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

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                      WASHINGTON. O C  20460
                           DEC   7
                                                       Of net or
                                                    "•«£ AOMINISTP » TO»
MEMORANDUM

SUBJECT:  "Comparing Risks and Setting Environmental Priorities"

FROM:
TO:
F. Henry Habicht II
Deputy Administrator,

Addressees
     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  for
planning to account for geographic distinctions.

     The  results of  these projects  will b«  used  to  guide the
choices  of  these  three  Regions  in  EPA's  strategic  planning
process.  I  encourage  other Regions and National Programs to use
these projects as a model  in  analyzing and developing their own
goals and strategic choices.
Attachment

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EPA Headquarters:
     Assistant Administrators
     Deputy Assistant Administrators
     Program Office Directors
     Program Office Deputy Directors

EPA Regional
     Regional Administrators
     Deputy Regional Administrators
     Associate Regional Administrators
     Division Directors

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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
1445 Ross Avenue
Dallas,  TX  75202-2733
(214) 655-6570

Jackie Ferguson
USEPA - Region  VII
726 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. llth Avenue
  RM 350
  Denver, CO  80220
  (303) 331-4436

  Phil Miller
  Department of Ecology
  Abbot Raphael Hall
  MaiIstop PV-ll
  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

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                               -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  0 4 3 3.3
 (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

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                                     Preface
     "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. Reilly, 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, B.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.

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      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

      U.S. 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
                                        11

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                              Acknowledgements
      Numerous individuals contributed their time and effort to this report. They are:
Coordinator:
Catherine S. Tunis, Geographic Integration Branch
Reviewers:
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 No thman, 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.
AppendixF lists the participants of each Regional project.
                                       ill

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                               Contents
Preface	  i
Acknowledgements	 m
Contents  . .	   iv
Tables		 vi
Figures	   vii
Executive Summary	 viii

I Introduction	...	  i
     A. Comparative Risk Projects Address Major Challenges in Environmental
           Management	  3
     B. Objectives of the Office of Policy, Planning and Evaluation	  6

IL 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
     C. Each Project Set Common Analytical Ground Rules  	   16
     D. Each Project Analyzed Risks and Developed Rankings	   20

HL Process and Participants	   25
     A Getting Started	  .... ..........   25
           f                                   ,, •
     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

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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

VI Next Steps 		  79
      A. Implementing the Analytical Findings in the Regions	  79
      B. Work by OPPE	.  . . . .	  82

VIL 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

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                                  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

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                                    Figures
Figure 1: Regional Comparative Risk Projects  . .  .
Figure 2: Ranking of Problem Areas by Region 1
Figure 3: Ranking of Problem Areas by Region 3
Figure 4: Ranking of Problem Areas by Region 10
 1
39
40
41
                                      Vll

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                             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
                                       Vlll

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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

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             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

Low Health Risks
                                            High  Ecological Risks

                                            Physical modification  o£
                                              habitats "^
                                            Nonpoint"source discharges
                                              to  surface waters
                                            Low Ecological~Risks'
      Underground storage  tanks           Active hazardous waste(RCRA)' sites
      Active hazardous waste (RCRA)       Non-hazardous (solid)  waste sites
         sites                              Radiation other than radon
      Abandoned hazardous  waste (CERCLA)  Underground storage tanks
         sites                                               ''
      Non-hazardous  (solid)  waste sites

                                                   t     '<*            f   "*        *

  Note: a.  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.

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       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 role
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.
                                        XI

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       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.
                                         Xll

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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.
                                        Xlll

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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

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      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.
                   1      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 arid to  Regional  ecosystems.   Region 3 also
                     assessed the welfare losses associated with each problem  area.
mmmmmm^mmmmmi^^  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.

