objective fashion. The rankings were done with carefully developed methodologies for each of the types of risk. Although the methods were not perfect, they imposed consistency and objectivity in each problem area. In addition, each work group conducted their analyses and developed their rankings in collegial fashion, with the entire group having the opportunity to question and debate major points. 24 ------- IH Process and Participants The Regions used a similar process throughout the first year of their Comparative Risk Projects. The processes are expected to diverge more in the second year as the Regions pursue more particularized means to expand the first year's findings and to implement them. The major elements of the Regional projects to date follow. A. Getting Started Regional Administrators (RA's) and Deputy Regional The projects Administrators (DRA's) in • the three Regions, as managers of provide analytical environmental protection efforts by all the Program Offices, were support for interested in the potential a Comparative Risk Project has for Regional priorities. assisting in environmental decision-making across all media. Each of these Regions was also interested in increasing their flexibility to address problems that they felt should have a higher priority then the National Program Managers did (or a higher priority in the Region than nationally.) The National Program Managers generally felt that a Region that could support its priorities with solid risk-based analysis could make the best case for being given the needed flexibility for implementing those priorities. The Comparative Risk Projects seemed to be the best way of accomplishing that goal. The RAs and DRAs recognized the need to involve the Division Directors from each Program Office in their Regions in these projects to get the benefit of staff expertise in conducting the projects and to insure the credibility of the results. The Division Directors served on the Project Steering Committee, which set the direction for the project and reviewed the analyses prepared by the technical work groups. Region 10 also included a representative from a state environmental program. The Steering Committee 25 ------- meetings were usually chaired by the RA or DRA, and were attended by Division Directors, Branch Chiefs, and other managers. The Steering Committees typically reviewed and approved the project workplans, ground rules, ranking methods, and results. Each Region designated one or more project coordinators. Region 1 created and advertised a position to manage the project. It was filled by an individual with substantial risk assessment experience. Several individuals from Regional program offices were subsequently detailed to help her. Region 3 designated an individual in the planning branch of the Environmental Services Division who had managed the Region's process for selecting MERITs ~ cross-media Regional initiatives. Region 10 selected a former director of one of their state environmental departments. At Headquarters, the Geographic Integration Branch in OPA provided assistance to the Regional projects. A staff analyst was assigned full-time to support each of the three projects. The individual supporting Region 10 was detailed to the Region to help. In addition, other staff provided assistance as needed on particular topics. mid-level managers. Region 10 included a representative from a state environmental program on each of their work groups. All major EPA programs were represented on each work group, in order to provide them with the breadth of substantive expertise about environmental problems needed to perform their cross-cutting tasks. The Regions tried to assign individuals with experience and training in health, ecological or welfare risk assessment to appropriate work groups. The result was a wide range of methodological Regional work groups performed analysis and prepared the rankings. Each Region formed work groups, which performed the bulk of the project analysis and prepared the rankings. Regions 1 and 10 each formed three work groups: health risk, ecological risk, and risk management. Region 3 formed three work groups also: health risk, ecological risk, and welfare risk. Each work group consisted of 10-20 individuals, mostly Regional technical staff but including a few Regional managers. The work groups were all chaired by 26 ------- expertise on each work group. In the first year, more than one hundred and fifty individuals from the Regions and Headquarters have participated extensively in the three Regional Comparative Risk Projects, - •——— ¦ This is a resource-intensive process. Each Regional project has invested the following approximate staff and budget resources: . o Thirty to forty professional staff people served as work group members. They spent 5-10% of their time on the project. o Steering Committee functions took about five two-hour meetings by all senior Regional managers. Additional uncounted time was spent for project initiation, supervising staff, and implementing findings. o One to three professional staffers served full-time as project managers. o About 1 .work year from OPPH in analytical and administrative staff support was provided for each Regional project. o $125,000 - $150,000 in contract resources was provided by OPPE to assist the work groups in developing their ranking methodologies, gather data and perform analyses. ' ¦ 27 ------- B. Establishing the Analytical Framework Starting points for the problem area lists and the analytical ground rules were provided by Headquarters staff to each Region. These drafts were based generally on Unfinished Business, modified to fit a Regional context and Regional interests. Each Region modified these drafts to suit their wishes, typically by the project management staff and the Steering Committee. In Region 10, the work groups were also involved in defining the problem areas and as a result some are defined differently across the work groups. Developing analytical methods for comparing and ranking the problem areas was the first major task for the health, ecological, and welfare work groups. These methods would provide a structure determining the type of data to be collected and analyses to be conducted for each problem area by each work group. The methods would also impose a consistent approach across problems, enhancing the objectivity of the comparative rankings. Designing these methods was quite difficult, because many work group members were not yet familiar with standard risk assessment techniques in their assigned area. Some standard methods do exist, e.g., for assessing cancer risks and for monetizing some welfare damages, but major questions have not been resolved about how to assess non- cancer risks, how to combine cancer and non-cancer risks, how to conduct ecological risk assessment, and how to value most types of welfare damages. The work groups basically had to design their own new methods to meet these needs. 28 ------- OPPE staff, contractors, and Regional project management staff all worked with the groups to develop methodology options. Three methodology option papers (one each for health, ecological, and welfare risk analysis) were prepared and circulated by OPPE. Each work group spent about four two-hour meetings discussing and developing methodologies, and continued to modify their original methods as the analysis progressed. Each work group developed a method based roughly upon the paradigm for risk assessment. Because of the broad scope of the necessary analysis, the methods diverged substantially from traditional quantitative risk assessment. One might imagine conducting a traditional risk assessment for all the pollutants associated with each problem area, summing across pollutants, and then comparing the estimated risks for each problem. In fact, that would be an impossibly large task. Most problem areas involve numerous pollutants (sometimes potentially thousands of toxic pollutants), each of which may cause several damaging effects, and each of which occurs in thousands of different patterns of exposure across the nation. The risk analysis methods used for the Regional Comparative Risk Projects generally consisted of: o Identifying representative or typical exposure scenarios for representative pollutants associated with each problem area, o Calculating risks for the chosen scenarios using generally available information on hazards and dose-response relationships, and o Scaling up to the entire problem area. For health risks the methods included: 1.) selecting chemicals representing each problem area, 2.) estimating individual and population risks for cancer effects using OPPE, contractors, and Regions worked together to develop analytical methods. 29 ------- The Risk Assessment Process In the simplest sense, risks from environmental pollutants are a function of two measurable factors: hazard and exposure. To cause a risk, a pollutant has to be both toxic (present an intrinsic hazard), and be present in the environment at some significant level (thereby coming in contact with humans, plants, animals or materials of economic value). Risk assessment interprets the evidence on these two points, judging whether or not an adverse effect will occur, and usually making the necessary calculations to estimate the extent of total effects. Risk assessment will normally consist of the following'four steps: 1. Hazard identification involves weighing the available evidence and deciding whether a substance exhibits a particular adverse effect. Most attention has been focused on human health effects, particularly cancer, but hazard identification can extend to ecological damages (e.g., does suspended sediment in water damage fish reproduction?) and to welfare damages (e.g., does ozone damage plastics?) as well. f j y 2. Dose-response assessments determine potency -- how strong a particular adverse effect is caused by a pollutant at various levels of exposure or dose. 3. Exposure assessment entails estimating the concentrations, frequency and duration of human exposure to pollutants of concern, the routes or pathways of exposure (how the pollutant gets to the person), and the number of persons exposed for various combinations of exposure and pathways. The best method is direct measurement or monitoring of ambient conditions, but this is often prohibitively expensive. In practice, risk assessors usually rely on estimates of emissions and limited monitoring information, combined with mathematical models that estimate resulting concentrations. 4. Risk characterization estimates the risk associated; with the particular exposures in the situation being considered. While the final calculations are straightforward (exposure multiplied by potency equals risk), the way in which the information is presented is important. The final assessment should display all relevant information, including such factors as the nature and weight of evidence for each step of the process, the estimated uncertainty of the component parts, and the distribution of risk across various sectors of the population. 30 ------- standard Agency methods for the chemicals, 3.) estimating non-cancer effects for the chemicals using various approaches, 4.) scaling up from the selected representative chemicals to the entire problem area, and 5.) combining information on cancer, non- cancer, individual and population risks. The ecological risk assessment methods were much broader, focusing on aggregate judgments about the intensity and geographic extent of ecological damages from each problem. The welfare risk method (Region 3 only) relied on estimating the total monetized damages caused by each problem area, modified by factors relating to the scope of the affected area, the severity of impacts to affected individuals, and the reversibility of the damages. More details on the specific methods used by each Region are included in the individual Regional reports. (See Preface and Supplementary Reading list.) C Analyzing and Ranking the Problems The lead work group member for each problem area was responsible for deciding on a plan for analyzing the problem area that conformed with the work group's methodology, collecting the necessary data, performing the analysis, and reporting the results to the entire work group. ^^ first step for the problem-leaders was to prepare "Plan of Leaders for Attack" (POA) papers for each problem. These outlined the data each problem presented and analysis proposed for each problem, and typically relied on analysis to national analyses modified to reflect data sources thought,to be work groups. available to the Regions. No Region-specific data was actually acquired, this was left for the analysis step. The problem-leaders presented their POAs to the entire work group for review so inconsistencies or flaws could be spotted before they were put into action. 31 ------- Work group members next worked closely with contractors, Regional, and OPPE staffs to gather data and conduct the analyses. Papers summarizing the results of the analyses were written by or provided to the problem-leaders. This analysis took place over a three-month period. Rankings were developed by the work groups in all-day "or^oups meetings. In these meetings, the problem leads presented the problems in all- results of the analyses to the other work group members. The day meetings. processes used for ranking then differed across the work groups. Some were quantitative, in which the work .group used explicit procedures to score a set of predetermined factors for each problem area and combine the scores into a total score for each problem. The ranking was then given by the rank- ordered scores for the problems. At the other extreme, some work groups used a qualitative process. They simply reviewed the available information on risks from the problem areas, and worked to develop a group consensus on an overall ranking of problems. In this approach, each work group member might have different ideas about the key factors involved in ranking, and how these factors interrelated. More specifically, the ranking methods used for the three types of risk were as follows: Health risk approach: Region 1 developed information on individual and population risks for cancer and non-cancer effects for each problem area. They developed a cancer ranking and a non-cancer ranking, then used a qualitative consensus process to combine them into a single health ranking. The ranking places each problem into one of five relative risk categories, but problems 32 ------- within a risk category are not ranked against each other. Region 3 developed information and created rankings for four categories of health risk: population and individual risks, for cancer and non-cancer effects. They tried a variety of mathematical techniques for combining the four rankings, evaluated them, and after lengthy discussion settled finally on a group consensus that weighs cancer and population risks most heavily. All problems were ordinally ranked against each other. Region 10 developed information for each problem area on cancer effects, non- cancer effects from chronic exposures and non-cancer effects from acute exposures. Each individual on the work group then ranked the problems by the three health effect categories and overall (combining the three effects however each individual thought appropriate) and the team members' rankings for each problem were then averaged. The work group then refined this preliminary ranking in a group discussion. The ranking places each problem into one of five relative risk categories, and problems within a risk category are not ranked against each other. Ecological risk approach: The Region 1 work group identified the ecological stressors associated with most problem areas. Ecological damages associated with each stressor in 10 different types of ecosystem were evaluated. Risk estimates were aggregated across stressors within each problem area/ecosystem combination. Finally, risks for each problem area were aggregated across the ecosystems, and the problem areas were ranked. The work group had great difficulty deciding which ecosystems were of more importance. The final ranking places problems in one of three risk categories based upon the highest score for the problem for any ecosystem. Problems within a risk category are not ranked against each other. The Region 3 work group defined distinct ecosystems of interest and identified the stressors associated with each problem area. They then qualitatively assessed the 33 ------- impact of the stressors and scored each problem area for four criteria: (1) level and duration of ecosystem exposure to stressors at levels resulting in toxicity; (2) reversibility/permanence; (3) volume and geographic extent of contamination sources; and (4) geographic extent of damage to ecosystems. The work group derived consensus scores for each of the four criteria focusing mostly on the effect of stressors on ecosystem function. The total score for a problem was the sum of its criteria scores, and the problems were ordinally ranked on the basis of their total scores. The Region 10 work group members each scored every problem area for five criteria: (1) intensity of ecological impacts, (2) their scale, (3) their reversibility, (4) trends (whether the problem is getting better or worse over time), and (5) the importance of the ecosystems affected. Each member ranked the problem areas based on a common mathematical formula for combining these scores and also ranked the problems using whatever procedure he or she wished. Each individual thus produced two rankings. The entire group reviewed all these rankings, and produced a single summary ranking after lengthy discussion. The summary ranking places problems in one of four groups. Problems are also ranked against each other within groups, but with much less confidence than is associated with the ranking by groups. Welfare risk approach: Region 3 is the only Region to complete a welfare analysis and ranking in the first year. The work group carefully defined each category of welfare damage caused by a problem area, e.g., materials damage, recreation, aesthetics. They then developed a scale for systematically scoring the welfare impact of each problem area, and assigned scores. The scores depended primarily on an estimate of the total dollar damage by the problem in that damage category, modified by scores reflecting: (1) the geographic extent of damages; (2) the level of impact to the affected individuals; and (3) reversibility. Scores were summed across damage categories, to give a total score for each problem area. Problems were ordinally ranked on the basis of their total scores, then were also grouped 34 ------- into one of three categories of relative risk. Because the members understood the limitations of the methodology, they felt more confident in this high/medium/low grouping. D. Developing Solutions to Environmental Problems Regions 1 and 10 decided to start in the first year on analyses that would be helpful in risk management, and work groups were assigned to the topic. Region 3 planned to use its MERITs process for developing initiatives to address high-risk The Region 1 work group identified and evaluated potential factors which should be considered by Regional management in developing strategies to reduce risks associated with each of the environmental problem areas. This was to supplement the risk analysis conducted by the health and ecological risk work groups by overlaying "real world" considerations on the decision-making process. The risk management factors evaluated for each problem included: (1) public perception, (2) availability of Regional office resources, (3) economic impact of controls, (4) legal authorities to reduce risks, and (5) the effectiveness of available control techniques. Each factor was scored on a scale of one to five, with one indicating that the problem was difficult to manage and five indicating that the problem was easy to manage. The result was a matrix showing the score for each problem area for each factor. It was decided not to combine the scores into a single overall total, since the work group could not agree on a way to reflect the relative significance of the different factors in the decision-making process. Region 10's "risk reduction team" was charged with developing and evaluating proposals to alleviate risk, especially in areas targeted as high-risk. The Region 10 team assigned a member to each problem area being analyzed. These individuals were responsible for understanding the risk assessment findings and for creating risk reduction problems. Regions 1 and 10 analyzed risk management in work groups. Region 3 used MERITS. 