United States Policy, Planning, August 1989
Environmental Protection And Evaluation
Agency (PM-220)
cjrEPA Comparing Risks
And Setting
Environmental Priorities
Overview Of
Three Regional Projects
Printed on Recycled Paper
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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 1389
0"tct Of
r»C AOMlNllTfliTOfl
MEMORANDUM
SUBJECT: "Comparing Risks and Setting Environmental Priorities"
It is my pleasure to present you with the attached new
report, "Comparing Risks and Setting Environmental Priorities:
Overview of Three Regional Projects." These projects represent a
major attempt by EPA and state agencies to assess the seriousness
of environmental problems based on the effects they have on human
health and the environment. The projects demonstrate innovative
approaches to managing these problems.
The report documents the process and compares the results of
the first year of two-year pilot Comparative Risk Projects in
EPA's Regions 1, 3, and 10. The projects combine the leadership
of Regional senior managers with the technical expertise of
professional Regional staff. The projects use estimates of risk
as a common measure for comparing and setting priorities among
environmental problems within and across media. We will continue
to refine and use these rankings of environmental problems as we
develop an Agency-wide risk-based strategic plan.
While the rankings are generally consistent across Regions,
there were some important differences in risk for certain
problems, pointing to areas where Regional priorities may differ
from national priorities. In addition, causes of risk sometimes
vary across Regions. These findings indicate the need foe
planning to account for geographic distinctions.
Ths results of these projects will be used to guide the
choices of thsss three Regions in EPA's strategic planninc
process. I encourage other Regions and National Programs to use
these projects as a model in analyzing and developing their owr
goals and strategic choices.
TO:
FROM:
Attachment
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EPA Headquarters:
Assistant Administrators
Deputy Assistant Administrators
Program Office Directors
Program Office Deputy Directors
EPA Regions t
Regional Administrators
Deputy Regional Administrators
Associate Regional Administrators
Division Directors
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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
14 45 Ross Avenue
Dallas, TX 75202-2733
(214) 655-6570
Jackie Ferguson
USEPA - Region VII
72 6 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7363
Don Johnson
USEPA - Region VIII
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1456
Janis Gomes
USEPA - Region IX
75 Hawthorne
San Francisco, CA 94105
(415) 744-1623
Keith Hinman
USEPA - Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-4044
STATES
Kate Kramer
CDOH
4210 E. 11th Avenue
RM 350
Denver, CO 80220
(303) 331-4436
Phil Miller
Department of Ecology
Abbot Raphael Hall
Mailstop PV-11
Olympia, WA 98504-8711
(206) 459-6282
Doug Kievit-Kylar
Office of the Secretary
Agy. of Natural Resources
103 S. Main Street
Waterbury, VT 05676
(802) 229-4438
Jean Thompson
Office of the Secretary
Department of Environmental
Quality
P.O. Box 82263
Baton Rouge, LA 70884
(504) 765-0720
Bill Rustem
Public Sector Consultants
300 S. Washington Square
Suite 401
Lansing, MI 48933
(517) 484-4954
Bob Lieberman
Office of Research & Planning
Illinos Dept. of Energy and
Natural Resources
325 W. Adams
Springfield, IL 62704
(217) 785-0124
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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 04333
(207) 289-2811
Steven Nicholas
RM 200, Seattle Municipal
Bid.
600 Fourth Ave
Seattle, WA 98194
(206) 684-8377
Suharjo Haditirto
DOH, Environmental Planning
500 Ala Maona Blvd.; Ste 250
Honolulu, HI 96813
(80.8) 586-4337
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Preface
"N
"Our main mission at EPA is to protect human health and the environment.
As EPA employees will attest, that is not easy. Because there are so many
different kinds of environmental and health risks—different pollutants from
different sources entering different media—it is sometimes very difficult to
tell which problems are the most serious and thus which demand the most
attention. Comparative risk analysis helps us accomplish our mission by
suggesting where our efforts can do the most good."
William K. Reiliy, EPA Administrator
The report was prepared by the Office of Policy, Planning and Evaluation (OPPE)
of the Environmental Protection Agency (EPA). It documents the results of the first year
of three Comparative Risk Projects sponsored on a demonstration basis in EPA's Regions
1 (Boston), 3 (Philadelphia), and 10 (Seattle), The projects are a collaborative effort
between participating Regions and OPPE's Geographic Integration Branch at EPA
Headquarters in Washington, D.C. The projects use risk information in an integrated
approach to identify and to assess environmental issues, to set priorities among these
issues, and to develop appropriate strategies to manage these problems.
EPA initiated these two-year projects in 1987 to pursue new approaches to
environmental management and policy. These three Regions participated, not because
they have unusual environmental problems, but because they wanted to explore better
ways to manage environmental problems in their areas.
The decision-making body of each Comparative Risk Project consisted of a Steering
Committee made up mainly of senior Regional staff. Three technical work groups of
professional staff from the Region evaluated the risk information and developed the initial
rankings of issues. OPPE provided administrative, technical, analytical, and financial
support.
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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
US. Environmental Protection Agency
Region 3 - Environmental Services Division
841 Chestnut Street (3ES43)
Philadelphia, PA 19107
U.S. Environmental Protection Agency
Region 10 - Management Division
1200 Sixth Avenue (MD-102)
Seattle, WA 98101
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Acknowledgements
Numerous individuals contributed their time and effort to this report. They are:
Catherine S. Tunis, Geographic Integration Branch
Frederick W. Allen, Deputy Director, Regulatory Integration
Division
Arthur Koines, Chief, Geographic Integration Branch
Michael Drysdale, Geographic Integration Branch
James Hemby, Office of Air and Radiation, formerly with the
Geographic Integration Branch
Keith Hinman, Geographic Integration Branch
Mark Mahoney, Region 1
Lane Nothman, Region 10
Eva P. Ring, Geographic Integration Branch
Jeri Weiss, Region 1
Patricia Wilbur, Region 3
Thanks to all of the participants in each of the Regional Comparative Risk
Projects, both EPA staff and consultants. They have and are giving their best to these
projects, and have made possible the advances in knowledge gained from them.
Appendix F lists the participants of each Regional project.
iii
Coordinator:
Reviewers:
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Contents
Preface i
Acknowledgements iii
Contents iv
Tables vi
Figures vii
Executive Summary viii
L Introduction l
A. Comparative Risk Projects Address Major Challenges in Environmental
Management 3
B. Objectives of the Office of Policy, Planning and Evaluation 6
IX Analytical Approach to Ranking by Risk 9
A. The Projects were Designed to Meet Regional Needs 9
B. Each Region First Defined the Set of Environmental Problems 10
Q Each Project Set Common Analytical Ground Rules 16
D. Each Project Analyzed Risks and Developed Rankings 20
HI Process and Participants 25
A. Getting Started 25
B. Establishing the Analytical Framework 28
C Analyzing and Ranking the Problems 31
D. Developing Solutions to Environmental Problems 35
R Senior Management Approval and Documenting the Work 36
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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
VL Next Steps 79
A. Implementing the Analytical Findings in the Regions 79
B. Work by OPPE . . 82
VII. Conclusions 84
Appendix A. Definitions of Problems For Comparative Risk
Assessment A-i
Appendix B. Combining Different Types of Risk b-i
Appendix C. Successful Methodological Innovations. C-i
Appendix D. list of Acronyms D-i
Appendix E. Supplementary Reading E-i
Appendix F. Regional Project Participants F-i
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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
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Figures
Figure 1: Regional Comparative Risk Projects 1
Figure 2: Ranking of Problem Areas by Region 1 39
Figure 3: Ranking of Problem Areas by Region 3 40
Figure 4: Ranking of Problem Areas by Region 10 41
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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
viii
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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
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o higher health risks from Industrial Point Sources and Non-Point Discharges
to Surface Waters in the Regions where there are greater concentrations of
industrial dischargers and where a higher fraction of the population relies
on surface water as a source of drinking water.
PROBLEMS THAT WERE RANKED CONSISTENTLY BY ALL THREE REGIONS
High Health Risks
Indoor radon
Indoor air pollution other
than radon
Pesticides (primarily residues
on food)
Drinking water contamination
High Ecological Risks
Physical modification of
habitats
Nonpoint source discharges
to surface waters
Low Health Risks
Low Ecological Risks
Underground storage tanks
Active hazardous waste (RCRA)
sites
Active hazardous waste(RCRA) sites
Non-hazardous (solid) waste sites
Radiation other than radon
Abandoned hazardous waste (CERCLA) Underground storage tanks
sites
Non-hazardous (solid) waste sites
Note; ft list of all problem areas analyzed by the Regions Is presented in Table 1 beginning on page
12, and full definitions for each problem are presented in Appendix A.
Even where the relative risk rankings are similar, the causes of the risk sometimes were
different across Regions. These differences in the causes of risk indicate the need for
differing solutions.
The Regional rankings, again with a few important exceptions, compare well with
those developed in 1987 at the national level in EPA's Unfinished Business project.
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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 roje
in setting national environmental priorities. If we performed an analysis on smaller
geographic areas or on more narrowly defined environmental problems, geographic
distinctions in risk would become much more important. At an extreme, say at the
community level, the health risks from an uncontrolled hazardous waste site to the specific
individuals living in its immediate vicinity may well exceed those from indoor air pollution.