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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

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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.                         .                                ,
  Some problems
  are affected by
  local conditions
  and require
  tailored local
  solutions.
                         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
mm^^mmmmm^^^^  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

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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.
  Risk analysis is
  the best
  common
  denominator
  for making
  rational
  comparisons.
effective programs.
                       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
                     is  common  throughout government:   concern for the  Federal
                     deficit  and   tight  budgets.    Environmental  programs  remain
                     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.
These projects  •
help managers
work with
limited budgets.
      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

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""••••«•••^""^^^m  effective and efficient manner.  The problems must be looked at
  Managers must    jn a systematic and integrated way to determine which are most in
  set priorities
  carefully.           need of attention. And programs should be carefully designed to
^^•M^^^^^^^  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 v 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 tq 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.
  Projects show
  how risks vary
  across Regions
    A second OPPE objective is a better understanding  of how
risks in Regions of the  country differ from in risks viewed in an
aggregate national perspective.   The first  Comparative 'Risk
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

-------
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
  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
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

                                         7

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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.                                           >

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BL 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 wo'uld 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 EPA
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

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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

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G 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
•i^""«"—mmmmmmm  causec} 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 SO2 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

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 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).  The, 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.
  Risk
  assessment was
 •carefully
  separated from
  risk
  management.
     More important  in this  regard, though, is the third ground
 rule: in ranking the problem areas, the Regions have considered
 only the risks associated with them.  The Regions sought to keep
 the risk ranking, separate from  consideration of other attributes
 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

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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 risk
   rankings are a
   rough guide for
   resource shifts.
   More analysis
   is needed.
                          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
mmm^^mMM^^M  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
                                         18

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 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
                      environmental „  protection  should  be   directed   at   reducing
                      demonstrated risks.   But other factors,  called risk management
                      factors,  are  also important, and  setting priorities  must involve
™""^™"^^"i^™"11"1-  balancing numerous concerns.  .Where then does risk management
-- determining what EPA should do about environmental problems - come into  these
projects?                       '   .
Priority-se tting
must balance
risk and other
concerns.
        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.
  All three
  Regions are
  analyzing risk
  management.
                      In all three Regions, risk management is a main focus in the
                  second year of the projects.  All 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
                                        19

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r
              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

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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.                  .        ,
  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  ~
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.

               '                          21        '

-------
  Separate work
  groups
  analyzed each
  type of risk
  and developed
  a ranking.
welfare risk.
                          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
  did not
  combine their
  separate
  rankings.
                   1       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:
                                         22

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      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,   pull  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.
  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
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

                                        23

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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 riot
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

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IEL Process  and Participants       j

      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  arid to
implement them.  The major elements of the Regional projects to date follow.

      A Getting Started
  The projects
  provide
  analytical
  support for
  Regional
  priorities.
                  "*       Regional  Administrators  (RA's)  and  Deputy  Regional
                      Administrators (DRA's)  in < the  three  Regions, as managers of
                      environmental protection efforts by all the Program Offices, were
                      interested in  the  potential a Comparative Risk Project has for
                      assisting in environmental decision-making across all,media.  Each
^^^^Bmmf^^^^am   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

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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.
  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, ecolpgical risk, and
                     risk management.  Region 3 formed three work groups also: health
                     risk, ecological risk, and welfare risk. Each work group consisted
f^^^gfg^f^i^^M  of 10-20 individuals, mostly Regional technical  staff but including
                     a few Regional managers.  The work groups were all chaired by
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
                                        26

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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.
                             f     *
  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.
          //'"***«     ', °-sn   --                          '-,    '
      o About l,work year from OPPE in analytical and administrative staff support
      was prdvided 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

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      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

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   OPPE,
   contractors,
   and Regions
   worked
   together to
   develop
   analytical
   methods.
    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

                                         29

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                          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  eji:fects._Risk assessment will normally
consist of the following' four steps:          ,1  "     ",,  „ ,   -         ><

    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 cart
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.

    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",' ffie'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

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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.)