35 ------- strategies in those areas. The team then developed an explicit set of ranking criteria for evaluating strategies that emphasized legal, technical, and political feasibility, cost, and potential risk reduction. Next the team sought risk reduction strategies from Regional and state environmental personnel. A detailed nomination form was used to encourage all strategy writers to provide consistent and relevant information about their proposals. Team members in some cases helped with developing strategies, or wrote and submitted their own. Forty-two strategies were proposed. The team then scored the strategies using the evaluative criteria, resulting in two rankings: one based on effectiveness in addressing ecological risks, and one for human health risks. The team submitted its top-ranked ecological and human health strategies to the Steering Committee for its consideration. Regional management decided to pursue budget proposals to implement eight strategies as a result of this work. E. Senior Management Approval and Documenting the Work In the three Regions, the work groups' risk rankings were The Steering presented to the Steering Committees. No Steering Committee Committees ratified the chose to modify the rankings, preferring to rely on the analysis work groups and technical judgments of the work groups. In addition, no rankings. Steering Committee chose to combine the separate rankings (health, ecological, welfare) into a single aggregate ranking. This choice not to combine rankings may make the task of allocating resources according to risk priorities somewhat more difficult. But the task of combining the separate risk rankings is complex. Not only would decision-makers need to value, or weight, different types of risk, but they would also need to consider another issue. Because the problem areas were only ordinally and not cardinally ranked, the difference in risk between the #1 and #2 problem areas may be much different than that between #2 and #3, and the difference in risk between the first and last ranked problem areas for health risk may 36 ------- different from that for ecological or welfare risk. After Steering Committees approved the rankings, each Region is writing a report summarizing the results of the first year of its project. The Region 1 report has been released and is available from the National Technical Information Service. (See the Supplementary Reading list at the end of this report for more information.) The Region 3 and Region 10 reports are expected to be available from the Regional offices listed in the Preface. 37 ------- IV. Major Products and Benefits of Year One The major products of the first year in each of the Regional Comparative Risk Projects are twofold. The main product is the rankings based on the residual risk of problem areas and the data and analysis that support these rankings. Another important product is the risk management analysis and proposals. The second type of product is less tangible but no less valuable: it is the increased understanding of risk assessment and risk management by all the project participants, the development of a "cross-media" perspective, and the improved ability to set priorities among competing environmental concerns. In the first part of this chapter we describe these ranking results, compare them across Regions, and contrast them with findings from Unfinished Business and current national priorities. In the second part of this chapter, we discuss ways of using the rankings to reduce actual environmental risks as well as the other procedural benefits of the projects. A Substantive Findings Ranking Results for Each Region Figures 2, 3 and 4 below show the risk ranking results for each of the Regions. Each Figure shows the problem areas ranked from highest risk to lowest risk. Region 1 ranked as its most serious health problems criteria air pollutants (driven by large scale exposure to high ozone levels across the Region), indoor radon (up to 1500 cancers annually), and lead (serious health effects primarily among children from ingestion of soil or inhalation). The highest ecological risks were attributed to criteria air pollutants, acid deposition, industrial point source discharges, POTW discharges, nonpoint 38 ------- Health o Criteria Air Polutants (Ozone) o Radon o Lead Figure 2: Ranking of Problem Areas by Region 1 o Add Deposition and V&bifty (includes particulates) ~ Indoor Air Polutants Other than Radon o Industrial Point Source Discharges to Surface Waters ~ Drinking Water o Other Groundwater Contamination o Pesticide Residue Foods HIGHER RISK o Hazardous/Toxic Air Polutants o Asbestos o Discharges to Estuaries, and Oceans o Nonpoirrt Source Discharges to Surface Surface Waters o POTW Discharges to Surface Waters, o Accidental o Releases From Storage Tanks o Pesticide Appication NO 0 Radiation from Sources Other than Radon (non-ionizing) o RCRA Waste Sites o Superfund Waste Sites o Municipal Waste Sites o Industrial Waste Sites Ecological o Criteria Air Polutants o Acid Deposition and Visibility o Industrial Point Source Discharges to Surface Waters o POTW Discharges to Surface Waters o Nonpoint Source Discharges to Surface Waters o Habitat Loss a Accidental Releases o Superfund Waste Sites o Industrial Waste Sites o Municipal Waste Sites o Other GW Contamination o Pesticide Residues on Food o Pesticide Application o RCRA Waste Sites o Releases from Storage Tanks Note: Region 1 problem areas are unranked within each boxed category. LOWER RISK oRadon O Indoor Air PoRutants Other Than Radcn o Drinking Water o Lead o Asbestos o Radiation From Sources Other than Radon (Non-Ionizing) * These problem areas were not ranked because of low eco risks. ------- Figure 3: Ranking of Problem Areas by Region 3 Health i i Ecological Welfare z © X m u (/> * O m 30 3D £ T o Indoor Air o Indoor Radon o Other Pesticide o Radiation o Nonpolnt Sources o Water Supply o Acid Deposition oPOTWs o Criteria Air o Other Groundwater o Industrial Point Sources o RCRA Sites oCERCLA Sites o Air Toxics o Solid Waste o Terrestrial Habitat Modification o USTs o Aquatic Habitat Modification o Terrestrial Habitat Modification o Aquatic Habitat Modification o Nonpolnt Sources o Acid Deposition o CERCLA Sites o Criteria Air o Air Toxics o USTs o Industrial Point Sources o Radiation oPOTWs o RCRA Sites o Solid Waste o Indoor Radon o Indoor Air o Other Groundwater o Other Pesticides o Water Supply o Criteria Air o Acid Deposition o Nonpolnt Sources o Water Supply o Indoor Air o Indoor Radon o Other Pesticides oPOTWs o Radiation o USTs o Industrial Point Sources o Other Groundwater o RCRA Sites o Terrestrial Habitat Modification o Solid Waste o Aquatic Habitat Modification oCERCLA Sites o Toxic Air Pollutants Note: The Region 3 problem areas are ordinally ranked for each risk type. The Region 3 Health and Welfare Work Groups also divided each ordinal ranking into High, Medium, and Low categories. The Welfare Work Group had more confidence in this grouping than in their ordinal ranking. See the Region 3 report for details. ------- Health Figure 4: Ranking of Problem Areas by Region 10 o Indoor Radon o Other Indoor Air o Pesticides o Air Toxics Plus PM10 o Non-Public Drinking Water o Public Drinking Water o Other GW o Criteria Air Pollutants HIGHER RISK o Nonpolnt Sources o POTWs o Accidental Releases o Hazardous Waste Sites, Abandoned o Other Radiation o Releases from Storage Units o Industrial Point Sources o Current Hazardous Waste Sites o Non-Hazardous Waste Sites Ecological o Nan-Chemical Degradation -Terrestrial o Non-Chemical Degradation - Aquatic o Pesticides o Nonpolnt Sources o Industrial Point Sources o Criteria Air Pollutants o POTWs LOWER RISK o Accidental Releases o Add Precipitation o Hazardous Air Pollutants o Active Hazardous Waste Sites oAbandoned Hazardous Waste Sites o Releases From Storage Units o Non-Hazardous Waste Sites o Other Radiation Note: Region 10 problem areas are unranked within each boxed category for health risk. They are ordinally ranked within the boxes for ecological risk. ------- sources, habitat losses, and accidental releases. Region 3 ranked as its most serious health problems indoor air pollution (despite poor data, a wide variety of adverse health effects and extremely broad exposure) and indoor radon (causing about 1700 cancers annually). The highest ecological risks were attributed to physical modification of both terrestrial and aquatic habitats (because they are widespread, can cause devastating impact, and may be irreversible), with nonpoint sources close behind. The highest welfare risks were believed to be caused by criteria air pollutants (materials damage, crop damage, and forest damage) and acid deposition (visibility losses, health care costs, materials damage, and forestry damage). Region 10 ranked as its most serious health problems indoor radon (based on strong data, and areas of high natural radiation), other indoor air pollution (caused especially by tobacco smoke, formaldehyde, volatile organic compound mixtures, microbials), pesticides (both immediate effects from application as well as effects from residues on food and aerial drift) and air toxics plus particulate matter less than ten microns (because of cancer risks from air toxics, and high non-cancer risks ~ including death — from high particulate exposures in about a dozen cities). The highest ecological risks were caused by non-chemical degradation of terrestrial and aquatic ecosystems (again because of wide scale effects that are often severe and occur in high-value ecosystems), pesticides (due to high toxicity, large scale, and increasing use) and non-point source discharges (problems from agriculture, forestry, urban runoff and failing septic systems). Findings for Major Problem Areas In this section, we display the three Regions' findings for each of the major problem areas. In order to simplify the presentation, we take some liberties by grouping together problems that are defined somewhat differently across the Regions. The findings for the major problem areas are shown below in Table 2. 42 ------- lauie z: oummary or rinaings ior Major fro Diem Areas Rankings by Region Risk Problem Area Region Ranking General Comments Specific Regional Comments Criteria Air Pollutants Human Health Risk R1 R3 RIO High Medium Medium Large numbers of low severity non-cancer effects and no cancer effects. Definitions more restrictive than typical. Rl: High ranking due to ozone. Definition excludes lead, particulates and acid aerosols. R3; Definition excludes sulfates. RIO; Definition excludes PM 10 Ecological Risk R1 R3 RIO High Medium/high Medium/high Experimental data on growth declines for trees and crops exposed to criteria air pollutants cited. Effects of acid deposition excluded and counted in its own problem area. Rl: Documented adverse impacts in Region R3, RIO: Damages expressed, but not observed and documented in Regions, Welfare Risk R3 High R3: Ranked highest, at about $1 billion annual damages. -P»- u> Air Toxics Human Health Risk Rl R3 RIO Medium Low High Similar data available to each Region on modeled concentrations of about 20 chemicals. R3:Low ranking attributable to finding no evidence of non-cancer effects. R10:High ranking may be due to inclusion of PM10. Ecological Rl Unranked Data on impacts virtually non-existant in all 3 Risk R3 Medium/high Regions. RIO Medium Welfare Risk R3 Low R3:Only health care costs were examined. Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10, ------- Table 2: Summary of Findings for Major Problem Areas Rankings by Region Risk Problem Area Region Ranking General Comments Specific Regional Comments Acid Deposition Human Health Risk R1 R3 RIO Medium/High Medium Unranked R1,R3: Ranked acid deposition high due to debatable adverse effects from acid aerosols and airborne sulfates. Ecological Risk R1 R3 RIO High Medium/High Medium Different ranking by Regions because of varying geographic factors. Rl; Significant acidification in lake, forest decline. R3: Widespread potential, but unproven terrestrial effects. Some damage in surface waters. RIO: No current adverse impact measured. Welfare Risk R3 High R3: Second leading cause of welfare damage at over $500 million per year. -j^ Indoor Radon Human Health Risk Rl R3 RIO High High High First or second leading environmental cause of cancer in each Region. High indoor radon levels in all three Regions. Ecological Rl Low Risk R3 Low RIO Low Welfare Risk R3 Medium/high R3: Damages high due to large number of cancers causing high medical treatment costs and lost productivity. Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10. ------- Table 2: Summary of Findings for Major Problem Areas Rankings by Region Risk Problem Area Region Ranking General Comments Specific Regional Comments Indoor Air Pollution (other than radon) Human Health Risk R1 R3 RIO Medium/high High High Regional ranking difference relates to how each Region scaled up from limited data. Environmental tobacco smoke considered important factor. Rl: Asbestos ranked as separate problem area, which lowers ranking relative to other Regions. Ecological R1 Low Risk R3 Low RIO Low Welfare Risk R3 Medium/ high R3: Ranked as a medium/high welfare cost due to high health costs. ^ Radiation (other than radon) Human Health Risk Rl R3 RIO Low Medium/high Low In all Regions, increased radiation doses from human activities (i.e. nuclear fuel cycle,waste disposal) considered minimal. R3: Has higher ranking because they include natural background outdoor radiation. Ecological Rl Unranked Risk R3 Medium RIO Low Welfare Risk R3 Medium R3: Ranked medium due to costs of adverse health effects from natural background radiation. Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10. ------- Problem Risk Area Table 2: Summary of Findings for Major Problem Areas Rankings by Region Region Ranking General Comments Specific Regional Comments Industrial Point Source Discharges to Surface Waters Human Health Risk R1 R3 RIO Medium/high Medium/low Low Rankings reflect geographical and definitional differences among Regions. Effects through both fish consumption and drinking water. Rl: Included effects from contaminated sediments (PCBs and mercury); contaminated sediments included as non-point sources in R3 and RIO. Rl has more industrial discharges with substantial toxics near population centers than other Regions. Ecological Risk R1 R3 RIO High Medium Medium/high All Regions developed rankings based on biennial state reports on quality of their surface waters (305(b) reports). Welfare Risk R3 Medium/low R3: About $30 million annually in damages. •Ct POTW Discharges to Surface Water Human Health Risk Rl R3 RIO Medium/low Medium Medium/low POTWs typically discharge fewer toxics than industrials, but have more microbial pollutants. R3,R10: More concerned with the effects of bacteriological contamination. Ecological Risk Rl R3 RIO High Medium Medium/high Rankings based on biennial state reports on quality of their surface waters (305(b) reports). Welfare Risk R3 Medium R3: About $90 million in annual damages to recreation and aesthetics. Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10. ------- Table 2: Summary of Findings for Major irobiem Areas Rankings by Region Risk Problem Area Region Ranking General Comments Specific Regional Comments Non-point Discharges To Surface Water Human Health Risk R1 R3 RIO Medium Medium/High Medium/Low All Regions agreed that bacteriological problems in drinking water and fish and bioaccumulated toxics in fish represent primary risk pathwys. Ecological Risk R1 R3 RIO High High High Data from biennial state reports on quality of their surface waters (305(b) reports) showed non-point sources to degrade more water bodies than point sources. Welfare Risk R3 Medium/High R3: About $265 million in annual damages to recreation, aesthetics and domestic water consumption. Drinking Water -J ^ Contamination Human Health Risk R1 R3 RIO Medium/high Medium/high Medium/high Definitional differences are important to Regional rankings. See specific Regional comments. Rl: Included lead in separate category and found moderate cancer risks and important non-cancer risks from drinking water. R3: Defined drinking water to exclude contaminants from sources covered elsewhere. This included only risks from corrosion (lead) and trihalomethanes. RIO: Split drinking water risk into public and private systems. Private systems have fewer people exposed, but higher individual risks. Ecological R1 Low Risk R3 Low RIO Low Welfare Risk R3 Medium/high R3: About $25 million in annual damages attributable from corrosive water and health costs from corrosion and trihalomethanes. Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10. ------- Problem Risk Area Table 2: Summary of Findings for Major Problem Areas Rankings by Region Region Ranking General Comments Specific Regional Comments Other Groundwater Contamination Human R1 Medium/high All three Regions found highest risk to be large Health R3 Medium numbers of microbial disease cases from septic Risk RIO Medium/high and other sources, primarily affecting private wells. Ecological R1 Medium/high Rl: Ranked higher due to impact of nutrients Risk R3 Low from septic tanks on eutrophication of lakes and potential contamination of drinking water sources. RIO Unranked R3: Ranked low since surface discharge of contaminated groundwater counted as non-point source. Welfare R3 Medium/low R3: About $25 million in annual costs, to treat water Risk supply, and losses in value of groundwater for future use. Abandoned Hazardous Waste (CERCLA) Sites Human Health Risk Rl R3 RIO Low Medium/low Medium/low Based largely on worst-case modeling of ground water risks. Extrapolation from National Priority List (NPL) sites where data was available, to non- National Priority List (NPL) sites is uncertain. Ecological Risk Rl R3 RIO Medium Medium/high Medium Documented impacts to aquatic ecosystems from a moderate number of sites. Welfare Risk R3 Low R3: About $8 million in annual costs to treat water supplie and losses in value of groundwater for future use. Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10. ------- Rankings by Region Risk Problem Area Region Ranking General Comments Specific Regional Comments Active Hazardous Waste (RCRA) Sites Human Health Risk Rl R3 RIO Low Medium/low Low Rl: Used model to estimate risks from management of different streams. Incineration largest risk. R3: Assumed undetected releases from RCRA sites would pose similar risks as sites investigated in the past. RIO: Investigated risks at some of worst known sites. Ecological Risk Rl R3 RIO Medium Medium/low Medium Little data available, generally showing local aquatic impacts around a few sites. Rl 0: Believed risks higher for active rather than inactive sites because of larger quantity of waste being measured. R3: Believed the opposite of RIO. Welfare Risk R3 Medium/low R3: About $24 million in annual costs to treat water supplies and losses in value of groundwater for future use. -P- vo Non- Hazardous Waste Sites Human Health Risk Rl R3 RIO Low Low Low Work groups in all three Regions modeled groundwater pathway from landfills and surface impoundments. Incinerator risks appear small also. Ecological Risk Rl R3 RIO Medium Low Low Rl: Higher ranking due to impacts on freshwater wetlands and propensity for locating municipal landfills near them. Welfare Risk R3 Low R3: About $15 million in annual damages to treat water supplies and losses in value of groundwater for future use. Notes; Rl indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10. ------- Table 2: Summary of Findings for Major Problem Areas Rankings by Region Risk Problem Area Region Ranking General Comments Specific Regional Comments Releases from Storage Tanks Human Health Risk R1 R3 RIO Medium/low Low Low Rankings based on analyses showing large number of leaking tanks, but low human exposure means low risks. Rl: Included all storage tanks. R3: Included all underground storage tanks. RIO: Included storage units. Ecological Risk R1 R3 RIO Medium Medium Low Rl: Believed damage limited due to location of tanks in disturbed areas and limited transport of contaminants. R3: Cited leaking tanks and damage to terrestrial and aquatic settings. RIO: Few examples of adverse impacts. Welfare Risk R3 Medium/low R3: About $40 million in annual damages. This problem area is largest contributor to welfare damages via groundwater. Accidental Releases Human Health Risk Rl R3 RIO Medium/low Unranked Medium/low R3: Included accidental releases with routine releases in all other problem areas. Rl, RIO: Used historical data on deaths and injuries, scaled up to account for under-reporting. Ecological Risk Rl R3 RIO High Unranked Medium Regions 1 and 10 concerned with effects of oil spills on the marine environment. Rl: Concern over potential oil spills, and oil drilling near Georges Bank. RIO: Believed oil spill effects are reversible over time. Welfare Risk R3 Unranked Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10. ------- jl. %**¦/ a1w irfi %h?M* Jfc. JJH.\i# 11 iUi 1>1" JLC4J VJ1 JL A VJ U1WXU. Jk W^0>0 Rankings by Region Risk Problem Area Region Ranking General Comments Specific Regional Comments Pesticide Residues on Food Human Health Risk R1 R3 RIO Medium High High AH Regions agree that cancer risks to general population from food residue are high, but database is conservative. Risks to farmers and applicators are high on individual basis, but less significant population risks. Some difference in definitions. Rl: Ranked pesticide residues at medium/high and ranked pesticide application at medium/low. R3.R10: Ranked both residue and supplication together. Ecological Risk R1 R3 RIO Medium Unranked High Regions 1 and 10 concerned about large volume of pesticides used and effect on non-target species and ecosystems. Welfare Risk R3 Unranked u> Physical Modification of Land or Water Human Health Risk Rl R3 RIO Unranked Low Unranked Activities covered include second home construction, mining, etc. R3; Incidence of several diseases requiring animal vectors, e.g., rabies, may increase. Ecological Rl High Impacts are widespread and can range up to Risk R3 High devastating and irreversible. RIO High Welfare Risk R3 Low R3: Net welfare effect of physical modification is positive. Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10, ------- Differences Across Regions One of OPPE's major reasons for supporting these Regional projects is the opportunity they present for learning more about Regional variation in risks. Do different Regions tend to rank the environmental problems in the same order? Will the problems that are high risk in one Region be high risk in another Region? Ultimately, we are interested in gaining information about which EPA programs and priorities should be nationally uniform and whieh should vary geographically. (assuming five risk steps in all: high, medium/high, medium, medium/low, and low). Of the thirty-eight problem area/risk type combinations that all three Regions ranked, twenty-five are ranked similarly and thirteen are ranked disparately. Although differences in definitions sometimes reflect real differences in the nature of an environmental problem across Regions, it appears that nine of the thirteen disparate rankings are more likely due to definitional or methodological differences than to substantial real differences in risk between Regions. The four instances where major differences between Regions are based on risk are: o Criteria air pollutants for human health effects. Ozone risks are higher in The Regions ranked problems similarly, but there are important differences. The major conclusion is that there is a great deal of consistency in how the three Regions ranked the same problems. The three Regions agree far more often than they disagree. In Table 3, we display the areas for which the Regional rankings are disparate. Our definition of a disparity is when two Regions ranked a problem differently by at least two risk steps Region 1 than in the other Regions. About two-thirds of Region 1 counties 52 ------- xaui& j. x luuicrn mcaa yy iljljl vanauujus jlu. i\ams uy i\&giuu Risk Regional Ranking Problem Type 1 3 10 Explanation Criteria Air Pollutants HH H M M Real Differences in ozone risks. Air Toxics HH M L H RIO includes particulates less than 10 microns in their definition. M^jor uncertainty about total universe of air toxics realtive to 20 or so modelled. No real evidence of difference in risks. Acid Deposition Eco H M/H M Real differences in risk. Radiation HH L M/H L Definitional. R3 includes natural background radiation. Radiation Eco L M L Definitional. R3 considered potential accidents. Other Regions focused on typical damages. Industrial Point Sources HH M/H M/L L Real differences in risk. Also partially definitional, as R1 includes sediment releases. Industrial Point Sources Eco H M M/H May be real differences in risk. Also partially definitional. Also due to less discriminating nature of R1 eco rankings (more of their problem areas ranked as high risk than other Regions). POTWs Eco H M M/H May be real differences in risk. Also partially definitional. Also due to less discriminating nature of R1 eco rankings (more of their problem areas ranked as high risk than other Regions). Notes: HH means Human Health Risk, Eco means Ecological Risk, H means high risk, M means medium risk, L means low risk. R1 means Region 1, R3 means Region 3 and RIO means Region 10. ------- Table 3: Problem Areas With Variations in Ranks by Region Risk Regional Ranking Problem Type 1 3 10 Explanation Nonpoint Sources HH M M/H M/L Probably real differences in risk. Contaminated fish problems worse in more industrialized, populated areas. Other Groundwater Eco M L NA Definitional. R3 put groundwater impacts to surface water in non-point sources. Non-Hazardous Waste Eco M L L May be real differences in risk. More likely due to different ranking methods. Storage tanks Eco M M L May be real differences in risk. More likely due to different ranking methods. Accidental Releases Eco H NA M Definitional. R1 considered potential accidents, RIO focused on historical record. Notes: HH means Human Health Risk, Eco means Ecological Risk, H means high risk, M means medium risk, L means low risk. R1 means Region 1, R3 means Region 3 and RIO means Region 10. ------- are classified as non-attainment for ozone compared to less than half for Region 3 and only a few for Region 10. Acid deposition for ecological effects. The rankings put acid deposition as high risk in Region 1, medium/high in Region 3, but Region 10 only attributing medium risk to it. Region 1 has highly acid rainfall, and more than 100 acidified large lakes, with 700 threatened and over 2000 classified as sensitive. Acid deposition is suspected to be a major contributor to forest decline in northern New England. Region 3 has even more acidic rainfall, but its acidified lakes are in limited geographic areas and there is no evidence of acid deposition contributing to forest decline. Region 10 has much less acidic rainfall, and thorough studies demonstrate little or no current adverse impact on lakes there. Industrial point sources for human health effects. Region 1 ranked this problem as medium/high risk, Region 3 as medium/low, and Region 10 as low. There is some definitional difference that may account for the different rankings between Regions 1 and 3, but there are probably real risk differences between these two Regions and Region 10. Regions 1 and 3 are more heavily industrialized, with higher population densities and higher reliance on surface water supplies for drinking (72% and 77%, respectively) than Region 10 (54% reliance on surface water). Nonpoint sources for human health effects. Region 3 ranked this as medium/high risk, Region 1 as medium risk, and Region 10 as medium/low risk. Again, the more development, denser populations, and reliance on surface water in Regions 1 and 3 should make nonpoint sources a higher risk than in Region 10. The long history of industrial development along waterways in the eastern Regions has contributed to numerous instances of badly contaminated bottom sediments, releases from which are generally 55 ------- defined as a nonpoint source problem. The number of acres where shellfish harvesting is prohibited (often due to bacteriological contamination from nonpoint sources) is far higher in Regions 1 and 3 than in Region 10. Does this mean there are only rare differences in risk rankings across the Regions, and that a nationwide ordering of risks would be duplicated fairly closely in any individual Region? Not necessarily. A first caution is that we have looked at only three of the ten EPA Regions, which provides us with limited data. And we have looked at only the relative ranking of residual risks, not some absolute measure of total risk. Despite these caveats, what does our three-Region sample say about geographic uniformity of risk rankings? There is a strong general consistency to the findings across Regions. In a later section of this chapter we underscore this point by finding a strong similarity between the Regional rankings and the national rankings from Unfinished Business. But some differences in risk have emerged: at least four substantial ones and probably many more subtle ones that we have not discussed. The Regions and the problem areas over which these rankings have been conducted are large aggregations of disparate elements of risk. If we were to rank finer elements, we Would likely find more extensive evidence of geographic differences in risk. Two examples: o All three Regions encompass diverse land uses. Each has major cities, industrial areas, agricultural areas, forest lands, etc.. If we were ranking problems in more homogeneously defined geographic areas, we would undoubtedly see large distinctions in risk rankings. A ranking of environmental risks in an agricultural state, e.g., South Dakota, would be much different than one for an urbanized state, e.g., Rhode Island. The results from the four ongoing state Comparative Risk Projects will give us more data on this issue. 56 ------- o Risk rankings would begin to diverge if the problem areas were more narrowly defined. While nonpoint sources may cause similarly high ecological risks in Regions 3 and 10, the rankings would differ if the component portions of nonpoint sources were ranked individually. Nonpoint source effects from silviculture would rank very high in Region 10, but less so in Region 3. The reverse would be true for nonpoint source effects from mining, very high in Region 3, but less so in Region 10. Our conclusion is that a relative risk ranking of environmental problems, when conducted at a broad level (across EPA Regions, and across an environmental pie sliced into about 20 pieces), will show little geographic variation. What is true for one Region will be generally true for another. There may be an innate level of riskiness associated with each environmental problem that does not vary much between broad geographical areas. But there are differences when geographical areas or the problem areas themselves are defined more narrowly. Some of these are due to differences in natural features, types of industry, or land use patterns, some are due to combinations of factors that lead to geographical "hot spots." Even where the level of risk appears to be similar between Regions, the causes of that risk may differ — the pollutants involved in one Region may be more hazardous, while in another Region more people may be exposed. Thus it may be appropriate to have the solutions customized to address the local situation. There is validity in setting national priorities based on risk, but risk management priorities might still differ for good reasons. As the ranking or priority-setting becomes more precise, focusing on smaller geographic areas or smaller pieces of problem areas, geographic distinctions become much more important. Even where rankings are similar, the causes of risk- and thus the best solutions- may differ. 51 ------- Project Results Compared with Results from Unfinished Business The Regional Comparative Risk Projects built on the process and methodologies of Headquarters' Unfinished Business project. The lists of problem areas and the methods were similar to those used in Unfinished Business. Comparing the results is straightforward, with two exceptions: the Regional projects used slightly different definitions for some problem areas than did Unfinished Business, and Unfinished Business did not combine their separate rankings for cancer and non-cancer health effects. The results of the projects are very similar. All rated radon, indoor air pollution and pesticides as the highest health risks. Unfinished Business also ranked worker exposures and exposures to consumer products as causing very high health risks, but the Regional projects did not consider these problem areas. Drinking water contamination ranked quite high in health risks for both the National and Regional studies. At the low end of the health risk ranking, both National and Regional projects listed USTs, non-hazardous waste, RCRA sites, and, somewhat higher, CERCLA sites. This is due to the limited population exposures typically associated with groundwater contaminated from these sources. Groundwater pollution tends to be slow-moving and localized, and can usually be avoided at modest cost by obtaining alternate or treated water supplies. The health risk to an exposed individual may be as high from contaminated groundwater as from polluted air or surface water, but there typically will be far fewer people exposed. The health ranking methods used in both the Regional projects and Unfinished Business tended to weight population risk far more than they did individual risk. A few health risk rankings differed between the Regional projects and Unfinished Business. The rankings are similar to those from Unfinished Business, with some differences. 