The analysis that supports the rankings may be even more valuable than the
rankings themselves. This analysis shows which components of risk ~ pollutants, source
types, potency, pathways, or exposure — contribute the bulk of the risk for each problem
area. The analysis also shows where the causes of risk vary across Regions even where
the relative rankings of the problems may be similar. This knowledge is key to identifying
opportunities for reducing risks and makes it easier for Regions to target programs
efficiently at the portions of problems causing particularly high risks.
The Regional rankings sometimes contrast very sharply with the relative levels of
Regional resources devoted to these different problem areas. Each of the three highest
health risk areas — radon, indoor air pollution and pesticide residues — are the subject
of minimal Regional program efforts. Regional programs addressing the two highest
ecological risk areas — habitat modification and non-point sources -- are larger, but still
small. By contrast, two of the low-risk problem areas — active and abandoned hazardous
waste sites (RCRA and CERCLA sites, respectively) — are the subject of major Regional
programs. Underground storage tanks (USTs) are the subject of moderate Regional
programs. Program resources devoted to solid waste and to radiation other than radon,
like their risks, are small.
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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.
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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.
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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
Region 10
Region 1
Region 3
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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.
Grounded in the concepts of risk assessment and risk
management, Comparative Risk Projects use estimates of risk —
the probability of adverse effects ~ as a common measure for
comparing and setting priorities among environmental issues.
These issues involve different pollutants, sources, and exposure
pathways that may affect human health, ecosystems, and financial
resources. In the past ten years we have learned about hundreds
of chemicals present in our environment that pose some risks of
causing cancer or other adverse health effects. Comparing the risks to help set priorities
allows environmental managers to focus limited resources to achieve the greatest reduction
in risk for a given cost of control. The projects are also intended to involve local
participants in the Regions in managing and conducting the projects, ensuring that issues
of greatest local concern are adequately addressed.
During the first year of the projects, all three Regions
identified, analyzed, compared, and ranked the risks posed by
major environmental problems facing each particular Region. For
each problem, project participants assessed the current risks posed
to human health and to Regional ecosystems. Region 3 also
assessed the welfare losses associated with each problem area.
The second step of the projects, already started, is to develop and
analyze initiatives to mitigate these environmental problems in order to answer the
Regions
analyzed risks
to human
health,
ecosystems, and
economic
welfare.
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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.
Today, nearly two decades of progress have generally provided
the Nation with a good foundation of environmental protection.
Some remaining environmental problems require uniform national
or global programs. But others are very site-specific, requiring
tailored controls at the Regional, state or local level for effective
mitigation. Even some national problems may be strongly affected
by local conditions such as land use patterns, the proximity of
populations or sensitive environments to environmental hazards, or by meteorology,
hydrology, and even personal preferences. These may be best addressed by local
solutions.
Regional, state and local offices will more and more frequently be making the
basic decisions about which environmental problems deserve governmental attention and
what the nature of that attention should be.
The second challenge is the need to understand all the environmental problems
facing our Nation, and to set priorities for management. Instead of the obvious pollution
problems of the past, today we are confronted with much more insidious problems, often
involving toxic chemicals. With advances in measurement techniques, we can detect toxic
chemicals nearly anywhere: in food, in drinking water, and in household products. Public
Some problems
are affected by
local conditions
and require
tailored local
solutions.
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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.
If environmental policy-making is to be anything other than
reactive, we must use risk analysis to judge the relative importance
of different risks. Risk analysis allows us to make rational
comparisons between very different types of environmental
problems — it is the best common denominator that we have.
Once we have established risk-based priorities, they can be
incorporated into a long-term planning framework to establish
The third challenge in environmental management is one that
These projects • js cornmon throughout government: concern for the Federal
help managers
work with deficit and tight budgets. Environmental programs remain
limited budgets. overwhelmingly popular with the public, but even popular
government programs are under budget pressure. Environmental
managers must be sure to buy the most environmental protection possible with the
resources available.
This adds up to a need to set environmental priorities carefully. Agency managers
must choose which environmental problems they will tackle, and then do it in the most
Risk analysis is
the best
common
denominator
for making
rational
comparisons.
effective programs.
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Managers must
set priorities
carefully.
effective and efficient manner. The problems must be looked at
in a systematic and integrated way to determine which are most in
need of attention. And programs should be carefully designed to
obtain maximum environmental results. In addition to measuring
progress administratively by the number of permits issued,
enforcement actions taken, or sources inspected, programs can gauge progress by
measures of the ultimate goals -- to reduce damages to human health and the
environment.
B. Objectives of the Office of Policy, Planning and Evaluation
The objective of these Comparative Risk Projects is to help participating Regions
improve the way they set their priorities. A major share of the project benefits will
accrue to the participating Regions. But we also expect national benefits. The projects
will demonstrate a new, systematic way of setting risk-based priorities that can be widely
adopted. The entire Nation will benefit to the extent that the input from the three
Regions improves national environmental priorities. The specific objectives of OPPE in
supporting these Regional projects are as follows:
First, we want to demonstrate that comparative risk analysis can help substantially
in environmental priority setting, and to learn which approaches work well. We hope
additional EPA Regional Offices and states will do Comparative Risk Projects, and we
would like to develop a general model for conducting them most successfully.
^Project, conducted at EPA Headquarters, produced the report
Unfinished Business: A Comparative Assessment Of Environmental
Problems in February, 1987. It ranked thirty-one environmental problems in terms of their
A second OPPE objective is a better understanding of how
Projects show
risks in Recnnns nf the mnntrv rliffp.r frnm in risks vip.wp.rl in an
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total nationwide risks, and has provided substantial guidance to EPA in establishing
national priorities. We now wish to acquire a more precise geographic understanding of
these risks.
Which problems are common to all or most regions? Which are of primary
concern in only limited geographic areas? Are there any problems not of high risk
nationally, but major concerns in specific regions? Are there problems that can be abated
more effectively by adjusting a national strategy to local conditions?
A picture of the variation of risks across the country will give EPA important
information on which programs and priorities should be uniform nationally and which
should be targeted geographically. Regions will have the analytical tools to participate
more effectively in developing better national and local management strategies.
comparative risk analysis helps OPPE and Regional participants to identify new or
growing environmental problems. Finally, the understanding of which environmental
problems are most serious and why helps EPA communicate this understanding to its
constituencies: Congress, industry, state and local governments, and the public. This
enhanced communication should help build a consensus regarding how society will address
its environmental concerns.
In a separate effort, EPA is evaluating the current Agency budget, planning, and
management systems and developing a strategic planning proposal to help the Agency set
Comparative
risk analysis
helps
professionals
understand
problems
better.
A third OPPE objective is to promote knowledge of the
principles of risk assessment and risk management and use of risk
analysis throughout EPA. In addition to understanding problems
and setting priorities, risk analysis can alert managers and staff to
the problems of shifting risks across media. For example, some
water treatment technologies will shift pollutants from water to air.
The comprehensive review of environmental problems through
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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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IL Analytical Approach to Ranking by Risk
The primary objective in the first year of these projects for each Region was to
develop a comparative ranking of the risks posed by the major environmental problems
in the Region. The basic approach was to define the list of problems to be compared,
to develop methods to analyze the risks posed by the problems, to collect and analyze
relevant data, and to rank the problems using this data and the participants' best
professional judgments.
A- The Projects were Designed to Meet Regional Needs
A major concern in designing the projects was to meet the perceived needs of
each Region. Although Headquarters' Office of Policy Analysis supplied contract funds
and provided guidance based on their experience with Integrated Environmental
Management Projects and with Unfinished Business, each Region directed its own project.
OPPE presented an analytical and process framework to each of the Regions, that the
project participants then adapted to address what they identified as their project goals and
priorities. There were differences in how the Regions defined the environmental problems
* T
they would compare, in what sorts of risks they investigated, in how the risk analyses were
conducted, and in the extent to which risk management issues were considered in the first
year.
It was important to find an appropriate balance between competing objectives of:
a) the desires of each Region, and b) a substantial consistency of approach and definitions
so the three projects could be compared, both with each other and with Unfinished
Business. On the other hand, to the extent the Regional approaches differ, we now have
a broader base of experience with which to advise future sponsors of such projects about
methodological choices.
-------
The projects
followed a
generally
consistent
approach.
The three Regional projects followed a generally consistent
approach, with numerous small variations. In this section, we will
note these variations, assess them, and point out where we believe
differing conclusions across the Regions are a function of different
methods, as opposed to real differences in risk.
B. Each Region First Defined the Set of Environmental Problems
The first task, defining the problems, required several important decisions.
Problems were
defined to
match BP A
programs.