       G 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.
  Leaders for
  each problem
  presented
  analysis to
  work groups.
                          A first step for the problem-leaders was to prepare "Plan of
                     Attack" (POA) papers for each problem.  These outlined the data
                     and analysis proposed for each problem, and  typically relied on
                     national analyses modified to reflect data sources  thought vto be
                     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

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      Work group members next worked closely with contractors, Regional, and QPPE
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.
  Work groups
  ranked the
  problems in all-
  day meetings.
                         Rankings  were  developed by  the work groups  in  all-day
                     meetings.   In these  meetings, the problem leads presented the
                     results of the  analyses to the other work group members.  The
                     processes  used for ranking then differed across the work groups.
•""••mmmm^mm••••  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

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 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

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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.
                                                      i*
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

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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
problems.
  Regions 1 and
  10 analyzed
  risk
  management in
  work groups.
  Region 3 used
  MERITS.
                          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
^^^™"^^^™1^^^  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

                                        35

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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.
       R Senior Management Approval and Documenting the Work
   The Steering
   Committees
   ratified the
   work groups'
   rankings.
                  •      In  the  three Regions, the work groups' risk rankings were
                     presented to the Steering Committees.  No Steering  Committee
                     chose to modify the  rankings, preferring to rely on the  analysis
                     and technical judgments  of  the  work  groups.   In addition, no
                     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

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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

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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

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                                      41

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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

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                                                  51

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             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 which  should vary geographically.
  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
mmmmmmmmmmmmmmmmmm  Regions ranked a problem differently by at least  two risk steps
(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
             Region 1 than in the other Regions.  About two-thirds of Region 1 counties
                                         52

-------





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54

-------
      are classified as non-attainment for ozone compared to less than half for
      Region 3 and only a few for Region 10.
o     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.

o     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).

o     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.
Even where
rankings are
similar, the
causes of risk—
and  thus the
best solutions-
may differ.
                          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
"••^^^^^"•BB^^™  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.
                                      57

-------
             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 rankings
  are similar to
  those from
  Unfinished
  Business,  with
  some
  differences.
    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.
                                         58

-------
       o
       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.

 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.

 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
      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

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             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:
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 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
o
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.

 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.

Although both Region 3 and Unfinished Business  agreed that the welfare
damages from CERCLA sites, RCRA sites, solid waste management,  UST

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             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
mmm—mn^^—*  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.
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          PROBLEMS THAT WERE RANKED CONSISTENTLY BY ALL THREE REGIONS
                                           High Ecological Risks
                                           Physical modification, of
                                             habitats
                                           Nonpoint source discharges
                                             to surface waters
                                           Low Ecological  Risks
High Health Risks
Indoor radon
Indoor air pollution'other
  than radon
Pesticides (primarily residues
  on food)       . .
Drinking water contamination
Low Health Risks
      Underground storage tanks
      -Active ^hazardous waste (RCRA)
        sites "                ,  '
      Abandoned hazardous waste (CERCLA)  Underground  storage tanks
        -sites
      Non-hazardous  (solid)  waste sites
                                     Active hazardous waste(RCRA)  sites
                                     Non-hazardous (solid) waste  sites
                                     Radiation other than radon
      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.
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      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.
  Resources line
  up with past
  risks and public
  opinion more
  than current
  residual risk.
                          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
B^^^HIBM••••  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.
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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.
  Some problems
  have low
  residual risk
  because of
  effective
  'control
  programs.
   We .should
   continue to
   study the
   mismatch
   between risk
   and resources.
     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.

     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
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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
  noted where
  additional data
  or analysis
  would improve
  the rankings.
                          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.

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 , 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                                 .  ,   t,

  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.
  6 Actual (rather than modeled) data son 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 pn 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 Brisks- and,,how to aggregate cancer and non-cancer risks.