58 ------- o Unfinished Business rated accidental releases as higher risk than did the Regions. We believe the Regions' rankings may be more appropriate, as they used a new historical data base on injuries and deaths from accidental releases that was unavailable at the time of Unfinished Business. o The Regions ranked industrial point source and nonpoint source discharges both as somewhat higher risk than did Unfinished Business. This was because the Regions obtained data on toxic chemicals in edible fish tissue, and performed several modeling analyses to project human doses via fish consumption and drinking water. Unfinished Business used professional judgment with little data. The Regions' analyses used conservative assumptions, and may thus have overstated risks. o Unfinished Business ranked air toxics as causing substantially higher health risks than did the Regions. Unfinished Business and the three Regions drew quite different conclusions regarding this issue, disagreeing on the extent to which the twenty analyzed air toxics represented the entire universe, and the extent to which air toxics caused non-cancer effects. The ecological rankings were also quite similar across the studies. Physical modification, nonpoint sources and pesticides were ranked as high risk. Unfinished Business ranked global warming and ozone depletion as even higher risk, but the Regional projects did not rank these problems. All the studies found other radiation, RCRA sites, USTs, CERCLA sites, solid waste disposal and other groundwater contamination to present the lowest ecological risks. Several differences in the ecological rankings included: o Unfinished Business found point sources (both industrial and POTW) to present similar high risks as nonpoint sources. The Regions made a distinction, ranking nonpoint sources clearly higher. The Regions used data 59 ------- that Unfinished Business paid less attention to on the number of stream miles and lake acres degraded by the different sources of water pollution. This data showed nonpoint sources to be the greatest source of degradation by far. o Unfinished Business ranked air toxics as causing moderately high ecological damage. The Regions ranked it somewhat lower. Both Unfinished Business and the Regions noted the lack of data on ecological effects of air toxics and the great uncertainty in ranking this problem area. o Unfinished Business (as well as Region 10) ranked accidental releases as low ecological risk, based upon a determination that ecosystems have recovered well from even large accidental spills. Region 1 judged accidental releases as causing higher damage, based upon an assumption that they could potentially cause catastrophic effects independent of whether or not they actually have done so yet. o Unfinished Business and two of the three Regions ranked solid waste sites and other radiation as low risk. But one Region ranked each of them as medium ecological risk. Such differences in judgment can be expected in areas such as these for which ecological effects data is extremely limited. The welfare risk rankings by Region 3 also generally agree with those from Unfinished Business, although some important differences are apparent. In both studies the greatest damages by far were attributed to Criteria Air Pollutants (Unfinished Business includes Acid Deposition in this category). Acid Deposition was ranked second by Region 3. Nonpoint Sources were ranked third in Region 3 and second in Unfinished Business. Toxic Air Pollutants was found to pose the lowest welfare risks by both studies. Other noteworthy points of comparison are: 60 ------- o Region 3 and Unfinished Business differed substantially in their ranking of welfare risks from contaminants in drinking water. Region 3 ranked this as causing high welfare damages and Unfinished Business ranked it as low, despite the fact that Region 3 defined their drinking water problem area much more narrowly than did Unfinished Business. The reason for the different ranking is probably the much greater prevalence of old lead drinking water pipes and more corrosive water in Region 3 than across the Nation as a whole. o Region 3 ranked four problem areas (Indoor Air Pollution, Indoor Radon, Pesticide Contamination, and Radiation Other Than Radon) as causing relatively high welfare risks on the basis of damages consisting almost exclusively of costs entailed by the health effects associated with these problems. The Unfinished Business welfare work group defined welfare risks to exclude health care costs, believing that such damages are only monetized reflections of health risks, and that the health risks and any manifestations of them should be counted only in the ranking by the health work groups. Unfinished Business thus ranked these four problem areas as causing very low welfare risks. If the Unfinished Business assessment had included the health-related welfare damages from these problem areas, its ranking would align closely with Region 3's. o The other problem areas ranked high by Unfinished Business that were also studied by Region 3 were discharges from POTWs and from industrial point sources. If Region 3's welfare rankings were adjusted to exclude health care costs, Region 3 agrees that the welfare damages from these two problem areas are relatively high. o Although both Region 3 and Unfinished Business agreed that the welfare damages from CERCLA sites, RCRA sites, solid waste management, UST 61 ------- and other ground-water contamination were medium or low, the two projects differed substantially in their relative ordering among these five problems. Region 3 found other ground-water and UST to pose medium risks, with CERCLA and RCRA sites and solid waste management posing low risks. Unfinished Business put the five problems in exactly reversed order. This difference is probably the result of the differing data the two projects used. The Region 3 work group relied on a Regional data base on the number of ground-water contamination incidents caused by the five different problem areas, and then calculated the resulting costs for treatment and replacement of drinking water supplies. The Unfinished Business work group instead relied extensively on studies estimating declines in property values around hazardous waste sites. In Region 3, leaking USTs and other ground-water contaminants were responsible for many more contamination incidents than were hazardous or solid waste sites. Summary of Findings, and Comparison with Current EPA Control Efforts The rankings by each of the Regions show substantial consistency. In this section we discuss some of the noteworthy conclusions. The rankings contrast sharply with the relative levels of Regional resources devoted to the problem areas. Each of the three highest health risk areas — radon, indoor air pollution, pesticide residues — are the subject of minimal Regional program efforts. Regional programs addressing the two highest ecological risk areas — habitat modification and nonpoint sources - are larger, but still small. By contrast, two of the low residual risk problem areas — RCRA and CERCLA sites ~ are the subject of major Regional programs. UST is the subject of moderate Regional programs. Resources devoted to solid waste and to radiation other than radon, like their risks, are small. The rankings contrast sharply with the level of EPA resources devoted to the problems. 62 ------- PROBLEMS THAT WERE RANKED CONSISTENTLY BY ALL THREE REGIONS High Health Risks Indoor radon Indoor air pollution other than radon Pesticides (primarily residues on food) Drinking water contamination High Ecological Risks Physical modification of habitats Nonpoint source discharges to surface waters Low Health Risks Underground storage tanks Active hazardous waste (RCRA) sites Low Ecological Risks Active hazardous waste(RCRA) sites Non-hazardous (solid) waste sites Radiation other than radon Abandoned hazardous waste (CERCLA) Underground storage tanks Non-hazardous (solid) waste sites Looking at the ranking results within media, rather than across media, we found divergences between risk and EPA's current program effort: o In the air program, more resources are devoted to criteria pollutants and air toxics than to indoor air and radon. o In the water quality area, nonpoint sources and habitat modification cause the greatest problems. Yet the bulk of program resources are devoted to municipal and industrial point sources, with some resources devoted to wetland protection. o In the waste programs area, CERCLA, RCRA and to a lesser degree UST receive the most attention. Yet accidental releases and other sources of groundwater contamination seem to pose equal or larger risks. 63 ------- These findings are quite similar to those at the national level from Unfinished Business. They also support the general finding of Unfinished Business that the rankings by risk do not correspond well with EPA's current program priorities. Several problem areas causing high risk have low levels of resources, while other areas of relatively low risk are receiving much attention and effort. Why is there a substantial mismatch between the level of risk that a problem poses and the level of attention it gets from EPA? The answers at the Regional level are the same as at the national level. First, resource levels tend to be more closely aligned with how serious environmental problems have been perceived to be in the past, rather than the risks they pose now. EPA's priorities throughout the organization are determined far more by public opinion and its embodiment in statutes than by risk. Despite our findings that the relative risks associated with hazardous waste sites are low; the public clearly fears them and wants them cleaned up. They also want hazardous wastes managed safely, so that more dangerous sites are not created. For various reasons, indoor air pollution, radon and pesticide residues (until very recently) have not aroused the public consciousness. Public opinion often does not correlate well with risks as estimated by technical experts. This is because risk estimation is complex. Evaluation and comparison of the risks caused by different environmental problems is complex even for professionals, as is clear from the time and effort put into these projects. There may also be a fundamental difference in perspective between individual citizens and a government agency. Citizens tend to take a more personal view in evaluating risks, while a government agency must take a more societal view, often coping with problems that affect large numbers of people. The public considers qualitative aspects of risks, e.g., "is it voluntary?", that are not factored into our rankings. A second reason for the mismatch between risk and resources is controllability. Resources line up with past risks and public opinion more than current residual risk. 64 ------- Many of the high risk problem areas cannot easily or effectively be controlled using traditional authorities and technologies. Indoor air pollution, radon, nonpoint sources and habitat modification are difficult for EPA to reduce, either because the Agency doesn't have the necessary legal authority, or there is no universally applicable technology. Thus, EPA's resources devoted to these problems may be limited. Of course, some problem areas have low residual risk because effective control programs are in place that have reduced high risks to acceptable levels. The rankings produced thus far are based upon risk alone, and priorities for action or budget resources must depend on many more factors that we have not considered yet: public opinion, statutory mandates, cost, and controllability. Some problems have low residual risk because of effective ' control programs. We should continue to study the mismatch between risk and resources. We nevertheless believe that the mismatch between risk and resources is cause for concern and additional study. EPA's business should be to obtain real results for our program efforts - - to work on the most serious environmental problems facing the Nation and to reduce real risks. Level of Confidence in Ranking Results Participants are confident of their results. As noted earlier, the results of the Regional Comparative Risk Projects should be viewed more as informed professional judgment than as scientific risk assessment. The data used was very limited, and some of the methods were novel, imperfect, and judgmental. Despite these limitations, the participants are comfortable with their relative rankings of the problem areas. When work group participants were asked whether they would recommend redoing 65 ------- the ranking using better data and methods, many argued against doing so for at least several years. This was primarily because they did not think the rankings would change much. They thought it would take several years for a sufficient amount of new data to become available and new methods to be devised to make a reevaluation of the problem areas worth the considerable effort required. This view is supported by the similarity in the risk rankings across the Regions and with Unfinished Business. The participants in the projects have noted a number of areas where their conclusions are particularly uncertain, and where additional data and or analysis would improve the rankings. The problem areas for which rankings are uncertain are not necessarily the areas for which the available data are most limited or of poorest quality. In several cases, the work groups identified problem areas for which data was poor but a ranking could nevertheless be assigned confidently. For others, better quality data was available but the problem still could not be ranked confidently because of the absence of a single key piece of information. Many of these perceived gaps in data and analysis are similar to those mentioned by the Unfinished Business participants. In conclusion, the participants in these projects recognize the imperfections in what they have done, but believe that the rankings of the problem areas reflect their relative risks reasonably accurately, and they believe the knowledge gained about the risks associated with different problem areas was definitely worth the effort. Project participants did believe that it would be very worthwhile to update the data and knowledge base and to re-analyze and re-rank the problem areas on a periodic basis, perhaps every four or five years, to revise risk-based priorities in light of new information and especially to identify emerging environmental problems. The participants noted where additional data or analysis would improve the rankings. 66 ------- The following are areas identified by the work groups where additional information and analysis could do much to improve the confidence of the rankings: Health Risks o Exposure data on indoor air pollutants, o Health effects of airborne sulfates. o Actual exposures to contaminants at and around waste disposal sites, o Exposure data for damage pathways from waste sites other than groundwater, o Actual (rather than modeled) data on pesticide residues on foods as consumed, o Information on the total universe of toxic air pollutants in addition to the best- studied pollutants. ' . ~ . o Data on the specific sources of the contaminants found in fish or drinking water from surface waters. o In addition, the work groups expressed substantial methodological uncertainty about how,to assess non-cancer;risks and,how to aggregate cancer and non-cancer risks. Ecological Risks o Non-urban data on criteria air pollutant ambient concentrations. ' o Terrestrial effects of acid deposition, o Ecological effects data and studies for air toxics. o Survey of ecological damages from waste sites (CERCLA, RCRA and non- hazardous). o Data on the extent of discharge of contaminated groundwater to surface water, o In addition, all three ecological work groups expressed great uncertainty about their ecological comparative risk assessment methods and recommended that further efforts •be made to develop a more systematic approach. Welfare Risks o Methods for valuing the aesthetic damages from pollution, o'Methods for valuing the loss of unused but clean groundwater, o Critical review of studies on welfare losses due to acid deposition, o Methods for evaluating welfare losses from physical modification of habitats, o 'The Region 3 work group also expressed a general regret at the small number of studies monetizing welfare damages in most areas. 67 ------- B. Project Benefits The Regional Comparative Risk Projects have allowed the The best result participants to carefully and systematically evaluate and to rank the will be to improve the environmental problems facing their Regions using available data way EPA and informed judgment. Although not perfect, the projects are the allocates resources. most rigorous and objective comparisons of the seriousness of these environmental problems to date. The participants have expressed confidence in their risk rankings. Both the management of the participating Regions and the coordinators of the projects at Headquarters are pleased with the progress thus far. But the ultimate test of these projects is their utility in setting priorities. Will they improve the way the Agency allocates its resources? The implementation phase of the projects — where we will develop, evaluate and execute ways of reducing the risks we have analyzed - is now beginning. We are preparing to use the project results in three processes: o In the Regions' negotiations with National Program Managers. At separate stages in the annual budget and management cycle, the Regions discuss with National Program Managers what they believe the Agency's budget request should be and then, after EPA receives its appropriation, they discuss what work will be accomplished with the appropriated funds. o In allocating the Regions' own discretionary resources. Subsequent to agreement with National Program Managers on work to be accomplished, some amount of resources will remain to be spent at the Regions' discretion. o In dealing with the states. The Regions will negotiate directly with each state what it will accomplish with Federal grant funds. In addition, the Regions can 68 ------- try to encourage the states to use their own appropriated funds to reduce risks more effectively. The Comparative Risk Projects will make a difference in resource allocation as the Agency becomes more sensitized to the need for shifting efforts toward high risk problems. This would be the most important outcome of the projects, and we are working toward this goal during the second year. In the meantime, the projects have already provided several other procedural benefits: 1. A better understanding of Regional environmental problems and potential new directions for the Regional Administrator, Deputy, and other Regional managers. The comprehensive purview of the Comparative Risk Projects gives these managers a good information base for planning. 2. An understanding for the Regions of the relative risks of the environmental problems facing them, and of the "anatomy" of risk for each problem. The Regions now have better knowledge of which pollutants, pathways, source types or geographic areas ("hot spots") contribute the bulk of the risk in each problem area. This more detailed understanding will make it much easier for the Regions to design initiatives targeted efficiently at the portions of problems that cause particularly high risks. 3. An enhanced role for the Regions in national decision-making. In decisions made at EPA Headquarters, whether on resource allocation, regulatory or program policy issues, the Regions' role has traditionally been limited to some degree because of their lack of analytical backup for their positions. The Regions have offered opinions and arguments, but seldom supporting analyses. The EPA has reaped a number of benefits already. 69 ------- Comparative Risk Projects can now help the Regions participate more effectively in national decisions. 