There are many ways to divide up the universe of all
environmental problems. One might choose to divide by pollutants
(e.g., benzene, microbials, cadmium), by sources (e.g., automobiles,
power plants, USTs), by media (e.g., air, surface water), by
geographical region (e.g., Alaska, Puget Sound, the Cascades), or
by other factors. Each Region decided that the most useful scheme was to define the
problem areas to correspond to major EPA programs. This produced a mixture of
problems defined as pollutants, sources and media. EPA's air programs tend to divide
by pollutant class (criteria air pollutants, air toxics, radon, etc.), the waste programs divide
by source type (CERCLA sites, RCRA sites, USTs, etc.), but the water programs divide
by both source type (industrial point sources, publicly-owned treatment works (POTWs),
nonpoint sources), and media (wetlands, groundwater, drinking water). By defining the
problems in this way, the Regions made it easy to translate the results of a ranking into
implications for programs.
Second, each Region chose to start with the list from Unfinished Business, for
which thirty-one problem areas corresponding roughly with national EPA program areas
had been defined, and then make modifications.
10
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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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Table 1: Problem Areas Analyzed in the Regional
Comparative Risk Projects
Basic Problem Area
Criteria Air Pollutants
Acid Deposition
Toxic Air Pollutants
Indoor Radon
Indoor Air Pollutants Other
Than Radon
Radiation Other Than Indoor
Radon
Industrial Point Source
Discharges to Surface Waters
POTW Discharges to Surface
Waters
General Definition
Effects from six criteria air pollutants: sulfur dioxide,
total suspended particulates, carbon monoxide, nitrogen
oxides, ozone, and lead.
Effects from wet and dry deposition of acidic
compounds.
Effects from outdoor toxic air pollutants, excluding
criteria pollutants.
Effects from indoor radon from soil, drinking water,
building materials, etc.
Effects from all indoor air pollutants excluding radon.
Important Variations Across Regions
All Regions exclude sulfates, acid deposition. Region 10 in
its health ranking excludes particulates < 10 microns.
All Regions include effects of sulfates and acid aerosols.
Region 10 in its health rankings includes particulates < 10
microns.
Region 1 considers asbestos in a separate Problem Area.
Effects from naturally occurring and man-made
radiation other than radon. Includes both ionizing and
non-ionizing radiation.
Effects from industrial effluents discharged from
"discrete conveyances" such as pipes and outfalls.
Effects from discharges from municipal wastewater
treatment facilities. Also includes the effects from
industrial facilities that discharge to POTWs.
Region 1 includes only non-ionizing radiation. Region 10
excludes natural background radiation.
Region 3 also includes air emissions from industrial
wastewater treatment facilities.
Region 3 also includes air emissions from municipal
wastewater treatment facilities.
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Table 1: Problem Areas Analyzed in the Regional
Comparative Risk Projects
Basic Problem Area
General Definition
Important Variations Across Regions
Nonpoint Source Discharges to
Surface Waters
Drinking Water
Active Hazardous Waste
(RCRA) Sites
Abandoned Hazardous Waste
(Superfund) Sites
Effects from pollutants that reach surface waters from
sources other than discrete conveyances for effluents.
Includes runoff, air deposition, discharge of
contaminated ground water, releases from contaminated
in-place sediments, etc.
Effects from contaminants in drinking water at the tap.
Effects from contaminants released into any medium
(air, surface water, ground water, soil) by sites covered
by RCRA. These are mostly sites actively managing
hazardous wastes, but sites recently closed are included
also. Includes facilities such as landfills, incinerators,
storage units.
Effects from contaminants released into any medium by
abandoned, inactive hazardous waste sites. Includes
sites on the NPL, potentially on the NPL, being
addressed by states under similar programs, and any
other abandoned sites.
Region 1 attributes pollution from sediments to the source
type that contaminated the sediments in the first place.
Region 3 includes only contaminants not deriving from
other problem areas. Region 10 splits problem into public
and private systems.
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Table 1: Problem Areas Analyzed in the Regional
Comparative Risk Projects
Basic Problem Area
Non-Hazardous Waste Sites
Underground Storage Tanks
Other Ground-Water
Contamination
General Definition
Effects from contaminants released into any medium by
sites where non-hazardous waste is managed. Includes
municipal solid waste landfills, industrial non-hazardous
waste surface impoundments, municipal incinerators,
mining waste sites, etc.
Effects from contaminants released into any medium by
underground storage tanks. Includes mostly gasoline
tanks, but also chemical tanks, home heating oil tanks,
and chemical storage tanks.
Effects from ground-water contamination from sources
not covered under other problem areas. Includes such
sources as leaching of agricultural chemicals, septic
tanks and underground injection wells.
Important Variations Across Regions
Region 1 splits into separate problem areas for municipal
and industrial sites.
Region 1 includes all storage tanks. Region 10 includes all
storage units.
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Table 1: Problem Areas Analyzed in the Regional
Comparative Risk Projects
Basic Problem Area
Pesticides
Accidental Releases
Physical Alteration of Habitats
General Definition
Effects from pesticides through diverse pathways.
Effects from accidental, non-routine releases of
hazardous substances. Includes such events as oil spills,
chemical plant releases, transportation accidents.
Effects from physical activities that change ecological
conditions. Excludes pollution or chemical impacts.
Includes effects of activities such as dredging, filling
wetlands, urbanization, silviculture, dumping of plastics
and other litter.
Important Variations Across Regions
Region 1 has separate problem areas for pesticide residues
on food and pesticide application. Region 3 includes
residues on food and rista to applicators together. Region
10 has separate problem areas for application of pesticides
and other pesticide risks (including residues, leaching,
runoff, household use, etc.).
Region 3 has no separate problem area for this, instead
including accidental releases with routine releases under
other problem areas.
Region 3 and Region 10 both have separate problem areas
for aquatic and terrestrial habitats. Region 1 has only a
single problem area: Wetlands/Habitat Loss.
In addition, Region 1 included several problem areas that had no counterparts in the other Regions:
o Discharges to Estuaries, Coastal Waters, and Oceans from All Sources
o Lead
o Asbestos
o Lakes, Ponds, Impoundments
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C Each Project Set Common Analytical Ground Rules
All three Regions (as well as Unfinished Business preceding them) adopted several
important ground rules to structure the ranking of environmental problems.
Projects
compared
ultimate effects,
or risks.
First, the Regions decided to analyze and compare
environmental problems in terms of the ultimate effects (which
we will call "risks") that they entail. The ultimate effects we are
interested in are the final impacts to humans and the environment
caused by a type of pollution: the number and types of human
disease cases, the extent of ecological damage, and the amount of economic losses. EPA's
authorizing statutes specify these ultimate impacts as the reason for the Agency's existence
and the reason we try to mitigate environmental pollution. The Agency's mandate is to
protect human health and the environment. We do not install scrubbers on electric power
plants to reduce SOz emissions or to meet ambient air quality standards; we do it so that
fewer people will get sick, fewer lakes will suffer ecological damage from acidification, and
fewer outdoor materials will be damaged by airborne acids, needing repair or replacement.
Projects
analyzed
residual risks--
those remaining
given current
controls.
Second, the Regions focused on assessing the residual risks
associated with each problem area. By residual risks we mean
the risks that remain given current levels of controls in place and
current levels of non-compliance with regulatory requirements.
The Regions did not assess: 1) risks that have been abated, or
risks as they would have been in the absence of control actions; or
2) risks that will be abated, or risks as they will be after current
requirements are implemented and met.
The Regions focused on residual risks because of an interest in what more they
should do about environmental problems. They wanted to assume current controls as
16
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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). The4 analysis that supports the rankings will provide some clues,
but additional risk analysis is needed to identify specific program changes.
o A problem area can appear to be high risk now even though existing laws, and
regulations will reduce it to low risk when they are fully implemented.
For the above reasons, the risk ranking results cannot be translated directly into
priorities for a Region.
More important in this regard, though, is the third ground
rule: in ranking the problem areas, the Regions have considered
assessment was
carefully only the risks associated with them. The Regions sought to keep
separated from the risk ranking separate from consideration of other attributes
risk
management. that may be equally important in determining what we should do
about the problems. These items such as cost, technical feasibility
, of controls, public opinion, politics, and statutory mandates, are
17
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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 benefits and costs of any specific project proposal will
not necessarily match the inherent riskiness of the problem area
that it addresses. There may be a particularly good investment
opportunity to reduce risks in a low residual risk problem area.
There may be current EPA program activities aimed at a high
risk problem area that could be cut back without any appreciable
increase in risk. But there probably is a correlation between high
residual risk problem areas and good investment opportunities, and between low residual
risk problem areas and good disinvestment opportunities. Our risk rankings provide a
rough guide to where to begin to look for investment and disinvestment opportunities.
Specific budget shifts should depend on the analysis that supports the rankings as well as
The risk
rankings are a
rough guide for
resource shifts.
Afore analysis
is needed.
18
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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
Priority-setting environmental. protection should be directed at reducing
must balance
risk and other demonstrated risks. But other factors, called risk management
concerns. factors, are also important, and setting priorities must involve
balancing numerous concerns. Where then does risk management
— determining what EPA should do about environmental problems — come into these
projects?
In Regions 1 and 10, risk management has been addressed in the first year by
separate risk management work groups that functioned independently of the risk ranking
process. , These work groups developed ways of combining other factors with risk.
Regions 1 and 10 have also begun the process of developing and analyzing strategies to
respond to the environmental problems. Region 3 already had in place its Measurable
Environmental Results Initiatives (MERITs) program, through which they could solicit and
evaluate initiatives to address environmental problems, so they devoted staff time that
could have been used for a risk management work group to analyzing welfare risk.