  Ecological Risks       "-         "'*'-  - •'                              ' ~       *".',
• '   ?'',,',,           ''•,',;;   (.'j> i   *"'i    <-.*''       "          *  r,  ";'"*,A*
  o Non-urban data on criteria air pollutant ambient concentrations.
- • o Terrestrial effects of acid deposition,  " -   -'      '               -     -  *  - -
  o, Ecojogical effects data, and studies for air toxics.                            .  -f
  o Survey of ecological damages from waste sites  (CERCLA, RCRA and non-
  hazardous).                    '       -  -                                       -1
  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
: 'ecologicalxomparative 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,
'; 'o5 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.
  oThe Region 3 work group also expressed a general regret at the small number of
  studies monetizing welfare damages in most areas.
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    B. Project Benefits
The best result
will be to
improve the
way EPA
allocates
resources.
                         The Regional Comparative Risk Projects have allowed the
                     participants to carefully and systematically evaluate and to rank the
                     environmental problems facing their Regions using  available data
                     and informed judgment. Although not perfect, the projects are the
                     most  rigorous  and objective  comparisons of the seriousness  of
BB,^^^BBM^MBB.^  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

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      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.
  EPA has
  reaped a
  number of
  benefits
  already.
    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

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       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.
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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.
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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.
  Future projects
  can learn from
  the current
  ones.
    In this chapter, we look toward the participation of additional
Regions and states in the  comparative risk process, and discuss
some lessons we learned during the first set of projects.

    A. 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.
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      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.
  Projects require
  substantial
  resources, but
  benefit EPA
  and states for
  many years.
                         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
^^^^nnnmmmmmmm  Tisks  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

                                                 f.       •             -          -
      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

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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.
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       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,

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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.

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       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 1's
approach seems to have the advantage of providing  a  broad risk management analysis
of all  the  problem are.as, 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

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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

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 VI  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 generatjng an(j t^&n analyzing initiatives for dealing with  the
  analyze ideas                                                          6
  to reduce risks.     environmental problems.   Each Region intends to ask to its
mm^^H^^mm^^m^'  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.
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  The Regions
  will seek shifts
  of resources to
  high-risk areas.
                          Evaluating  allocation   of  resources.    Initiatives  will  be
                      considered for whatever incremental funding becomes available to.
                      the  Region.  In  addition, each Region will develop a process for
                      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
                      effectively in  Headquarters priority-setting.     Armed with  the
                      comparative risk analyses, the three Regions intend to play a more
                      active role in discussions with  Headquarters about both Regional
mmfmmmmmm^^^mm  and 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
   Regions plan
   to influence
   Headquarters'
   priorities.
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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.
  Regions  1 and
  10 will analyze
  welfare risks.
                          Expanding and improving weak spots in the analysis.   The
                      Regional work groups have indicated the level of confidence  with
                      which they ranked  each problem area.   Each Regional project
^•BMI^M^MHBB^M  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.
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      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
mmm^^^mmmmi^^m  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

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Additional
Regions and
states are
encouraged to
begin projects.
Guidance
materials are
being
developed.
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.
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VH. 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.
  Risk analysis
  provides
  rankings and
  insight to the
  causes of risk,
  indicating the
  best solutions.
    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.
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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-i.   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

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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

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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.
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.
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1-8.   POTW Discharges To Surface Waters

The  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

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 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

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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

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 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

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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).
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 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

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exposure.  There may be double-counting with Drinking Water (#12), Indoor Air (#5),
and Hazardous Air Pollutants (#3).
                                      A-10

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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

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3-4.   Indoor Air
      Pollutants
      Other Than Radon
All indoor exposures to air   Occupational exposure
pollutants for example:
Asbestos, Formaldehyde,
Tobacco,  CO, NOX,
pesticides.
3-5.   Radiation Other      Naturally occurring,
      Than Indoor Radon   manufacturing, radioactive
                            waste disposal, indoor
                            Medical x-rays, CERCLA
                            sites,  cosmic rays exposure
                            in aircraft, exposure from
                            ozone depletion,
                            occupational exposure,
                            radiation other than
                            radon, non-ionized
                            activities (microwaves, high  nuclear power plant
                            tension lines, etc.).          accidents.
3-6.    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.
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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.
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3-9.   Management of       All discharges to air, soil,
      Hazardous Waste at  surface water and
      RCRA Facilities      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.
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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
      Contamination
Residues on and in food
and applicator exposure.
Surface water runoff,
aerial drift, groundwater
contamination,
manufacturing, disposal,
non-commercial and non-
agricultural applicators.
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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      Chemical impacts from
sensitive terrestrial habitats  disposal  of dredge and fill
such as: dam building,      materials.
strip mining, highway
construction.
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.
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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 SO2 and NO2 -:-  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.
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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.
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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

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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

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(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

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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.
10-11.  Public Drinking Water Supplies
Public drinking water supplies are defined as those which serve 25 or more individuals,

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 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

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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), HazardousA^oxic 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, PGBs 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.