4. An improved understanding of Regional opportunities to establish their own priorities. The Regional Comparative Risk Projects have contributed to the degree of flexibility Regions now have to allocate their resources as they wish. Region 10 successfully used existing lapse positions to finance several of the initiatives suggested in the first year of the Comparative Risk Project, and is developing a process to use their lapse pool better to address high-risk priorities1. The Office of Management Systems and Evaluation (OMSE), part of OPPE at Headquarters, has conducted a study of the extent of Regional flexibility, and has made several recommendations to increase it. At least one Headquarters program office has offered Regions some limited flexibility to increase Strategic Planning and Management System (SPMS) commitments in one area and decrease them in another. 5. Education of the participating Regional staff. They are now better trained in risk assessment, have a better understanding of risks in their program areas, and have a better cross-media perspective. Many participants say they have enjoyed the opportunity to learn from their colleagues about environmental problems and programs other than their own. Future updates or enhancements to the initial Regional Comparative Risk Projects will now be easier to do. In sum, the projects have achieved several important steps toward better risk- 1 Lapse positions are a statistical artifact that occur because it may take several months to fill a job vacancy after an individual leaves. Each office is allocated a set number of full-time equivalents, or FTEs. An FTE is equal to one person, full-time, in a position for one year. When there is a lapse between the time an individual leaves a job and when a new person is hired, part of an FTE is unused. Over a whole Region, this may yield several FTEs per year, and the Regional management may decide how to use this resource. 70 ------- based decision-making, both in the Regions and at Headquarters. We expect further benefits as resource allocation gradually changes to reflect relative risks as estimated in these projects. 71 ------- V. Lessons for Future Projects Many of the expected benefits from the Regional Comparative Risk Projects will be realized only if other Regional Offices and states undertake similar projects. Within EPA, the participation of other Regions will lend credibility to the process and to the Regions' resource requests prompted by project results in negotiations with Headquarters. The participating Regions also intend to encourage Comparative Risk Projects in their states, contributing to well-informed, mutual decisions by the Region and a state on how to spend Federal grant dollars and state funds. mrnrn^ jn chapter, we look toward the participation of additional Future projects Regions and states in the comparative risk process, and discuss can learn from the current some lessons we learned during the first set of projects. ones. ^ Possible Resource Savings Given the substantial resources needed to conduct a Comparative Risk Project (see box on page 27), it is important for OPPE to evaluate where savings of time, staff or money might be made. Here are some lessons. o Work group size could be reduced, but only marginally since the expertise, broad office representation, and checks and balances of the work group process are critical to project success. o Contractor support probably cannot be reduced much because work groups cannot easily substitute for the risk assessment expertise and the consistent treatment of problem areas that contractors provide. There was also a considerable cost savings when a contractor prepared POAs or analysis similarly for two or three Regions. 72 ------- o OPPE is developing guidance materials, including training courses and methodology documents, to help future Comparative Risk Projects benefit from the experience of preceding ones. o Substantial time is needed for work groups to talk through methods, analysis, and rankings, but elapsed time could probably be reduced with better organization and use of guidance materials now being developed. o Comparative Risk Projects should not reduce data gathering efforts or analytical rigor supporting the professional judgments, or rankings may be little better than opinion polls. A comparative risk analysis will require substantial resources from any Region or state that undertakes one. However, a project sponsor should realize that such an investment will pay dividends for many years. Once the initial investment is made, it would cost little in future years to keep a Region or state informed about risks and opportunities to reduce them. The staff would be trained and knowledgeable about comparative risk and the data base created would require less effort to update or improve than to generate initially. ' B. Issues Involving Project Design Several aspects of project design differed across the three participating Regions. In this section, we pose questions about alternative approaches and offer some answers. Should projects analyze all national and global problems? The Regions did not analyze some problems that were not likely to be addressed at the Regional level, e.g., global warming, ozone depletion, worker exposure to chemicals. While the Regions Projects require substantial resources, but benefit EPA and states for many years. 73 ------- decided it was necessary to direct their efforts toward problems they felt they could affect more, it would also be appropriate for a Comparative Risk Project to include such problems in their analysis. It is important to determine how these problems rank relative to other problems, if risks vary or are uniform across the Nation, and what local efforts can be marshaled to control them. Should projects analyze welfare risk? Region 3 did so, with a separate work group and ranking of problem areas for welfare risk. Regions 1 and 10 did not. Several points are important relating to this issue: o Regions 1 and 10 chose not to analyze welfare risks to save resources for starting on risk management analyses in the first year. Their rationale was that protection of economic values (reduction of welfare risks) is less clearly a part of the Agency's mandate than is protection of human health and the environment. o Region 3's welfare risk ranking was substantially different than either their health or ecological rankings. In Region 3's view, welfare risk is clearly different from the other sorts of risk. If only health and ecological risks were considered, an incomplete picture would be obtained and priority choices might be inappropriate. o Regions 1 and 10 both initially planned to incorporate welfare concerns somehow in the ecological work group's charter. They were not able to do so because of welfare risk's distinct character. o Both Regions 1 and 10 have decided that they will analyze welfare risks in the second year, although perhaps not to the level of detail as in the health and ecological analyses. 74 ------- o OPPE staff and consultants working with the Region 3 welfare work group were initially concerned because economic techniques for monetizing environmental damages, critical in evaluating welfare risks, are complicated. Only one of the work group members had any training in economics. The Region 3 work group, however, did an excellent job of analyzing and ranking welfare risks. Should problem lists be defined as mutually exclusive? Region 3 took pains to define their problem areas in a mutually exclusive fashion. Regions 1 and 10 instead defined problem areas roughly consistently with the scope of risks covered by EPA programs. Because EPA program jurisdictions overlap, this resulted in a problem list that included numerous overlaps. Specific elements of environmental damage were counted under multiple problem areas. The health risks caused by a leaking UST that contaminates groundwater used for drinking could be addressed by the UST program and/or the groundwater program and/or the drinking water program. These particular risks were thus counted in all three problem areas. The Region 1 and 10 approach seemed to cause no analytical difficulties but some elements of risk are now double-counted. One could argue that a problem area has overestimated risks if it includes those also counted in other areas. On the other hand, some of Region 3's names imply more risk coverage than their actual definitions. For example, the drinking water and groundwater problem areas were subject to very restricted definitions. Should rankings be combined? Each of the three Regions developed separate rankings for the different types of risk, and did not develop a single aggregate risk ranking. Their rationale was that combining health, ecological and welfare risks is not an analytical matter but instead requires value judgments. Given a relative weight assigned to health, ecological and welfare concerns and a cardinal ranking of problem areas where one could determine a quantitative difference in risk between problems, 75 ------- analysts could easily combine a set of separate rankings into a single ranking. Analysts could also display how the single ranking would vary for alternative relative weights for the three types of risk. However, none of the Regions did a cardinal ranking, and only in Region 3 did all the work groups provide ordinal rankings. The Regions did not feel well equipped to make judgments about relative weights, and the rankings were not combined. In fact, EPA Headquarters was also unwilling to venture such judgments in Unfinished Business. Appendix B describes the process used by the Pennsylvania State Comparative Risk Project to combine their health, ecological and welfare rankings. Pennsylvania in effect assigned equal weights to each of three types of risk. How should risk management be approached? Regions 1 and 10 established separate work groups to consider risk management issues during the first year but gave them rather different tasks. In Region 1, the risk management work group evaluated and ranked the problem areas on the basis of five risk management factors: public perception, availability of Regional Office resources to deal with it, costs and economic impact of controls, legal authorities to reduce risks, and the effectiveness of available control techniques. The result is a rough guide to which problem areas are more and which are less easily manageable. In Region 10, the risk management work group took a different approach. The work group developed ranking criteria ~ legal, political, and technical feasibility, cost, potential in reducing risk ~ for evaluating initiatives. Motivated by Region 3's MERITs process, they then asked for ideas on specific initiatives to reduce risks. They spent most of their time analyzing the initiatives for feasibility based on the risk management criteria. They selected the best of the initiatives and ranked them. The Steering Committee then chose the eight best initiatives and the Region has been implementing them. 76 ------- Region 3 relied on its MERITs process to develop proposals to manage problems. The MERITs process operates separately from the Comparative Risk Project. Each year MERITs proposals are solicited from all Regional staff for ideas on new ways to address environmental problems. Each proposed MERIT is evaluated according to criteria, and resources are sought to implement the best MERITs. For FY 1989, strongest consideration will be given to proposals aimed at high-risk issues identified by the Region 3 Comparative Risk Project. It is too early to tell what the results will be of each approach. Region l's approach seems to have the advantage of providing a broad risk management analysis of all the problem areas, suggesting which might provide the most fertile ground for developing risk reduction initiatives. On the other hand, the Region 10 approach provides a full analysis of individual initiatives, not broad problem areas, thereby moving faster to selecting and implementing new projects as a result of the first year's comparative risk work. Whom to assign to work groups? For the project to work best, the work group members should be among the better professional staff in the Region, who know their programs well, and ideally have some experience and perspective across other programs in addition to their current program. It is very important that each work group include at least one member reasonably familiar with each problem area, someone who understands how it causes risk, what data exists, and how that might be analyzed. It is also useful for the work group to have several individuals who are experts in the type of risk being analyzed. It is difficult for a work group to rely solely on contractors or OPPE personnel for direction on how to establish its risk assessment methodology. It is preferable if the work group itself has some expertise and can be led from within. There has been some variation in approaches to work group membership. Region 10 included a state representative on each work group. Participation by these individuals 77 ------- was useful, as they brought knowledge of some data sources that might not otherwise have been available. In addition, they helped make their state and other states in the Region aware of the project, and extend the findings to the states. We saw no drawbacks, other than the cost of bringing the state representatives to the meetings. Other Regions or states might consider including additional outside participants. Academics with relevant expertise could be particularly useful. Successful methodological innovations. For the most part, the Regional Comparative Risk Projects built on the risk assessment methods developed in the Unfinished Business project, making several important improvements. The major difference is the Regional projects go well beyond Unfinished Business in considering and analyzing risk management factors and aim to change EPA activities in order to achieve greater reductions in risk. Unfinished Business was limited to risk assessment. Additional improvements are discussed in Appendix C. 78 ------- VL Next Steps In this chapter, we provide a brief discussion of the next steps for the Comparative Risk Projects. A- Implementing the Analytical Findings in the Regions The real test of the success of the Comparative Risk Projects is their utility in setting priorities. Most of the future work will come in translating the analytical findings about comparative risks of environmental problems into improved decisions about allocating resources to deal with them. Some background work has already been done in Regions 1 and 10. Their risk management work groups have begun the process of deciding which areas can be most effectively handled by the Region with specific initiatives. The three Regions plan generally similar activities for the second year of their projects: Developing initiatives. Each Region will develop a process Regions will for generating and then analyzing initiatives for dealing with the analyze ideas to reduce risks. environmental problems. Each Region intends to ask to its employees (and perhaps also states and the general public) to suggest initiatives to reduce risks. They will encourage initiatives targeted at the highest risk areas, but all initiatives will be welcomed. Those submitted will be analyzed by the relevant program divisions in the Region, and perhaps by the work groups to assess the likely risk reductions, cost and feasibility. The Region will choose the best initiatives to implement. 79 ------- Evaluating allocation of resources. Initiatives will be The Regions considered for whatever incremental funding becomes available to will seek shifts of resources to the Region. In addition, each Region will develop a process for high-risk areas. evaluating resource shifts within its base programs, typically from lower-risk problem areas to higher-risk ones. (Cost-effective shifts may certainly be found within a single program area, possibly from a higher risk problem area to a lower risk one.) The potential shifts will be evaluated like the initiatives. We expect that resource shifts within the next year or two will be limited to those remaining within the boundaries of a single media program. Cross-media shifts or shifts across major EPA offices are too difficult to achieve institutionally at present. Integrating the comparative risk process into existing program management and accountability systems. Each Region has somewhat different processes for making resource allocation decisions. Each will decide how to work in the comparative risk process. The Regions will decide whether comparative risk will be an annual process, an annual update, done every couple of years, or not done again. Region 3 intends to use the comparative risk results and work groups to assist with its MERITS process, used to allocate a pool of discretionary Regional resources derived from a lapse pool and a small draw on the Regional programs. Region 10 intends to develop a similar process for managing its lapse pool. Region 1 is considering adapting the Comparative Risk Project to serve as the general strategic planning process for the Region. Using the comparative risk results to participate more Regions plan effectively in Headquarters priority-setting. Armed with the to influence Headquarters' comparative risk analyses, the three Regions intend to play a more priorities. active role in discussions with Headquarters about both Regional ancj national priorities. Regional presentations will be developed for budget discussions with national program offices and for the spring Agency budget planning meeting. The three Regions have used their comparative risk analyses to 80 ------- provide the bulk of their input to OMSE's annual call for a Regional ranking of environmental problems. The Regions will use their analyses in negotiations with program offices on Strategic Planning and Management Systems (SPMS) commitments once the agency appropriations have been made. Expanding and improving weak spots in the analysis. The Regions 1 and Regional work groups have indicated the level of confidence with 10 will analyze welfare risks. which they ranked each problem area. Each Regional project ^plans to further investigate problems which were ranked with little confidence. In many cases the lack of confidence is due to the fact that important information about the problem simply does not exist, in which case research may be recommended. In other cases, the information may actually exist but the work group did not have the time or money to acquire it. Each Region will improve the data, analyses and risk assessments used in the first year of the projects for selected problem areas where further work could alter the ranking of the problems. Regions 1 and 10 will also conduct some limited welfare risk analysis for their problem areas based on the previous work of Unfinished Business and the Region 3 project. Increasing State involvement. Each of the three Regions is now working with one of their states on a State Comparative Risk Project (Pennsylvania, Vermont, Washington). The Regions plan several additional activities to encourage more states to participate in projects. Briefings will be given to state staff on project findings. Discussions will be held with states on initiatives or resource shifts for high risk areas. Risk Communication. Each Region will produce a document for public distribution summarizing the project findings. A communications strategy will include presentations on process and results to staff and management within the Region, in other parts of the Agency, and to the public. 