Although the final ranking of problem areas was not completed until after the deadline
for submitting MERITs, much of the information and analysis that went into the rankings
also prompted some FY '88 MERITs. Each Region developed successful proposals for
new projects and resource shifts based on the first year's risk management analyses.
Many of these initiatives are now being implemented.
In all three Regions, risk management is a main focus in the
second year of the projects. Ail three Regions plan to integrate
risk analysis and risk management to identify and analyze strategies
for addressing risk (especially in the higher-ranked problem areas)
in the most effective and cost-efficient manner, and incorporate
All three
Regions are
analyzing risk
management.
19
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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.
occurring for nearly all the problem areas — risks in all three categories were attributed
to the problem area. There was no effort to decide which type of risk was most
important
Some gray areas that fell between these three types of risk were resolved during
the course of the analysis. Region 3 gave substantial thought to establishing a boundary
between health and welfare risks. The health effects themselves due to environmental
pollutants were counted as health risks, but costs of treating these diseases and
productivity lost because of illness were counted as welfare losses. This did not represent
double-counting risks, but simply that an environmental problem can simultaneously cause
multiple types of risk.
Environmental
problems can
cause several
types of risk.
Environmental problems may cause multiple types of risk.
For example, elevated levels of ozone can cause human health
damage (increased asthmatic attacks), ecological damage (reduced
rates of growth of many plant species) and welfare damage
(accelerated deterioration of rubber products). In such cases ~
21
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The risks were analyzed by two or three separate work
groups, one for each type of risk. Regions 1 and 10 established
health and ecological work groups for risk analysis, while Region
3 established health, ecological and welfare work groups. Distinct
rankings for each type of risk were produced in each Region.
Thus, a problem, e.g. indoor radon, could rank high for human
health risk, but low for ecological risk, and medium/high for
The Regions considered combining the separate health,
ecological, and, in Region 3, welfare rankings into a single
aggregate risk ranking. Each Region decided not to do so. They
believed there was no sound analytical or scientific basis for
deciding which type of risk is most important. This was thought
to be a policy question distinct from risk analysis that would
require considerably more thought and discussion.
It is, however, possible to compare how a specific problem area ranks across the
different varieties of risk. Each work group in a Region, with very few exceptions, dealt
with problem areas that were defined identically. Each work group used the same
analytical ground rules, and each had a clear specification of the boundaries of the type
of risk they considered.
There have been other opportunities for EPA Regions to express their opinions
on which environmental problems are most pressing, but the Comparative Risk Projects
are unique in that they seek to generate a priority ranking in a systematic, objective, and
data-driven way. The projects aimed to generate as much quantitative data on risks as
possible, but faced some inevitable constraints:
Separate work
groups
analyzed each
type of risk
and developed
a ranking.
welfare risk.
The Regions
did not
combine their
separate
rankings.
22
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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. Full risk, assessment, in which data on
emissions and ambient concentrations are collected, exposures are modeled,
and ultimate impacts are projected, is very costly.
o Even if resources had been unlimited, risk analysis is an uncertain process.
Subjective interpretation of the results of any risk analysis is always
necessary, weighing the strength of the data base used and the validity of
the assumptions made.
estimates and assessments.
To stretch our resources, we relied extensively on . risk analyses that had already
been done for other purposes prior to the Regional Comparative Risk Projects, and
adjusted them to suit our needs. The work done on Unfinished Business was particularly
helpful. In many cases, we extrapolated from existing analyses that covered only part of
what we were interested in -- only some of the pollutants of concern, only some of the
Region, or only some of the damage pathways encompassed by a problem area.
For example, for each of the three Regions, a contractor modeled the Regional
health risks from about twenty toxic air pollutants. But there are far more than twenty
The projects
supplemented
data with
expert
judgement in
an objective
manner.
We used the expert judgment of EPA Regional staff
knowledgeable about local environmental problems to evaluate
available data and analyses. We decided to quantify our results
to the extent available data and time allowed, to recognize the
universal; need to supplement the data with judgment, to make
the judgments in an objective and consistent manner, and to
address significant gaps in data through future refinement of the
23
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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 not
perfect, they imposed consistency and objectivity in each problem area. In addition, each
work group conducted their analyses and developed their rankings in collegial fashion,
with the entire group having the opportunity to question and debate major points.
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IH Process and Participants
The Regions used a similar process throughout the first year of their Comparative
Risk Projects. The processes are expected to diverge more in the second year as the
Regions pursue more particularized means to expand the first year's findings and to
implement them. The major elements of the Regional projects to date follow.
A. Getting Started
Regional Administrators (RA's) and Deputy Regional
The projects Administrators (DRA's) in • the three Regions, as managers of
provide
analytical environmental protection efforts by all the Program Offices, were
support for interested in the potential a Comparative Risk Project has for
Regional
priorities. assisting in environmental decision-making across all media. Each
of these Regions was also interested in increasing their flexibility
to address problems that they felt should have a higher priority
then the National Program Managers did (or a higher priority in the Region than
nationally.) The National Program Managers generally felt that a Region that could
support its priorities with solid risk-based analysis could make the best case for being
given the needed flexibility for implementing those priorities. The Comparative Risk
Projects seemed to be the best way of accomplishing that goal.
The RAs and DRAs recognized the need to involve the Division Directors from
each Program Office in their Regions in these projects to get the benefit of staff expertise
in conducting the projects and to insure the credibility of the results. The Division
Directors served on the Project Steering Committee, which set the direction for the
project and reviewed the analyses prepared by the technical work groups. Region 10 also
included a representative from a state environmental program. The Steering Committee
25
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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.
mid-level managers. Region 10 included a representative from a state environmental
program on each of their work groups. All major EPA programs were represented on
each work group, in order to provide them with the breadth of substantive expertise about
environmental problems needed to perform their cross-cutting tasks. The Regions tried
to assign individuals with experience and training in health, ecological or welfare risk
assessment to appropriate work groups. The result was a wide range of methodological
Regional work
groups
performed
analysis and
prepared the
rankings.
Each Region formed work groups, which performed the bulk
of the project analysis and prepared the rankings. Regions 1 and
10 each formed three work groups: health risk, ecological risk, and
risk management. Region 3 formed three work groups also: health
risk, ecological risk, and welfare risk. Each work group consisted
of 10-20 individuals, mostly Regional technical staff but including
a few Regional managers. The work groups were all chaired by
26
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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,
- •——— ¦
This is a resource-intensive process. Each Regional project has invested the following
approximate staff and budget resources:
. o Thirty to forty professional staff people served as work group members. They
spent 5-10% of their time on the project.
o Steering Committee functions took about five two-hour meetings by all senior
Regional managers. Additional uncounted time was spent for project initiation,
supervising staff, and implementing findings.
o One to three professional staffers served full-time as project managers.
o About 1 .work year from OPPH in analytical and administrative staff support
was provided for each Regional project.
o $125,000 - $150,000 in contract resources was provided by OPPE to assist the
work groups in developing their ranking methodologies, gather data and perform
analyses. ' ¦
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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.
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OPPE staff, contractors, and Regional project management
staff all worked with the groups to develop methodology options.
Three methodology option papers (one each for health, ecological,
and welfare risk analysis) were prepared and circulated by OPPE.
Each work group spent about four two-hour meetings discussing
and developing methodologies, and continued to modify their
original methods as the analysis progressed.
Each work group developed a method based roughly upon the paradigm for risk
assessment. Because of the broad scope of the necessary analysis, the methods diverged
substantially from traditional quantitative risk assessment.
One might imagine conducting a traditional risk assessment for all the pollutants
associated with each problem area, summing across pollutants, and then comparing the
estimated risks for each problem. In fact, that would be an impossibly large task. Most
problem areas involve numerous pollutants (sometimes potentially thousands of toxic
pollutants), each of which may cause several damaging effects, and each of which occurs
in thousands of different patterns of exposure across the nation. The risk analysis
methods used for the Regional Comparative Risk Projects generally consisted of:
o Identifying representative or typical exposure scenarios for representative
pollutants associated with each problem area,
o Calculating risks for the chosen scenarios using generally available information
on hazards and dose-response relationships, and
o Scaling up to the entire problem area.
For health risks the methods included: 1.) selecting chemicals representing each
problem area, 2.) estimating individual and population risks for cancer effects using
OPPE,
contractors,
and Regions
worked
together to
develop
analytical
methods.
29
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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 effects. Risk assessment will normally
consist of the following'four steps:
1. Hazard identification involves weighing the available evidence and deciding
whether a substance exhibits a particular adverse effect. Most attention has been
focused on human health effects, particularly cancer, but hazard identification can
extend to ecological damages (e.g., does suspended sediment in water damage fish
reproduction?) and to welfare damages (e.g., does ozone damage plastics?) as well.
f j y
2. Dose-response assessments determine potency -- how strong a particular
adverse effect is caused by a pollutant at various levels of exposure or dose.