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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).
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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.
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 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.
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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 chloroflurorcarbons (CFCs) and nitrogen dioxide from industrial
processes and solid waste sites could significantly reduce the ozone layer.
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10-23.  CO2 and Global Warming

Atmospheric concentrations of carbon dioxide (CO2) 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 CO2 may raise  climatic temperatures  globally, raising the sea
level.
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Appendk  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.

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.
      3.
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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
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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.
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Appendix D.   list of Acronyms
CERCLA

DDT
DRA
EDB
EPA
MERITS
NPL
OMSE
OPA
OPPE
PCB
POA
POTW
RA
RCRA
SPMS
THM
UST
Comprehensive Environmental Response, Compensation, and Liability
Act
Dichloro-diphenyl-trichloroethane
Deputy Regional Administrator
Ethylene  dibromide
Environmental Protection Agency
Measurable environmental results initiatives
National Priorities List
Office of Management Systems and Evaluation
Office of Policy Analysis
Office of Policy, Planning and  Evaluation
Polychlorinated biphenyl
Plan of attack
Publicly Owned Treatment Works
Regional  Administrator
Resource Conservation and Recovery Act
Strategic  Planning and Management System
Trihalomethane
Underground storage tank
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Appendix R   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.)
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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

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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.
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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

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Region 3
Robert Allen
Sheila Briggs
Henry Brubaker
Maryann Bucknavage
Jeffrey Burke *
Jon Capacasa
Gail Caron
Robin Cole
Barbara D'Angelo
Joe Davis
Bruce Diamond
Richard Fetzer *
Alyce Fritz
James Harper
Kim Hummel
Greene Jones
Robert Kramer
Stanley Laskowski
Denis Lohman
Paula Luborsky
Thomas Maslany
Andy McErlean
Tony Meadows
Israel Milner
Bruce Molholt
Alvin Morris
Randy Pomponio
Ron Preston
Robert Reed
Charles Rhodes
Robert Runowski
Charles Sapp
Roland Schrecongost
Dianne Sims
Roy Smith
Bruce Smith
Henry Sokolowski
Rebecca Taggart
Lawrence Teller
Jean Thompson
Virginia Thompson
James Topsale
Michael Vaccaro
Janet Viniski
Randy Waite
Stephen Wassersug
Carey Widman
Patricia Wilbur *
William Wisniewski
Sidney Worthington
Denis Zielinski
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Region 10
John Armstrong
John Barich
Dick Bauer
Paul Boys
Ken Brooks
Robert Burd
Bob Coughlin
Robert Courson
Dana Davoli
Mike Downs
Bruce Duncan
Al Ewing
Chuck Findley
Clark Gaulding
Michael Gearheard
Wayne Grotheer
Julie Hagensen
Gil Haselberger
Jan Hastings
Mark Hooper
Duane Kama
Dru Keenan
Greg Kellogg
Bob Kievit

* Current and former project managers
Dave Kircher
Amy Kyle
Ron Lee
Jerry Leitch
Bub Loiselle
Lee Marshall
Nora McGee
Lynn McKee
Phillip Miller
Dede Montgomery
Bill Mullen
Chris Noah-Nichols
Lane Nothman
Gary O'Neal
Bill Ross *
Chuck Shenk
Bill Sobolewski
Elaine Somers
Pat Storm
Dave Tetta
Kathy Veit
Mike Watson
Leigh Woodruff
John Yearsley
                                     F-3

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