81 ------- B. Work by OPPE OPPE is taking several steps to make use of the projects' results. OPPE is developing methods to evaluate initiatives to reduce risks. Methodological work is in progress on the question of what analysis should be done to evaluate specific candidate resource shifts from a low risk to a high risk area. The analyses conducted thus far in the Comparative Risk projects have focused on assessing residual risks for broad problem areas. Analyses of specific investment and disinvestment opportunities will build on these residual risk analyses, but will be qualitatively different, requiring different sorts of data and procedures. Risk communication guidance is available. EPA Headquarters has developed risk communication materials and courses that will help these and future Comparative Risk Projects convey their results to the public. The Risk Communication Workshop is the most significant of those recently completed. The two-day course, soon to be offered on a regular basis in EPA Headquarters and Regional offices, is designed to introduce the workshop participant to the principles of risk communication. Using video clips, case studies, and role playing, the course teaches the participant about the various aspects of risk communication. It also discusses a number of communication options and gives participants practice in using guidelines developed for more effective communication about environmental risks. Perhaps most importantly, OPPE is also taking steps to encourage additional Regional or state Comparative Risk Projects. Three additional states have begun projects during the second half of 1988: Colorado, Washington, and Vermont. OPPE's Geographic Integration Branch is soliciting additional interest. Materials have been and are being developed that explain the Comparative Risk process in an understandable way and aid 82 ------- additional states or Regions that undertake projects. A one to two day comparative risk training course illustrates the role comparative risk analysis can play in setting environmental priorities. Seminars on health, ecological and welfare methodologies used in the Comparative Risk Projects and risk assessment and risk management courses teach the methods and uses for risk analysis. These courses and materials promise to help future Comparative Risk Projects benefit from the experience of preceding ones. 83 ------- VII Conclusions Each of these Regions devoted considerable effort to defining, gathering data, analyzing, and ranking a comprehensive list of environmental problems. The risk analysis framework integrated data and professional judgement in a consistent manner to allow comparison and priority-setting among problems based on the human health, ecological, and for Region 3, welfare risks they pose. The slight differences in methods used by the three projects allowed us to learn about the relative strengths and weaknesses of different methods. The ranking results show that the relative seriousness of most problem areas is fairly consistent across the three Regional projects and Unfinished Business. There are important differences, however. Some are due to different definitions of problem areas used, but most are due to differing conditions across the Regions. Regions also found that even where the relative seriousness of problem areas is the same, the underlying causes of risk may be different in different Regions. These findings support the idea that EPA should consider risk management strategies that are customized to local conditions for most effective environmental management. The product of these projects is not just the rankings. The analysis on each problem area that supports the rankings provides insight about underlying causes of risk and often indicates what the most effective solutions to these problems may be. These risk- based solutions, when considered against risk management factors, lead to an effective, feasible, and cost efficient strategy for addressing environmental problems. Risk analysis provides rankings and insight to the causes of risk, indicating the best solutions. 84 ------- Appendix A> Definitions of Problems For Comparative Risk Assessment This appendix lists the environmental problems analyzed by each of the three Regional projects with a description of each problem as defined by the Region. Region 1: 1-1. Criteria Air Pollutants This problem arises when the concentration of a criteria air pollutant exceeds the ambient standards required under the Clean Air Act to protect human health and welfare. The criteria air pollutants are sulfur dioxide, total suspended particulates, carbon monoxide, nitrogen oxides, ozone, and lead. Major sources of these pollutants are mobile sources- -motor vehicles, and stationary sources—industrial, commercial, and residential fuel burning. 1-2. Acid Deposition and Visibility This topic includes both wet and dry acid deposition. Acid deposition effects include terrestrial impacts (e.g., forests, crops, soil), ecological impacts (e.g., streams, lakes), potential drinking water impacts, and possible welfare impacts (e.g., building materials and monuments). Visibility will also be considered. Visibility impacts are primarily the result of long-range transport of sulfates, a key component of acid deposition. A-l ------- 1-3. Hazardous/Toxic Air Pollutants This area covers exposure to airborne toxic and hazardous air pollutants from routine or continuous emissions form outdoor point and nonpoint sources. Pollutants include asbestos, benzene, chromium, TSDF emissions, gasoline vapors, incomplete combustion products, airborne pathogens, cooling towers, and a variety of other volatile organic chemicals and toxics. Major sources include large industrial facilities, waste treatment facilities, motor vehicles, and commercial solvent users. There may be some double- counting with risks from waste sites and Publicly Owned Treatment Works (POTWs). For purposes of this project, to the extent possible, this category excludes risks from pesticides, radioactive substances, chlorofluorocarbons, and pollution from indoor sources. 1-4. Radon Radon is a radioactive gas produced by the decay of radium, which occurs naturally in almost all soil and rock. A problem develops when radon migrates through building materials, water, or fuel pipes into a building. The gas is trapped by dense building materials and accumulates to very high levels. When inhaled at such levels, the radon decay products accumulate in lung tissue and can cause cancer. This category covers indoor radon only, as outdoor concentrations are much lower. It also includes inhalation from water stripping through domestic water use. 1-5. Indoor Air Pollutants Other Than Radon This category applies to exposure to accumulated indoor air pollutants from sources in buildings. These sources include unvented space heaters and gas ranges, foam insulation, pesticides, passive smoking, wood preservatives, fireplaces, cleaning solvents, and paints. A-2 ------- The pollutants include tobacco smoke, asbestos, carbon dioxide, pesticides and numerous volatile organic chemicals, such as benzene and formaldehyde. Pollutants that are indoors as a result of diffusion from outdoors are not included, unless indoor levels are a function of the building itself (e.g., poor ventilation). Inhalation of contaminants volatilized from drinking water is included. 1-6. Radiation From Sources Other Than Indoor Radon Nonoccupational exposure to nonionizing radiation (beyond natural background) is included here. Nonionizing radiation sources include high-voltage power lines, broadcast towers, and microwave and radar transmission. t 1-7. Industrial Point Source Discharges To Surface Waters "Point sources" are sources of pollution that discharge effluents into surface waters through discrete conveyances such as pipes or outfalls. Discharges may result in contamination of fish and subsequent exposure of humans. Point sources have been divided for this project into industrial (this category) and POTW sources (#8). Pollutants of concern include total suspended solids, BOD, toxic organics (phthalates and phenols), toxic inorganics, such as metals, and thermal pollution. Typical sources of discharge include coal and ore mining, metal finishing, pulp and paper processing, and iron and steel production. Such facilities discharge to surface waters under NPDES permitting; facilities discharging to surface waters are required to have such a permit. Substantial double-counting with #10—Estuaries, Coastal Waters, and Oceans. A-3 ------- 1-8. POTW Discharges To Surface Waters Hie discharges from municipal sewage treatment systems (POTWs), including industrial "indirect dischargers" connected to POTWs, often travel to surface water. Discharges may result in contamination of fish and subsequent exposure of humans. Combined sewer overflows (CSOs) are included here also. The pollutants are similar to those in #7 but POTWs are also a major source of ammonia, chlorination products, and nutrients. Double-counting is possible with all categories relating to surface water (#'s 7, 9, 10, 11). 1-9. Nonpoint Source Discharges To Surface Waters Pollutants that reach surface waters from sources other than discrete conveyances for effluents, as in #7 and #8, are nonpoint pollutants. This includes runoff from agricultural, urban, industrial, silvicultural, or even undisturbed land (including pesticides)- -particularly construction and logging sites and areas of hydromodification, surface discharge of ground water, releases from contaminated in-place sediments, and air pollutants that settle into the water. Discharges may result in contamination of fish and subsequent exposure of humans. Possible pollutants vary a great deal, though they include most point source pollutants mentioned in #7 and #8. Storm water carries a large amount of solids, nutrients, and even toxics. Double-counting may occur with the air pollutant categories where deposition is included and with discharges to surface water categories. 1-10. Discharges To Estuaries, Coastal Waters, and Oceans Form All Sources This problem area includes a wide variety of pollutants and sources that reach such waters and may result in contamination of seafood and subsequent exposure of humans. Specific sources can include ocean dumping of wastes, air deposition of criteria and A-4 ------- hazardous pollutants, nonpoint runoff, dredge spoil disposal, etc. Possible pollutants are numerous and include those mentioned specifically in other categories that deal with surface water. There will likely be double-counting with air pollutants, discharges from point and nonpoint sources, and numerous other problem areas. 1-11. Wetlands/Habitat Loss This problem area includes all risks from pollutants reaching wetlands and impacts from physical alteration of wetlands. Activities that contribute to the problem include agricultural modification; flood control channelization; filling for highways, housing, and landfills; dredging for navigation channels, harbors, and marinas; mining and resource extraction; discharges from point and nonpoint sources, and others, including contamination from hazardous wastes. Such activities alter the salinity and water level while contributing turbidity, sedimentation, and numerous pollutants, including those detailed in the point and nonpoint source categories. The more significant overriding impact is the continued loss of habitat through the elimination of both wetlands and uplands. The significance of this loss of habitat is that it is a unique resource that may not be replaceable once the necessary sub-ecosystem is destroyed. Double-counting will occur with categories dealing with discharges to surface water. 1-12. Drinking Water As drinking water arrives at the tap, it may contain a wide variety of contaminants from both natural and man-made sources, and point and nonpoint sources. This category covers both public and private water supplies from surface and ground water sources and relates to drinking water contamination from the source to the tap. Pollutants of concern include pathogens, disinfectant by-products, and fluoride from natural deposits. This is for consumption only; it does not include inhalation of volatilized contamination. It A-5 ------- excludes contamination from waste sites (#s 13, 14, 15, 16) and underground storage tanks (#18). 1-13. RCRA Waste Sites This category generally includes the risks posed by hazardous waste sites regulated under the Resource Conservation and Recovery Act (RCRA). More specifically, it includes RCRA landfills and surface impoundments (both open and closed), hazardous waste storage tanks, hazardous waste burned in boilers and furnaces, hazardous waste incinerators, and associated solid waste management units. Seepage and routine releases from these sources contaminate soil, surface water, and ground water and pollute the air. There is potential double-counting of the risks from this problem with those from Drinking Water (#12), Hazardous/Toxic Air Pollutants (#3), and discharges to surface water (#s 7, 8, 9). 1-14. Superfund Waste Sites This category includes hazardous waste disposal sites that are not covered by RCRA, but by Superfund. Generally, they are inactive and abandoned. They can include sites on the NPL, those deleted from the NPL, those that are candidates for the NPL, and any additional sites that states may be addressing. As with active hazardous waste sites, these sites may contaminate ground and surface water, threaten nearby residents with direct exposure to toxic chemicals, and pollute the air, through direct discharges to water sources and air, soil migration, and runoff. Pollutants may include TCE, lead, toluene, chromium, PCBs, and numerous other toxic and hazardous chemicals, some in unidentified quantities and mixtures. There may be some double-counting of the risks from this problem with those from Drinking Water (#12), Hazardous Air Pollutants (#3), and discharges to surface water (#s 7, 8, 9). A-6 ------- 1-15. Other Waste Sites—Municipal Consists primarily of 16,000 open and closed municipal landfills, municipal sludge and refuse incinerators, and municipal surface impoundments nationwide. These sources can contaminate ground and surface water and pollute the air with particulates, toxics, BOD, microbes, PCDFs, PCBs, and nutrients. Contamination may occur through routine releases, soil migration, or runoff. There is potential double-counting of the risks from this project with those from Hazardous/Toxic Air Pollutants (#3), Drinking Water (#12), and discharges to surface water. 1-16. Other Waste Sites-Industrial There are about 3,400 nonhazardous industrial landfills, 15,000 industrial surface impoundments, and 120,000 oil and gas waste impoundments throughout the country regulated under Subtitle D, along with numerous incinerators and land application units. Routine and nonroutine releases, soil migration, and runoff may contribute particulates, toxics, BOD, and nutrients to air, surface water, ground water, and soil. Risks from this category could be double-counted with other sources of ground and surface water contamination. 1-17. Accidental Releases Contaminants are accidentally released into the environment in a variety of ways during transport or production. For example, an industrial unit may explode and emit toxics into the air, or a railroad tank car may turn over and spill toxics into surface water or onto soil and roads. Damages to industrial property and personnel and releases to sewers, oceans, and waterways may occur from substantial, though short-term releases of variety of chemicals, some highly toxic or flammable. Acids, PCBs, ammonia, sodium hydroxide, A-7 ------- etc. are examples of past releases, with PCB accidents the most frequent. Releases from oil spills are also included in this category with a focus on water releases, where the impacts are often the most severe. Spilled products may include pesticides, crude oil, gasoline, solvents, diesel oil, fuel oil and other distillates. Spills from tanks are included in #18. 1-18. Releases From Storage Tanks Includes releases of petroleum products or other chemicals from tanks that are above, on, or underground, tanks owned by farmers, and the fuel oil tanks of homeowners. Stored products include motor fuels, heating oils, solvents, and lubricants that can contaminate ground water with such toxics as benzene, toluene, and xylene. Most of the available data are on underground storage of gasoline. Storage of hazardous wastes or pesticides in tanks is not included. The primary environmental hazard is contamination of ground water, though soil is also affected. There is some potential for double-counting of the risks from this problem with those from Drinking Water (#12). 1-19. Other Ground-Water Contamination A variety of sources of pollution not counted in other categories for this analysis also contaminate ground water. These include fertilizer leaching, pesticides, septic systems, road salt, Class V injection wells, nonwaste material stockpiles, pipelines, and irrigation practices. This category excludes impacts from tanks and hazardous waste sites. The list of possible contaminants is extensive and includes nutrients, toxic inorganics and organics, oil and petroleum products, thermal pollution, and microbes. There is some potential for double-counting with Drinking Water (#12), A-8 ------- 1-20. Pesticide Residues On Foods Eaten By Humans and Wildlife Through residues on or in food-plants, meat, seeds, and insects-humans, wildlife, and other animals are directly exposed to pesticides. Examples include insecticides that are carbamates or organophosphates, specifically, EPN, aldicarb, and diazinon. In addition, certain pesticides bioaccumulate and contaminate food chains. Residues from proper as well as improper application are included. Risks from pesticides prior to exposure through food are included in category #21. 