3. Exposure assessment entails estimating the concentrations, frequency and
duration of human exposure to pollutants of concern, the routes or pathways of
exposure (how the pollutant gets to the person), and the number of persons exposed
for various combinations of exposure and pathways. The best method is direct
measurement or monitoring of ambient conditions, but this is often prohibitively
expensive. In practice, risk assessors usually rely on estimates of emissions and
limited monitoring information, combined with mathematical models that estimate
resulting concentrations.
4. Risk characterization estimates the risk associated; with the particular
exposures in the situation being considered. While the final calculations are
straightforward (exposure multiplied by potency equals risk), the way in which the
information is presented is important. The final assessment should display all
relevant information, including such factors as the nature and weight of evidence for
each step of the process, the estimated uncertainty of the component parts, and the
distribution of risk across various sectors of the population.
30
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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.)
C Analyzing and Ranking the Problems
The lead work group member for each problem area was responsible for deciding
on a plan for analyzing the problem area that conformed with the work group's
methodology, collecting the necessary data, performing the analysis, and reporting the
results to the entire work group.
^^ first step for the problem-leaders was to prepare "Plan of
Leaders for Attack" (POA) papers for each problem. These outlined the data
each problem
presented and analysis proposed for each problem, and typically relied on
analysis to national analyses modified to reflect data sources thought,to be
work groups.
available to the Regions. No Region-specific data was actually
acquired, this was left for the analysis step. The problem-leaders
presented their POAs to the entire work group for review so inconsistencies or flaws
could be spotted before they were put into action.
31
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Work group members next worked closely with contractors, Regional, and OPPE
staffs to gather data and conduct the analyses. Papers summarizing the results of the
analyses were written by or provided to the problem-leaders. This analysis took place
over a three-month period.
Rankings were developed by the work groups in all-day
"or^oups meetings. In these meetings, the problem leads presented the
problems in all- results of the analyses to the other work group members. The
day meetings. processes used for ranking then differed across the work groups.
Some were quantitative, in which the work .group used explicit
procedures to score a set of predetermined factors for each problem area and combine
the scores into a total score for each problem. The ranking was then given by the rank-
ordered scores for the problems.
At the other extreme, some work groups used a qualitative process. They simply
reviewed the available information on risks from the problem areas, and worked to
develop a group consensus on an overall ranking of problems. In this approach, each
work group member might have different ideas about the key factors involved in ranking,
and how these factors interrelated.
More specifically, the ranking methods used for the three types of risk were as
follows:
Health risk approach: Region 1 developed information on
individual and population risks for cancer and non-cancer effects
for each problem area. They developed a cancer ranking and a
non-cancer ranking, then used a qualitative consensus process to
combine them into a single health ranking. The ranking places
each problem into one of five relative risk categories, but problems
32
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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.
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
The Region 1 work group identified and evaluated potential
factors which should be considered by Regional management in
developing strategies to reduce risks associated with each of the
environmental problem areas. This was to supplement the risk
analysis conducted by the health and ecological risk work groups
by overlaying "real world" considerations on the decision-making
process. The risk management factors evaluated for each problem
included: (1) public perception, (2) availability of Regional office resources, (3) economic
impact of controls, (4) legal authorities to reduce risks, and (5) the effectiveness of
available control techniques. Each factor was scored on a scale of one to five, with one
indicating that the problem was difficult to manage and five indicating that the problem
was easy to manage. The result was a matrix showing the score for each problem area
for each factor. It was decided not to combine the scores into a single overall total, since
the work group could not agree on a way to reflect the relative significance of the
different factors in the decision-making process.
Region 10's "risk reduction team" was charged with developing and evaluating
proposals to alleviate risk, especially in areas targeted as high-risk. The Region 10 team
assigned a member to each problem area being analyzed. These individuals were
responsible for understanding the risk assessment findings and for creating risk reduction
problems.
Regions 1 and
10 analyzed
risk
management in
work groups.
Region 3 used
MERITS.
35
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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.
E. Senior Management Approval and Documenting the Work
In the three Regions, the work groups' risk rankings were
The Steering presented to the Steering Committees. No Steering Committee
Committees
ratified the chose to modify the rankings, preferring to rely on the analysis
work groups and technical judgments of the work groups. In addition, no
rankings.
Steering Committee chose to combine the separate rankings
(health, ecological, welfare) into a single aggregate ranking. This
choice not to combine rankings may make the task of allocating resources according to
risk priorities somewhat more difficult. But the task of combining the separate risk
rankings is complex. Not only would decision-makers need to value, or weight, different
types of risk, but they would also need to consider another issue. Because the problem
areas were only ordinally and not cardinally ranked, the difference in risk between the #1
and #2 problem areas may be much different than that between #2 and #3, and the
difference in risk between the first and last ranked problem areas for health risk may
36
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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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Health
o Criteria Air
Polutants
(Ozone)
o Radon
o Lead
Figure 2: Ranking of Problem Areas by Region 1
o Add Deposition and
V&bifty (includes
particulates)
~ Indoor Air Polutants
Other than Radon
o Industrial Point
Source Discharges
to Surface Waters
~ Drinking Water
o Other Groundwater
Contamination
o Pesticide Residue
Foods
HIGHER RISK
o Hazardous/Toxic Air
Polutants
o Asbestos
o Discharges to
Estuaries, and Oceans
o Nonpoirrt Source
Discharges to Surface
Surface Waters
o POTW Discharges to
Surface Waters,
o Accidental
o Releases From
Storage Tanks
o Pesticide
Appication
NO
0 Radiation from
Sources Other than
Radon (non-ionizing)
o RCRA Waste Sites
o Superfund Waste Sites
o Municipal Waste Sites
o Industrial Waste Sites
Ecological
o Criteria Air Polutants
o Acid Deposition and
Visibility
o Industrial Point Source
Discharges to Surface
Waters
o POTW Discharges to
Surface Waters
o Nonpoint Source
Discharges to Surface
Waters
o Habitat Loss
a Accidental
Releases
o Superfund Waste Sites
o Industrial Waste Sites
o Municipal Waste Sites
o Other GW Contamination
o Pesticide Residues
on Food
o Pesticide Application
o RCRA Waste Sites
o Releases from Storage
Tanks
Note: Region 1 problem areas are unranked within each boxed category.
LOWER RISK
oRadon
O Indoor Air PoRutants
Other Than Radcn
o Drinking Water
o Lead
o Asbestos
o Radiation From Sources
Other than Radon
(Non-Ionizing)
* These problem areas
were not ranked because of
low eco risks.
-------
Figure 3: Ranking of Problem Areas by Region 3
Health
i i
Ecological
Welfare
z
©
X
m
u
(/>
*
O
m
30
3D
£ T
o Indoor Air
o Indoor Radon
o Other Pesticide
o Radiation
o Nonpolnt Sources
o Water Supply
o Acid Deposition
oPOTWs
o Criteria Air
o Other Groundwater
o Industrial Point Sources
o RCRA Sites
oCERCLA Sites
o Air Toxics
o Solid Waste
o Terrestrial Habitat Modification
o USTs
o Aquatic Habitat Modification
o Terrestrial Habitat Modification
o Aquatic Habitat Modification
o Nonpolnt Sources
o Acid Deposition
o CERCLA Sites
o Criteria Air
o Air Toxics
o USTs
o Industrial Point Sources
o Radiation
oPOTWs
o RCRA Sites
o Solid Waste
o Indoor Radon
o Indoor Air
o Other Groundwater
o Other Pesticides
o Water Supply
o Criteria Air
o Acid Deposition
o Nonpolnt Sources
o Water Supply
o Indoor Air
o Indoor Radon
o Other Pesticides
oPOTWs
o Radiation
o USTs
o Industrial Point Sources
o Other Groundwater
o RCRA Sites
o Terrestrial Habitat Modification
o Solid Waste
o Aquatic Habitat Modification
oCERCLA Sites
o Toxic Air Pollutants
Note: The Region 3 problem areas are ordinally ranked for each risk type.
The Region 3 Health and Welfare Work Groups also divided each ordinal
ranking into High, Medium, and Low categories. The Welfare Work Group had more
confidence in this grouping than in their ordinal ranking. See the Region 3
report for details.
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Health
Figure 4: Ranking of Problem Areas by Region 10
o Indoor Radon
o Other Indoor Air
o Pesticides
o Air Toxics Plus
PM10
o Non-Public
Drinking Water
o Public
Drinking Water
o Other GW
o Criteria Air
Pollutants
HIGHER RISK
o Nonpolnt
Sources
o POTWs
o Accidental
Releases
o Hazardous
Waste Sites,
Abandoned
o Other Radiation
o Releases from
Storage Units
o Industrial Point
Sources
o Current Hazardous
Waste Sites
o Non-Hazardous
Waste Sites
Ecological
o Nan-Chemical
Degradation
-Terrestrial
o Non-Chemical
Degradation
- Aquatic
o Pesticides
o Nonpolnt Sources
o Industrial Point
Sources
o Criteria Air
Pollutants
o POTWs
LOWER RISK
o Accidental
Releases
o Add Precipitation
o Hazardous Air
Pollutants
o Active Hazardous
Waste Sites
oAbandoned
Hazardous Waste
Sites
o Releases From
Storage Units
o Non-Hazardous
Waste Sites
o Other Radiation
Note: Region 10 problem areas are unranked within each boxed category for health
risk. They are ordinally ranked within the boxes for ecological risk.
-------
sources, habitat losses, and accidental releases.
Region 3 ranked as its most serious health problems indoor air pollution (despite
poor data, a wide variety of adverse health effects and extremely broad exposure) and
indoor radon (causing about 1700 cancers annually). The highest ecological risks were
attributed to physical modification of both terrestrial and aquatic habitats (because they
are widespread, can cause devastating impact, and may be irreversible), with nonpoint
sources close behind. The highest welfare risks were believed to be caused by criteria air
pollutants (materials damage, crop damage, and forest damage) and acid deposition
(visibility losses, health care costs, materials damage, and forestry damage).
Region 10 ranked as its most serious health problems indoor radon (based on
strong data, and areas of high natural radiation), other indoor air pollution (caused
especially by tobacco smoke, formaldehyde, volatile organic compound mixtures,
microbials), pesticides (both immediate effects from application as well as effects from
residues on food and aerial drift) and air toxics plus particulate matter less than ten
microns (because of cancer risks from air toxics, and high non-cancer risks ~ including
death — from high particulate exposures in about a dozen cities). The highest ecological
risks were caused by non-chemical degradation of terrestrial and aquatic ecosystems (again
because of wide scale effects that are often severe and occur in high-value ecosystems),
pesticides (due to high toxicity, large scale, and increasing use) and non-point source
discharges (problems from agriculture, forestry, urban runoff and failing septic systems).
Findings for Major Problem Areas
In this section, we display the three Regions' findings for each of the major
problem areas. In order to simplify the presentation, we take some liberties by grouping
together problems that are defined somewhat differently across the Regions. The findings
for the major problem areas are shown below in Table 2.
42
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lauie z: oummary or rinaings ior Major fro Diem Areas
Rankings by Region
Risk
Problem Area Region Ranking General Comments Specific Regional Comments
Criteria Air
Pollutants
Human
Health
Risk
R1
R3
RIO
High
Medium
Medium
Large numbers of low severity non-cancer
effects and no cancer effects. Definitions
more restrictive than typical.
Rl: High ranking due to ozone. Definition excludes
lead, particulates and acid aerosols.
R3; Definition excludes sulfates.
RIO; Definition excludes PM 10
Ecological
Risk
R1
R3
RIO
High
Medium/high
Medium/high
Experimental data on growth declines for trees
and crops exposed to criteria air pollutants
cited. Effects of acid deposition excluded and
counted in its own problem area.
Rl: Documented adverse impacts in Region
R3, RIO: Damages expressed, but not observed
and documented in Regions,
Welfare
Risk
R3
High
R3: Ranked highest, at about $1 billion annual damages.
-P»-
u>
Air Toxics
Human
Health
Risk
Rl
R3
RIO
Medium
Low
High
Similar data available to each Region on modeled
concentrations of about 20 chemicals.
R3:Low ranking attributable to finding no evidence
of non-cancer effects.
R10:High ranking may be due to inclusion of PM10.
Ecological
Rl
Unranked
Data on impacts virtually non-existant in all 3
Risk
R3
Medium/high
Regions.
RIO
Medium
Welfare
Risk
R3
Low
R3:Only health care costs were examined.
Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10,
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Table 2: Summary of Findings for Major Problem Areas
Rankings by Region
Risk
Problem Area Region Ranking General Comments Specific Regional Comments
Acid Deposition
Human
Health
Risk
R1
R3
RIO
Medium/High
Medium
Unranked
R1,R3: Ranked acid deposition high due to debatable
adverse effects from acid aerosols and airborne
sulfates.
Ecological
Risk
R1
R3
RIO
High
Medium/High
Medium
Different ranking by Regions because of
varying geographic factors.
Rl; Significant acidification in lake, forest decline.
R3: Widespread potential, but unproven terrestrial
effects. Some damage in surface waters.
RIO: No current adverse impact measured.
Welfare
Risk
R3
High
R3: Second leading cause of welfare damage at over
$500 million per year.
-j^ Indoor Radon
Human
Health
Risk
Rl
R3
RIO
High
High
High
First or second leading environmental cause of
cancer in each Region. High indoor radon
levels in all three Regions.
Ecological
Rl
Low
Risk
R3
Low
RIO
Low
Welfare
Risk
R3
Medium/high
R3: Damages high due to large number of cancers causing
high medical treatment costs and lost productivity.
Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10.
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Table 2: Summary of Findings for Major Problem Areas
Rankings by Region
Risk
Problem Area Region Ranking General Comments Specific Regional Comments
Indoor Air Pollution
(other than radon)
Human
Health
Risk
R1
R3
RIO
Medium/high
High
High
Regional ranking difference relates to how each
Region scaled up from limited data.
Environmental tobacco smoke considered
important factor.
Rl: Asbestos ranked as separate problem area, which
lowers ranking relative to other Regions.
Ecological
R1
Low
Risk
R3
Low
RIO
Low
Welfare
Risk
R3
Medium/ high
R3: Ranked as a medium/high welfare cost due to high
health costs.
^ Radiation
(other than radon)
Human
Health
Risk
Rl
R3
RIO
Low
Medium/high
Low
In all Regions, increased radiation doses from
human activities (i.e. nuclear fuel cycle,waste
disposal) considered minimal.
R3: Has higher ranking because they include natural
background outdoor radiation.
Ecological
Rl
Unranked
Risk
R3
Medium
RIO
Low
Welfare
Risk
R3
Medium
R3: Ranked medium due to costs of adverse health effects
from natural background radiation.
Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10.
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Problem
Risk
Area
Table 2: Summary of Findings for Major Problem Areas
Rankings by Region
Region Ranking General Comments Specific Regional Comments
Industrial
Point Source
Discharges to
Surface Waters
Human
Health
Risk
R1
R3
RIO
Medium/high
Medium/low
Low
Rankings reflect geographical and definitional
differences among Regions. Effects through
both fish consumption and drinking water.
Rl: Included effects from contaminated sediments
(PCBs and mercury); contaminated sediments included
as non-point sources in R3 and RIO. Rl has more
industrial discharges with substantial toxics near
population centers than other Regions.
Ecological
Risk
R1
R3
RIO
High
Medium
Medium/high
All Regions developed rankings based on biennial
state reports on quality of their surface waters
(305(b) reports).
Welfare
Risk
R3
Medium/low
R3: About $30 million annually in damages.
•Ct POTW Discharges to
Surface Water
Human
Health
Risk
Rl
R3
RIO
Medium/low
Medium
Medium/low
POTWs typically discharge fewer toxics than
industrials, but have more microbial pollutants.
R3,R10: More concerned with the effects of bacteriological
contamination.
Ecological
Risk
Rl
R3
RIO
High
Medium
Medium/high
Rankings based on biennial state reports on
quality of their surface waters (305(b) reports).
Welfare
Risk
R3
Medium
R3: About $90 million in annual damages to recreation
and aesthetics.
Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10.
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Table 2: Summary of Findings for Major irobiem Areas
Rankings by Region
Risk
Problem Area Region Ranking General Comments Specific Regional Comments
Non-point
Discharges
To Surface Water
Human
Health
Risk
R1
R3
RIO
Medium
Medium/High
Medium/Low
All Regions agreed that bacteriological problems
in drinking water and fish and bioaccumulated
toxics in fish represent primary risk pathwys.
Ecological
Risk
R1
R3
RIO
High
High
High
Data from biennial state reports on quality
of their surface waters (305(b) reports) showed
non-point sources to degrade more water bodies
than point sources.
Welfare
Risk
R3
Medium/High
R3: About $265 million in annual damages to recreation,
aesthetics and domestic water consumption.
Drinking Water
-J
^ Contamination
Human
Health
Risk
R1
R3
RIO
Medium/high
Medium/high
Medium/high
Definitional differences are important to Regional
rankings. See specific Regional comments.
Rl: Included lead in separate category and found
moderate cancer risks and important non-cancer
risks from drinking water.
R3: Defined drinking water to exclude contaminants from
sources covered elsewhere. This included only risks from
corrosion (lead) and trihalomethanes.
RIO: Split drinking water risk into public and private
systems. Private systems have fewer people exposed,
but higher individual risks.
Ecological
R1
Low
Risk
R3
Low
RIO
Low
Welfare
Risk
R3
Medium/high
R3: About $25 million in annual damages attributable
from corrosive water and health costs from corrosion
and trihalomethanes.
Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10.
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Problem
Risk
Area
Table 2: Summary of Findings for Major Problem Areas
Rankings by Region
Region Ranking General Comments Specific Regional Comments
Other Groundwater
Contamination
Human
R1
Medium/high
All three Regions found highest risk to be large
Health
R3
Medium
numbers of microbial disease cases from septic
Risk
RIO
Medium/high
and other sources, primarily affecting private
wells.
Ecological
R1
Medium/high
Rl: Ranked higher due to impact of nutrients
Risk
R3
Low
from septic tanks on eutrophication of lakes
and potential contamination of drinking
water sources.
RIO
Unranked
R3: Ranked low since surface discharge of
contaminated groundwater counted as non-point
source.