1-21. Application Of Pesticides Risks to people applying pesticides, as well as nonoccupational exposures (e.g., bystanders), including farm workers (10,000 to 250,000) who mix, load, and apply them, are of concern. Risk from proper and improper application are included. Risks from home/consumer application are also included. Some of the more dangerous substances include ethyl parathion, paraquat, and dinoseb. 1-22. Lead This category would evaluate the risks from exposure to lead in soil, drinking water, and air. Although there may be some double-counting with Drinking Water (#12) and Hazardous Air Pollutants (#3), it will be useful to evaluate the multi-media risk posed by this ubiquitous contaminant. 1-23. Asbestos Similar to the lead category, this problem area would evaluate all risks due to asbestos A-9 ------- exposure. There may be double-counting with Drinking Water (#12), Indoor Air (#5), and Hazardous Air Pollutants (#3). A-10 ------- Region 3: ISSUE INCLUDES EXCLUDES 3-1. Criteria Air Pollutants Ambient Sulfur Dioxide, PM 10 (TSP prior to approved PM 10 SIP), CO, NOX, Ozone & related VOCs, and Lead. Acid deposition. 3-2. Hazardous/Toxic Air Pollutants NESHAPs substances (approved and pending), Acutely Toxic Chemicals List, pesticides, routine & accidental releases. Toxics from wastewater treatment plants, CERCLA sites, radionuclides NESHAPs, solid waste disposal, RCRA TSD, air deposition impacts. 3-3. Radon - Indoor Indoor radon exposures from any source. Occupational exposure, outdoor exposure. A-ll ------- Indoor Air All indoor exposures to air Occupational exposure Pollutants pollutants for example: Other Than Radon Asbestos, Formaldehyde, Tobacco, CO, NOX, pesticides. Radiation Other Than Indoor Radon Naturally occurring, manufacturing, radioactive waste disposal, indoor radiation other than radon, non-ionized activities (microwaves, high tension lines, etc.). Medical x-rays, CERCLA sites, cosmic rays exposure in aircraft, exposure from ozone depletion, occupational exposure, nuclear power plant accidents. Impacts of Industrial Point Source Direct Discharge of Wastewater on Surface Waters and Air Pollutants in wastewater generated by all privately- owned sources that are directly discharged to surface waters (including wetlands) through discrete conveyances or volatilized to air. Discharges to or from publically-owned treatment facilities, treatment sludges, groundwater impacts from wastewater treatment, and physical impacts from discharges of dredge and fill material. A-12 ------- 3-7. Impacts of POTW Discharges on Surface Water and Air Pollutants in wastewater generated by all publically- owned sources that are directly discharged to surface waters (including wetlands) through discrete conveyances or volatilized to air, indirect industrial discharges, and combined sewer overflows. Discharges to or from privately-owned treatment facilities, treatment sludges, groundwater impacts from wastewater treatment, and physical impacts from discharges of dredge and fill material. 3-8. Non-point Source Discharges to Surface Waters Discharges from non- discrete conveyances including agricultural runoff, industrial runoff, silvicultural runoff, pesticide runoff, surface discharge of septic tanks, stormwater runoff, mine drainage, contaminated in- place sediments, air deposition, oil and gas operations, and chemical discharges from disposal of dredge and fill materials. Acid deposition impacts, discrete discharges of contaminated groundwater, solid waste disposal, hazardous waste sites (RCRA & CERCLA), and physical impacts from discharges of dredge and fill material. A-13 ------- 3-9. Management of Hazardous Waste at RCRA Facilities All discharges to air, soil, surface water and groundwater from active and closed RCRA facilities, waste transportation, and illegal disposal/lack of capacity. Discharges to wastewater treatment plants and criteria air pollutants. 3-10. Hazardous Substances at CERCLA Sites NPL sites and potential NPL sites. Illegal disposal/lack of capacity. Discharges to wastewater treatment plants and criteria air pollutants. 3-11. Solid Waste Management Multi-media discharges to air, soil, surface water and groundwater from all household, municipal, and industrial waste not regulated by RCRA as a hazardous waste, treatment sludges, transportation, and illegal disposal/lack of capacity. Discharges to wastewater treatment plants and criteria air pollutants. A-14 ------- 3-12. Releases from Underground Storage Tanks All substances released from underground storage tanks such as: gasoline, pesticides, solvents, and oil. RCRA regulated tanks and CERCLA sites. 3-13. Groundwater Contamination Pollutants impacting groundwater from sources such as: agricultural, industrial, municipal, silvicultural, oil, gas & mining operation, pesticides, UIC defined discharges, road salt, urban runoff, underground discharges from septic tanks, saltwater intrusion, and naturally occurring fluorides. CERCLA and RCRA regulated sites, underground storage tanks, and solid waste disposal. 3-14. Other Pesticide Residues on and in food Surface water runoff, Contamination and applicator exposure. aerial drift, groundwater contamination, manufacturing, disposal, non-commercial and non- agricultural applicators. A-15 ------- 3-15. Physical Modification of Aquatic Habitats All physical changes to aquatic habitats such as: dredging and filling of wetlands, dams, and channelization. Chemical impacts from disposal of dredge and fill materials. 3-16. Physical Modification of Environmentally Sensitive Terrestrial Habitats All physical changes to sensitive terrestrial habitats such as: dam building, strip mining, highway construction. Chemical impacts from disposal of dredge and fill materials. 3-17. Acid Deposition All damages caused by wet or dry deposition of acidic compounds from the atmosphere. Primary impacts of sulfur oxides, NOX, and VOCs. 3-18. Operation and Maintenance of Water Supply Facilities All water treatment facilities and distribution networks. Contamination in the raw water. A-16 ------- Region 10: 10-1. Criteria Air Pollutants This problem arises when the concentration of a criteria air pollutant exceeds the ambient standards developed by EPA pursuant to the Clean Air Act to protect human health and welfare. The criteria air pollutants are sulfur dioxide, particulate matter (total suspended particulates and fine particulates/PM 10), carbon monoxide, nitrogen dioxide, ozone, and lead. Major sources of most of these pollutants are mobile sources - motor vehicles, and stationary sources -industrial, commercial, and residential fuel burning. In some cases, strip mining and open pit mining are important sources of particulates. Criteria air pollutants may have an impact on human health, sensitive ecosystems (e.g. forests) and welfare (e.g. visibility, materials damage).2 10-2. Acid Precipitation This problem is thought to result from chemical transformation of oxides of sulfur and nitrogen, resulting in acidic rain or fog. Acid precipitation alters the chemistry of affected aquatic and terrestrial ecosystems, damaging plant and animal life. Sources are the same as criteria pollutant sources of S02 and NOz - a wide variety of industrial, commercial and residential fuel combustion sources. 2 Note: In ranking this problem, the Human Health Work Team decided to exclude the effects of PM10, including it instead under hazardous/toxic air pollutants. A-17 ------- 10-3. Hazardous/Toxic Air Pollutants This area covers outdoor exposure to airborne hazardous air pollutants from routine or continuous emissions from point and non-point sources. Pollutants include asbestos, various toxic metals (e.g., chromium, beryllium), organic gases (benzene, chlorinated solvents), and polycyclic aromatic hydrocarbons (PAHs, such as benzo(a)pyrene, primarily in particulate form). This problem area covers exposure through both inhalation and air deposition of these air pollutants. Major sources include large industrial facilities, waste treatment facilities, motor vehicles, commercial solvent users, and combustion sources. There may be some double-counting with risks from waste sites and POTWs. For purposes of this project, to the extent possible, this category excludes risks from pesticides, radioactive substances, chlorofluorocarbons, as well as exposure to air toxicants that occur indoors.3 10-4. Radon - Indoor Radon is a radioactive gas produced by the decay of radium, which occurs naturally, in varying amounts, in almost all soil and rock. A problem develops when radon enters a building through small gaps, cracks and sumps where the building contacts the soil. The gas can be trapped by building materials and become concentrated. When inhaled, the radon decay products accumulate in lung tissue and can cause cancer. This category covers indoor radon only, as outdoor concentrations are much lower. 3 Note: In ranking this problem, the Human Health Work Team decided to include the effects of PM10 also. A-18 ------- 10-5. Indoor Air Pollutants Other Than Radon This category applies to exposure to accumulated indoor air pollutants, primarily from sources inside buildings and homes. These sources include unvented space heaters and gas ranges, foam insulation, pesticides, passive smoking, wood preservatives, fireplaces, cleaning solvents and paints. The pollutants include tobacco smoke, asbestos, carbon dioxide, and numerous volatile organic chemicals such as benzene and formaldehyde. Pollutants that are indoors as a result of diffusion from outdoors are not included, unless indoor levels are a function of the building itself (e.g., poor ventilation). Some risks may be double-counted with those from Other Pesticides Risks (#19). 10-6. Radiation from Sources Other Than Indoor Radon Consumer exposure to ionizing and nonionizing radiation (beyond natural background) is included here. Sources of radiation included in this category are: radio frequencies (also T.V. towers, power lines, radar, etc.); radiation from nuclear power operations; radiation from hazardous "mixed waste" (including both the radiological and chemical attributes of waste); high-level radioactive waste (including spent nuclear reactor fuel) and low-level waste (including radiopharmaceuticals and laboratory clothing from hospitals involved in nuclear medicine, tools used in cleaning up contaminated areas, etc.); residual radioactivity (including the decommissioning of facilities such as laboratories and power plants, that use radioactive materials); radioactive waste from abandoned hazardous waste sites; and radiation resulting from nuclear accidents where radioactivity is released. Also included in this category are industrial processes such as uranium mining and milling, and the mining of phosphate. EPA's regulatory authority to limit radiation exposures from these sources stems from several Federal statutes and Executive Orders, including the Atomic Energy Act, the A-19 ------- Public Health Service Act, the Clean Air Act (NESHAPs), the Safe Drinking Water Act; and more limited authority under the Resource Conservation and Recovery Act (RCRA) and the National Environmental Policy Act (NEPA)/Environmental Impact Statement (EIS) review process. Additionally, potential authority to handle abandoned radioactive waste exists under CERCLA (Superfund). Because radionuclides are included in the drinking water categories, double-counting is possible with #11 and #12 (Drinking Water). 10-7. Industrial Point Source Discharges to Surface Waters "Point sources" are sources of pollution that discharge effluents into surface waters, through discrete conveyances such as pipes or outfalls. Point sources have been divided for this project into industrial (this category) and POTW sources (#8). Pollutants of concern include total suspended solids; BOD; toxic organics, including phthalates and phenols; toxic inorganics such as heavy metals; and thermal pollution. Typical sources of discharge include coal and ore mining, oil and gas development, placer mining (and many other types of mining), metal finishing, pulp and paper processing, and iron and steel production. Discharges from fish hatcheries are also included in this category. Such facilities discharge to surface waters under National Pollution Discharge Elimination System (NPDES) permitting; facilities discharging to surface waters are required to have such a permit. 10-8. POTW Discharges to Surface Waters The discharges from municipal sewage treatment systems (Publicly-Owned Treatment Works - "POTW's"), including industrial dischargers connected to POTW's (often referred to as "indirect dischargers"), often travel to surface water. Combined sewer overflows A-20 ------- (CSO's) are included here also. The pollutants are similar to those in #7, but POTW's are also a major source of ammonia, chlorination products, and nutrients. Double- counting is possible with drinking water problem areas (#11 and #12). 10-9. Non-point Source Discharges to Surface Waters Pollutants that reach surface waters from sources other than discrete conveyances for effluents, as in #7 and #8, are non-point pollutants. This includes runoff from agricultural, urban, industrial, mining, silvicultural or even undisturbed land - particularly construction and logging sites and areas of hydromodification, surface discharge of ground water, releases from contaminated in-place sediments, and air pollutants that settle into the water. Possible pollutants vary a great deal, including most point source pollutants mentioned in #7, #8. Storm water carries a large amount of solids, nutrients, and even toxics. Double-counting may occur with the air pollutant categories where deposition is included in discharges to surface water. Pesticides are a substantial part of agricultural runoff, but are counted in #19, Other Pesticide Risks. 10-10. Non-Chemical Degradation of Aquatic Ecosystems In addition to the chemical and biological sources of degradation included in all other categories, aquatic ecosystems are affected by a wide variety of physical and other stress agents. This category includes physical modifications (e.g. dredging and shoreline construction) and other sources of degradation (e.g. dumping of plastics and other litter) that affect aquatic ecosystems. Ecosystems of concern include: 1) estuaries, coastal waters, and oceans; 2) wetlands; and, 3) freshwater ecosystems/rivers and lakes. Section 404 of the Clean Water Act (the "Dredge and Fill" program), administered by the Army Corp of Engineers, provides EPA with its primary source of authority over f A-21 ------- influencing the protection of aquatic ecosystems. To a lesser degree, EPA also maintains authority over "significant Federal action" through its role in reviewing Environmental Impact Statements (EISs) under the National Environmental Policy Act (NEPA). Under Section 404 and the NEPA/EIS process, EPA can influence the activities which contribute to degradation of aquatic ecosystems, including, but not limited to: o filling and dredging (e.g. filling for highways, houses, landfills; dredging for harbors and marinas) o shoreline construction and stabilization o sedimentation o sand and gravel mining o upstream dam construction o flood control channelization o changes to watersheds o changes to the hydrolic regime o dumping of solid matter (including plastics and other litter) o non-point runoff o dredge spoil disposal o various mining activities (e.g. strip mining of coal, and mining activities which result in increased turbidity and hydrogeologic disturbances). Other activities which contribute to degradation of aquatic ecosystems, but over which EPA has more limited authority (if any), include: 1) introduced species (including the introduction of domestic animals, resulting in over-grazing); 2) conversion of wetlands to agriculture; and 3) urbanization. 20-11. Public Drinking Water Supplies Public drinking water supplies are defined as those which serve 25 or more individuals, A-22 ------- and are regulated under the Safe Drinking Water Act. This category covers public water supplies from surface and groundwater sources. As drinking water arrives at the tap, it may contain a wide variety of contaminants from natural and person-made, point and non- point sources. Pollutants of concern include pathogens, disinfection byproducts, pesticides, inorganics (such as heavy metals), radionuclides, toxic organics, fluoride from natural deposits, and microbiological contaminants. There is some double-counting of risks from this problem with those from the categories related to sources of ground and surface water contamination. 10-12. Non-Public Drinking Water Supplies Non-public drinking water supplies are defined as those which serve fewer than 25 individuals, in most cases serving only a single residence. Such systems are not regulated under the Safe Drinking Water Act, nor under most state or county regulations. Non- public drinking water supplies are as susceptible (or more so) to contamination, as public supplies. Pollutants of concern are the same for public and non-public drinking water supplies, and include pathogens, disinfection byproducts, pesticides, inorganics (such as heavy metals), radionuclides, toxic organics, fluoride from natural deposits, and microbiological contaminants. There is some double-counting of risks from this problem with those from the categories related to sources of ground and surface water contamination. 10-13. Hazardous Waste Sites - Active This category generally includes the risks posed by hazardous waste sites regulated under the Resource Conservation and Recovery Act (RCRA). More specifically, it includes RCRA landfills and surface impoundments (both open and closed), hazardous waste storage tanks, hazardous waste burned in boilers and furnaces, hazardous waste A-23 ------- incinerators, and associated hazardous waste management units. Seepage and routine releases from these sources contaminate surface and ground water and pollute the air. There is potential double-counting of the risks from this problem with those from Drinking Water (#11 and #12), Hazardous/Toxic Air Pollutants (#3), and discharges to surface water (#*s 7, 8, 9). 10-14. Hazardous Waste Sites - Abandoned (Superfund) This category includes hazardous waste disposal/contamination sites that are not covered by RCRA, but by Superfund. Generally, they are inactive and abandoned. They can include sites on the National Priorities List (NPL), those deleted from the NPL, those that are candidates for the NPL, any additional sites that states may be addressing, and any other abandoned sites. As with active hazardous waste sites, these sites may contaminate ground and surface water, threaten nearby residents with direct exposure to toxic chemicals, and pollute the air, through direct discharges to water sources and air, soil migration, and runoff. Pollutants may include TCE, lead, toluene, chromium, PCBs and numerous other hazardous chemicals, some in unidentified quantities and mixtures. There may be some double-counting of the risks from this problem with those from Drinking Water (#11 and #12), Hazardous Air Pollutants (#3), and discharges to surface water (#s 7, 8, 9). 