Welfare
R3
Medium/low
R3: About $25 million in annual costs, to treat water
Risk
supply, and losses in value of groundwater for
future use.
Abandoned Hazardous
Waste (CERCLA) Sites
Human
Health
Risk
Rl
R3
RIO
Low
Medium/low
Medium/low
Based largely on worst-case modeling of ground
water risks. Extrapolation from National Priority
List (NPL) sites where data was available, to non-
National Priority List (NPL) sites is uncertain.
Ecological
Risk
Rl
R3
RIO
Medium
Medium/high
Medium
Documented impacts to aquatic ecosystems from
a moderate number of sites.
Welfare
Risk
R3
Low
R3: About $8 million in annual costs to treat water supplie
and losses in value of groundwater for future use.
Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10.
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Rankings by Region
Risk
Problem Area Region Ranking General Comments Specific Regional Comments
Active Hazardous
Waste (RCRA) Sites
Human
Health
Risk
Rl
R3
RIO
Low
Medium/low
Low
Rl: Used model to estimate risks from management of
different streams. Incineration largest risk.
R3: Assumed undetected releases from RCRA sites would
pose similar risks as sites investigated in the past.
RIO: Investigated risks at some of worst known sites.
Ecological
Risk
Rl
R3
RIO
Medium
Medium/low
Medium
Little data available, generally showing local aquatic
impacts around a few sites.
Rl 0: Believed risks higher for active rather than
inactive sites because of larger quantity of waste being
measured.
R3: Believed the opposite of RIO.
Welfare
Risk
R3
Medium/low
R3: About $24 million in annual costs to treat water
supplies and losses in value of groundwater for future use.
-P-
vo
Non- Hazardous
Waste Sites
Human
Health
Risk
Rl
R3
RIO
Low
Low
Low
Work groups in all three Regions modeled
groundwater pathway from landfills and surface
impoundments. Incinerator risks appear small
also.
Ecological
Risk
Rl
R3
RIO
Medium
Low
Low
Rl: Higher ranking due to impacts on freshwater
wetlands and propensity for locating municipal
landfills near them.
Welfare
Risk
R3
Low
R3: About $15 million in annual damages to treat water
supplies and losses in value of groundwater for future use.
Notes; Rl indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10.
-------
Table 2: Summary of Findings for Major Problem Areas
Rankings by Region
Risk
Problem Area Region Ranking General Comments Specific Regional Comments
Releases from
Storage Tanks
Human
Health
Risk
R1
R3
RIO
Medium/low
Low
Low
Rankings based on analyses showing large
number of leaking tanks, but low human
exposure means low risks.
Rl: Included all storage tanks.
R3: Included all underground storage tanks.
RIO: Included storage units.
Ecological
Risk
R1
R3
RIO
Medium
Medium
Low
Rl: Believed damage limited due to location of tanks in
disturbed areas and limited transport of contaminants.
R3: Cited leaking tanks and damage to terrestrial and
aquatic settings.
RIO: Few examples of adverse impacts.
Welfare
Risk
R3
Medium/low
R3: About $40 million in annual damages. This
problem area is largest contributor to welfare
damages via groundwater.
Accidental Releases
Human
Health
Risk
Rl
R3
RIO
Medium/low
Unranked
Medium/low
R3: Included accidental releases with routine releases
in all other problem areas.
Rl, RIO: Used historical data on deaths and injuries,
scaled up to account for under-reporting.
Ecological
Risk
Rl
R3
RIO
High
Unranked
Medium
Regions 1 and 10 concerned with effects of
oil spills on the marine environment.
Rl: Concern over potential oil spills, and oil drilling
near Georges Bank.
RIO: Believed oil spill effects are reversible over time.
Welfare
Risk
R3
Unranked
Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10.
-------
jl. %**¦/ a1w irfi %h?M* Jfc. JJH.\i# 11 iUi 1>1" JLC4J VJ1 JL A VJ U1WXU. Jk W^0>0
Rankings by Region
Risk
Problem Area Region Ranking General Comments Specific Regional Comments
Pesticide Residues
on Food
Human
Health
Risk
R1
R3
RIO
Medium
High
High
AH Regions agree that cancer risks to general
population from food residue are high, but
database is conservative.
Risks to farmers and applicators are high on
individual basis, but less significant population
risks. Some difference in definitions.
Rl: Ranked pesticide residues at medium/high and
ranked pesticide application at medium/low.
R3.R10: Ranked both residue and supplication
together.
Ecological
Risk
R1
R3
RIO
Medium
Unranked
High
Regions 1 and 10 concerned about large volume
of pesticides used and effect on non-target
species and ecosystems.
Welfare
Risk
R3
Unranked
u>
Physical Modification
of Land or Water
Human
Health
Risk
Rl
R3
RIO
Unranked
Low
Unranked
Activities covered include second home
construction, mining, etc.
R3; Incidence of several diseases requiring animal
vectors, e.g., rabies, may increase.
Ecological
Rl
High
Impacts are widespread and can range up to
Risk
R3
High
devastating and irreversible.
RIO
High
Welfare
Risk
R3
Low
R3: Net welfare effect of physical modification is positive.
Notes: R1 indicates Region 1, R3 indicates Region 3, and RIO indicates Region 10,
-------
Differences Across Regions
One of OPPE's major reasons for supporting these Regional projects is the
opportunity they present for learning more about Regional variation in risks. Do different
Regions tend to rank the environmental problems in the same order? Will the problems
that are high risk in one Region be high risk in another Region? Ultimately, we are
interested in gaining information about which EPA programs and priorities should be
nationally uniform and whieh should vary geographically.
(assuming five risk steps in all: high, medium/high, medium, medium/low, and low).
Of the thirty-eight problem area/risk type combinations that all three Regions
ranked, twenty-five are ranked similarly and thirteen are ranked disparately. Although
differences in definitions sometimes reflect real differences in the nature of an
environmental problem across Regions, it appears that nine of the thirteen disparate
rankings are more likely due to definitional or methodological differences than to
substantial real differences in risk between Regions. The four instances where major
differences between Regions are based on risk are:
o Criteria air pollutants for human health effects. Ozone risks are higher in
The Regions
ranked
problems
similarly, but
there are
important
differences.
The major conclusion is that there is a great deal of
consistency in how the three Regions ranked the same problems.
The three Regions agree far more often than they disagree.
In Table 3, we display the areas for which the Regional
rankings are disparate. Our definition of a disparity is when two
Regions ranked a problem differently by at least two risk steps
Region 1 than in the other Regions. About two-thirds of Region 1 counties
52
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Risk Regional Ranking
Problem
Type
1
3
10
Explanation
Criteria Air Pollutants
HH
H
M
M
Real Differences in ozone risks.
Air Toxics
HH
M
L
H
RIO includes particulates less than 10 microns in their definition.
M^jor uncertainty about total universe of air toxics realtive to 20 or so
modelled. No real evidence of difference in risks.
Acid Deposition
Eco
H
M/H
M
Real differences in risk.
Radiation
HH
L
M/H
L
Definitional. R3 includes natural background radiation.
Radiation
Eco
L
M
L
Definitional. R3 considered potential accidents. Other Regions
focused on typical damages.
Industrial Point Sources
HH
M/H
M/L
L
Real differences in risk. Also partially definitional, as R1
includes sediment releases.
Industrial Point Sources
Eco
H
M
M/H
May be real differences in risk. Also partially definitional. Also due
to less discriminating nature of R1 eco rankings (more of their problem
areas ranked as high risk than other Regions).
POTWs
Eco
H
M
M/H
May be real differences in risk. Also partially definitional. Also due
to less discriminating nature of R1 eco rankings (more of their problem
areas ranked as high risk than other Regions).
Notes: HH means Human Health Risk, Eco means Ecological Risk, H means high risk, M means medium risk, L means low risk.
R1 means Region 1, R3 means Region 3 and RIO means Region 10.
-------
Table 3: Problem Areas With Variations in Ranks by Region
Risk Regional Ranking
Problem
Type
1
3
10
Explanation
Nonpoint Sources
HH
M
M/H
M/L
Probably real differences in risk. Contaminated fish
problems worse in more industrialized, populated areas.
Other Groundwater
Eco
M
L
NA
Definitional. R3 put groundwater impacts to surface water
in non-point sources.
Non-Hazardous Waste
Eco
M
L
L
May be real differences in risk. More likely due to different
ranking methods.
Storage tanks
Eco
M
M
L
May be real differences in risk. More likely due to different ranking methods.
Accidental Releases
Eco
H
NA
M
Definitional. R1 considered potential accidents, RIO focused
on historical record.
Notes:
HH means Human Health Risk, Eco means Ecological Risk, H means high risk, M means medium risk, L means low risk.
R1 means Region 1, R3 means Region 3 and RIO means Region 10.
-------
are classified as non-attainment for ozone compared to less than half for
Region 3 and only a few for Region 10.