10-15. Non-Hazardous Waste Sites - Municipal and Industrial Includes two major types of waste sites - municipal and industrial - containing primarily non-hazardous wastes. The municipal waste site universe consists primarily of 16,000 open and closed municipal landfills, municipal sludge and refuse incinerators, and municipal surface impoundments. A-24 ------- These sources can contaminate ground and surface water and pollute the air with conventional pollutants (particulate matter, microbes, nutrients) and toxic pollutants. Contamination may occur through air releases, migration to soil and groundwater, or runoff. Industrial waste sites comprise about 3,400 non-hazardous industrial landfills, 15,000 industrial surface impoundments, and 120,000 oil and gas waste impoundments throughout the country regulated under Subtitle D, along with numerous incinerators and land application units. Pollutants and pathways of exposure are similar to those for municipal sites. Risks from this category could be double-counted with other sources of ground and surface water contamination, toxic air pollutants (#3) and drinking water contamination (#11 and #12). 10-16. Releases from Storage Units Includes releases of petroleum products or other chemicals (including hazardous waste and hazardous materials that are not waste) from tanks that are above, on or underground, tanks owned by farmers, the fuel oil tanks of homeowners, or other storage units (such as barrels). Stored products include motor fuels, heating oils, solvents, and lubricants that can contaminate ground water with such toxics as benzene, toluene, and xylene. Most of the available data are on underground storage of gasoline. Storage of hazardous wastes of pesticides in tanks is not included. The primary environmental hazard is contamination of ground water, though soil is also affected. There is some potential for double-counting of the risks from this problem with those from Drinking Water (#11 and #12). A-25 ------- 10-17. Other Ground Water Contamination A variety of sources of pollution not counted in other categories for this analysis also contaminate ground water. These include fertilizer leaching, septic systems, road salt, underground injection wells, non-waste materials stockpiles, pipelines, irrigation practices, and various mining practices (e.g. tailings ponds, oil and gas reserve pits, and acid mine drainage). The list of possible contaminants is extensive and includes nutrients, toxic inorganics and organics, oil and petroleum products, thermal pollution, and pathogens. Some double-counting with Drinking Water (#11 and #12). 10-18. Application of Pesticides Risks to people applying agricultural pesticides, including farm workers who mix, load, and apply them, are of concern. Some of the more dangerous substances include ethyl parathion, paraquat, and dinoseb. Category also includes risk of exposure to the public in the local region, and to nearby residents/bystanders, as a result of short-range drift, overspray or misuse. Impacts from long range (non-local) air deposition of pesticides are included in Problem #19, Other Pesticide Risks. In Region X, health problems have resulted when pesticides released through the air as a result of agricultural applications affected nearby residents. In some instances, the disposal of mixed pesticide wastes has resulted in the generation of highly toxic, largely unknown byproducts that have entered the air . and caused serious health problems. Suburban spraying of private property, often done with high pressure systems, can result in contamination of neighboring property, residents, pets and livestock. EPA and state laboratories are poorly equipped to sample and to analyze airborne pesticides and their toxic byproducts. A-26 ------- 10-19. Other Pesticide Risks This problem includes spills, residues on raw agricultural commodities and in processed foods (including such overlooked items as wine; a major concern in the Northwest), leaching and runoff of pesticides, air deposition from spraying (including impacts from long-range (non-local) transportation of pesticides resulting from drift), and consumer use of household pesticides. These chemicals can contaminate water supplies, aquatic ecosystems and indoor air, and seep into soil and groundwater. Of particular concern is exposure to chlordane, dursban, ficam, diazinon, and others. They can affect people, farm animals, fish, wildlife and birds, such as wild geese and ducks (diazinon has adversely affected wild birds in the Pacific Northwest). Certain pesticides can also bioaccumulate. Double-counting with #7 (non-point sources), #11 and #12 (drinking water), #5 (indoor air). 10-20. Accidental Releases of Toxics This category focuses on catastrophic events with acute impacts, often requiring some sort of emergency response. Toxic chemicals are accidentally released into the environment in a variety of ways during transport, production, storage or use. For example, an industrial unit may explode and emit toxics into the air, or a railroad tank car may turn over and spill toxics into surface water, onto soil and roads. Damages to industrial property and personnel and releases to surface water, ground water and air may result from substantial, though short-term releases of a variety of chemicals, some highly toxic or flammable. Acids, PCBs, ammonia, sodium hydroxide, etc., are examples of past releases. Releases from oil spills are also included in this category, with a focus on water releases, where the impacts are often the most severe. Spilled products may include crude oil, gasoline, solvents, diesel oil, fuel oil and other distillates. Spills from tanks are included in #16. A-27 ------- 10-21. Non-Chemical Degradation of Terrestrial Ecosystems/Habitats Sources affecting terrestrial ecosystems/habitats include both chemical and non-chemical stress agents. Because chemical sources of degradation are addressed in other categories, this category includes physical modifications (such as mining and highway construction) and other sources of degradation (such as dumping of plastics and other litter) that affect terrestrial ecosystems/habitats. Although EPA lacks direct regulatory authority, through the NEPA/EIS review process EPA has the potential to influence a number of activities which contribute to terrestrial degradation when they occur in the context of "significant Federal action." Activities that may fall under this review authority include: silviculture; mining; highway construction; flooding from dams; pipeline construction; oil exploration; etc. Other activities of concern (including conversion of land to agriculture and urbanization) may be completely outside of EPA's authority, and difficult to influence under the current regulatory authorities. For purposes of this project, this problem area excludes those activities that are clearly beyond any EPA authority to control. Major terrestrial ecosystems included in this category are: forests (coniferous and deciduous); grasslands; desert and semi-arid regions; and alpine and tundra areas. AREAS TO RANK AT DISCRETION OF WORK TEAMS 10-22. Stratospheric Ozone Depletion The stratospheric ozone layer shields the earth's surface from harmful ultraviolet (UV- B) radiation. Releases of chloroflururcarbons (CFCs) and nitrogen dioxide from industrial processes and solid waste sites could significantly reduce the ozone layer. A-28 ------- 10-23. C02 and Global Warming Atmospheric concentrations of carbon dioxide (C02) are projected to increase over the next century due to an increase in fossil fuel combustion and a decrease in tropical forests. Higher levels of C02 may raise climatic temperatures globally, raising the sea level. A-29 ------- ------- Appendix B. Combining Different Types of Risk. Although we are not covering the results of the Pennsylvania State Comparative Risk project in this report, it is worth noting that the Steering Committee for this project did combine the separate risk rankings from the work groups. A key to doing so was asking the work groups to provide rankings that were cardinal as well as ordinal. With the cardinal rankings, the Pennsylvania Steering Committee had quantitative information available on the degree to which a high-ranked problem area was more risky than a low- ranked problem for a single type of risk. Pennsylvania combined their three separate health, ecological and welfare rankings by: 1. Deciding that each variety of risk was equally important 2. Normalizing each separate risk ranking by giving the highest ranking problem a score of 100, and giving the other problems a normalized score equal to the percentage that their raw risk score is relative to the raw risk score of the highest ranking problem. 3. Adding the normalized scores for the three types of risk for each problem in order to obtain an aggregate score. The aggregate risk ranking was based on this aggregate score. This process gave Pennsylvania a satisfactory final ranking of their environmental problems based on all three types of risk. B-l ------- ------- Appendix C. Successful Methodological Innovations. All three Regions explicitly assessed maximum individual health risks as well as population risks. Regions 1 and 10 then based their health risk rankings primarily on population risk, as the Unfinished Business cancer work group did. But Region 3 developed four separate health rankings, based on population and maximum individual risks for cancer and non-cancer health effects. The rankings were different from each other. The work group used a non-rigorous process for combining the four rankings into a single health risk ranking, generally weighing cancer and population risk most heavily. What is of interest is not the process they used for combining the four rankings, but the fact that the work group made the four separate component rankings explicit and displayed them so that the Steering Committee or other interested reviewers could understand the implications of the work group's choices. A reviewer who believes that individual risk is more important, or that cancer and non-cancer effects should be weighed equally, can project rather easily what the effects of these different choices would be. Similarly, the Region 1 health work group developed separate rankings for cancer and noncancer risk. Each work group member then developed their own combined ranking, dividing the problems into five risk categories. A consensus ranking was developed for about two-thirds of the problems. Further discussions resulted in the final consensus ranking, although some work group members might have preferred to see a problem shifted by one risk category. Another innovation occurred in Region 3's welfare risk scoring method. Unfinished Business relied solely on an estimate of the likely annual dollar damages caused by a problem to determine its welfare ranking. Region 3 believed that dollar damages were a very important factor in determining welfare risk, but that other factors mattered too: the geographic extent of the damages, individual welfare risk (as opposed to population C-l ------- welfare risk), and the reversibility of the damages. The work group developed a novel scoring formula that combined these factors, but weighed them less than aggregate dollar damages in determining their welfare risk ranking. The Region 1 ecological risk work group analyzed the location of stressor sources relative to the affected ecosystems using maps. This allowed the work group to evaluate the interaction of stressors and ecosystems more easily than with statistical data alone. The work group was able to gather or develop maps for only a few problems due to limited resources, but still demonstrated the value of this approach. C-2 ------- Appendix D. List of Acronyms CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act DDT Dichloro-diphenyl-trichloroethane DRA Deputy Regional Administrator EDB Ethylene dibromide EPA Environmental Protection Agency MERITS Measurable environmental results initiatives NPL National Priorities List OMSE Office of Management Systems and Evaluation OPA Office of Policy Analysis OPPE Office of Policy, Planning and Evaluation PCB Polychlorinated biphenyl POA Plan of attack POTW Publicly Owned Treatment Works RA Regional Administrator RCRA Resource Conservation and Recovery Act SPMS Strategic Planning and Management System THM Trihalome thane UST Underground storage tank D-l ------- ------- Appendix E. Supplementary Reading National Comparative Risk Project U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Office of Policy Analysis. Unfinished Business: A Comparative Assessment of Environmental Problems. Volume I. Overview. February, 1987. (Available from National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order number PB88127048, $21.95.) U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Office of Policy Analysis. Unfinished Business: A Comparative Assessment of Environmental Problems. Appendix I. Report of the Cancer Risk Work Group. February, 1987. (Available from National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order number PB88127055, $28.95.) U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Office of Policy Analysis. Unfinished Business: A Comparative Assessment of Environmental Problems. Appendix II. Non-Cancer Risk Work Group. February, 1987. (Available from National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order number PB88127063, $15.90.) U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Office of Policy Analysis. Unfinished Business: A Comparative Assessment of Environmental Problems. Appendix III. Ecological Risk Work Group. February, 1987. (Available from National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order number PB88127071, $36.95.) E-l ------- U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Office of Policy Analysis. Unfinished Business: A Comparative Assessment of Environmental Problems. Appendix IV. Welfare Risk Work Group. February, 1987. (Available from National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order number PB88127089, $21.95.) (Please note that all five Unfinished Business reports are available as a set from National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487- 4650. Order number PB88127030, $108.00) Region 1 Comparative Risk Project U.S. Environmental Protection Agency, Region 1, Planning and Management Division, Planning, Analysis, and Grants Branch. Unfinished Business in New England: A Comparative Assessment of Environmental Problems. Overview Report. December, 1988. (Available from National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order number PB89166375, $15.95.) U.S. Environmental Protection Agency, Region 1, Planning and Management Division, Planning, Analysis, and Grants Branch. Unfinished Business in New England: A Comparative Assessment of Environmental Problems. Public Health Risk Work Group Report. December, 1988. (Available from National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order number PB89166383, $21.95.) U.S. Environmental Protection Agency, Region 1, Planning and Management Division, Planning, Analysis, and Grants Branch. Unfinished Business in New England: A Comparative Assessment of Environmental Problems. Ecological Risk Work Group Report. December, 1988. (Available from National Technical Information Service, 5285 E-2 ------- Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order number PB89166391, $21.95.) U.S. Environmental Protection Agency, Region 1, Planning and Management Division, Planning, Analysis, and Grants Branch. Unfinished Business in New England: A Comparative Assessment of Environmental Problems. Risk Management Work Group Report. December, 1988. (Available from National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order number PB89167225, $15.95.) Other Comparative Risk Project Reports Regions 3 and 10 are each preparing reports about the first year of their projects. These reports will be available from the respective Regional Office listed in the Preface of this report. The forthcoming report on the first year of the Pennsylvania Cross-Media Project will be available from the Pennsylvania Department of Natural Resources, P.O. Box 2063, Harrisburg, PA 17120. E-3 ------- ------- Appendix F. Regional Project Participants Region 1 John Bastey Norman Beddows Larry Brill Richard Burkhart Clara Chow Frank Ciavattieri Edward Conley Kate Connolly Brooke Cook Tom D'Avanzo Sally Edwards * Stephen Ells David Fierra Kim Franz Louis Gitto Susan Green Eric Hall Jerry Healey Merrill Hohman Michael Jasinski Paul Keough Corrine Kupstas Harley Laing Sarah Levinson David Lim Don Mackie Mark Mahoney * Barbara McAllister Pat Meaney Patricia O'Leary Stephen Perkins Jon Pollack Ronald Poltak Steve Silva Marcia Spink Susan Studlien Douglas Thompson Ray Thompson Andrew Triolo Pi-Yun Tsai Ann Walsh Carol Wood John Zipeto F-l ------- Region 3 Robert Allen Randy Pomponio Sheila Briggs Ron Preston Henry Brubaker Robert Reed Maryann Bucknavage Charles Rhodes Jeffrey Burke * Robert Runowski Jon Capacasa Charles Sapp Gail Caron Roland Schrecongost Robin Cole Dianne Sims Barbara D'Angelo Roy Smith Joe Davis Bruce Smith Bruce Diamond Henry Sokolowski Richard Fetzer * Rebecca Taggart Alyce Fritz Lawrence Teller James Harper Jean Thompson Kim Hummel Virginia Thompson Greene Jones James Topsale Robert Kramer Michael Vaccaro Stanley Laskowski Janet Viniski Denis Lohman Randy Waite Paula Luborsky Stephen Wassersug Thomas Maslany Carey Widman Andy McErlean Patricia Wilbur * Tony Meadows William Wisniewski Israel Milner Sidney Worthington Bruce Molholt Denis Zielinski Alvin Morris F-2 ------- Region 10 John Armstrong Dave Kircher John Barich Amy Kyle Dick Bauer Ron Lee Paul Boys Jerry Leitch Ken Brooks Bub Loiselle Robert Burd Lee Marshall Bob Coughlin Nora McGee Robert Courson Lynn McKee Dana Davoli Phillip Miller Mike Downs Dede Montgomery Bruce Duncan Bill Mullen A1 Ewing Chris Noah-Nichols Chuck Findley Lane Nothman Clark Gaulding Gary O'Neal Michael Gearheard Bill Ross * Wayne Grotheer Chuck Shenk Julie Hagensen Bill Sobolewski Gil Haselberger Elaine Somers Jan Hastings Pat Storm Mark Hooper Dave Tetta Duane Kama Kathy Veit Dru Keenan Mike Watson Greg Kellogg Leigh Woodruff Bob Kievit John Yearsley * Current and former project managers F-3 ------- ------- |