Acid deposition for ecological effects. The rankings put acid deposition as
high risk in Region 1, medium/high in Region 3, but Region 10 only
attributing medium risk to it. Region 1 has highly acid rainfall, and more
than 100 acidified large lakes, with 700 threatened and over 2000 classified
as sensitive. Acid deposition is suspected to be a major contributor to forest
decline in northern New England. Region 3 has even more acidic rainfall,
but its acidified lakes are in limited geographic areas and there is no
evidence of acid deposition contributing to forest decline. Region 10 has
much less acidic rainfall, and thorough studies demonstrate little or no
current adverse impact on lakes there.
Industrial point sources for human health effects. Region 1 ranked this
problem as medium/high risk, Region 3 as medium/low, and Region 10 as
low. There is some definitional difference that may account for the different
rankings between Regions 1 and 3, but there are probably real risk
differences between these two Regions and Region 10. Regions 1 and 3 are
more heavily industrialized, with higher population densities and higher
reliance on surface water supplies for drinking (72% and 77%, respectively)
than Region 10 (54% reliance on surface water).
Nonpoint sources for human health effects. Region 3 ranked this as
medium/high risk, Region 1 as medium risk, and Region 10 as medium/low
risk. Again, the more development, denser populations, and reliance on
surface water in Regions 1 and 3 should make nonpoint sources a higher
risk than in Region 10. The long history of industrial development along
waterways in the eastern Regions has contributed to numerous instances of
badly contaminated bottom sediments, releases from which are generally
55
-------
defined as a nonpoint source problem. The number of acres where shellfish
harvesting is prohibited (often due to bacteriological contamination from
nonpoint sources) is far higher in Regions 1 and 3 than in Region 10.
Does this mean there are only rare differences in risk rankings across the Regions,
and that a nationwide ordering of risks would be duplicated fairly closely in any individual
Region? Not necessarily. A first caution is that we have looked at only three of the ten
EPA Regions, which provides us with limited data. And we have looked at only the
relative ranking of residual risks, not some absolute measure of total risk. Despite these
caveats, what does our three-Region sample say about geographic uniformity of risk
rankings?
There is a strong general consistency to the findings across Regions. In a later
section of this chapter we underscore this point by finding a strong similarity between
the Regional rankings and the national rankings from Unfinished Business.
But some differences in risk have emerged: at least four substantial ones and
probably many more subtle ones that we have not discussed. The Regions and the
problem areas over which these rankings have been conducted are large aggregations of
disparate elements of risk. If we were to rank finer elements, we Would likely find more
extensive evidence of geographic differences in risk. Two examples:
o All three Regions encompass diverse land uses. Each has major cities,
industrial areas, agricultural areas, forest lands, etc.. If we were ranking
problems in more homogeneously defined geographic areas, we would
undoubtedly see large distinctions in risk rankings. A ranking of
environmental risks in an agricultural state, e.g., South Dakota, would be
much different than one for an urbanized state, e.g., Rhode Island. The
results from the four ongoing state Comparative Risk Projects will give us
more data on this issue.
56
-------
o Risk rankings would begin to diverge if the problem areas were more
narrowly defined. While nonpoint sources may cause similarly high
ecological risks in Regions 3 and 10, the rankings would differ if the
component portions of nonpoint sources were ranked individually. Nonpoint
source effects from silviculture would rank very high in Region 10, but less
so in Region 3. The reverse would be true for nonpoint source effects from
mining, very high in Region 3, but less so in Region 10.
Our conclusion is that a relative risk ranking of environmental
problems, when conducted at a broad level (across EPA Regions,
and across an environmental pie sliced into about 20 pieces), will
show little geographic variation. What is true for one Region will
be generally true for another. There may be an innate level of
riskiness associated with each environmental problem that does not
vary much between broad geographical areas. But there are
differences when geographical areas or the problem areas themselves are defined more
narrowly. Some of these are due to differences in natural features, types of industry, or
land use patterns, some are due to combinations of factors that lead to geographical "hot
spots." Even where the level of risk appears to be similar between Regions, the causes
of that risk may differ — the pollutants involved in one Region may be more hazardous,
while in another Region more people may be exposed. Thus it may be appropriate to
have the solutions customized to address the local situation. There is validity in setting
national priorities based on risk, but risk management priorities might still differ for good
reasons. As the ranking or priority-setting becomes more precise, focusing on smaller
geographic areas or smaller pieces of problem areas, geographic distinctions become much
more important.
Even where
rankings are
similar, the
causes of risk-
and thus the
best solutions-
may differ.
51
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Project Results Compared with Results from Unfinished Business
The Regional Comparative Risk Projects built on the process and methodologies
of Headquarters' Unfinished Business project. The lists of problem areas and the
methods were similar to those used in Unfinished Business. Comparing the results is
straightforward, with two exceptions: the Regional projects used slightly different
definitions for some problem areas than did Unfinished Business, and Unfinished Business
did not combine their separate rankings for cancer and non-cancer health effects.
The results of the projects are very similar. All rated radon,
indoor air pollution and pesticides as the highest health risks.
Unfinished Business also ranked worker exposures and exposures
to consumer products as causing very high health risks, but the
Regional projects did not consider these problem areas. Drinking
water contamination ranked quite high in health risks for both the
National and Regional studies.
At the low end of the health risk ranking, both National and Regional projects
listed USTs, non-hazardous waste, RCRA sites, and, somewhat higher, CERCLA sites.
This is due to the limited population exposures typically associated with groundwater
contaminated from these sources. Groundwater pollution tends to be slow-moving and
localized, and can usually be avoided at modest cost by obtaining alternate or treated
water supplies. The health risk to an exposed individual may be as high from
contaminated groundwater as from polluted air or surface water, but there typically will
be far fewer people exposed. The health ranking methods used in both the Regional
projects and Unfinished Business tended to weight population risk far more than they did
individual risk.
A few health risk rankings differed between the Regional projects and Unfinished
Business.
The rankings
are similar to
those from
Unfinished
Business, with
some
differences.
58
-------
o Unfinished Business rated accidental releases as higher risk than did the
Regions. We believe the Regions' rankings may be more appropriate, as
they used a new historical data base on injuries and deaths from accidental
releases that was unavailable at the time of Unfinished Business.
o The Regions ranked industrial point source and nonpoint source discharges
both as somewhat higher risk than did Unfinished Business. This was
because the Regions obtained data on toxic chemicals in edible fish tissue,
and performed several modeling analyses to project human doses via fish
consumption and drinking water. Unfinished Business used professional
judgment with little data. The Regions' analyses used conservative
assumptions, and may thus have overstated risks.
o Unfinished Business ranked air toxics as causing substantially higher health
risks than did the Regions. Unfinished Business and the three Regions drew
quite different conclusions regarding this issue, disagreeing on the extent to
which the twenty analyzed air toxics represented the entire universe, and the
extent to which air toxics caused non-cancer effects.
The ecological rankings were also quite similar across the studies. Physical
modification, nonpoint sources and pesticides were ranked as high risk. Unfinished
Business ranked global warming and ozone depletion as even higher risk, but the Regional
projects did not rank these problems. All the studies found other radiation, RCRA sites,
USTs, CERCLA sites, solid waste disposal and other groundwater contamination to
present the lowest ecological risks. Several differences in the ecological rankings included:
o Unfinished Business found point sources (both industrial and POTW) to
present similar high risks as nonpoint sources. The Regions made a
distinction, ranking nonpoint sources clearly higher. The Regions used data
59
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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:
60
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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 Region 3 ranked four problem areas (Indoor Air Pollution, Indoor Radon,
Pesticide Contamination, and Radiation Other Than Radon) as causing
relatively high welfare risks on the basis of damages consisting almost
exclusively of costs entailed by the health effects associated with these
problems. The Unfinished Business welfare work group defined welfare risks
to exclude health care costs, believing that such damages are only monetized
reflections of health risks, and that the health risks and any manifestations
of them should be counted only in the ranking by the health work groups.
Unfinished Business thus ranked these four problem areas as causing very
low welfare risks. If the Unfinished Business assessment had included the
health-related welfare damages from these problem areas, its ranking would
align closely with Region 3's.
o The other problem areas ranked high by Unfinished Business that were
also studied by Region 3 were discharges from POTWs and from industrial
point sources. If Region 3's welfare rankings were adjusted to exclude
health care costs, Region 3 agrees that the welfare damages from these two
problem areas are relatively high.
o Although both Region 3 and Unfinished Business agreed that the welfare
damages from CERCLA sites, RCRA sites, solid waste management, UST
61
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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
larger, but still small. By contrast, two of the low residual risk
problem areas — RCRA and CERCLA sites ~ are the subject of major Regional
programs. UST is the subject of moderate Regional programs. Resources devoted to
solid waste and to radiation other than radon, like their risks, are small.
The rankings
contrast sharply
with the level
of EPA
resources
devoted to the
problems.
62
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PROBLEMS THAT WERE RANKED CONSISTENTLY BY ALL THREE REGIONS
High Health Risks
Indoor radon
Indoor air pollution other
than radon
Pesticides (primarily residues
on food)
Drinking water contamination
High Ecological Risks
Physical modification of
habitats
Nonpoint source discharges
to surface waters
Low Health Risks
Underground storage tanks
Active hazardous waste (RCRA)
sites
Low Ecological Risks
Active hazardous waste(RCRA) sites
Non-hazardous (solid) waste sites
Radiation other than radon
Abandoned hazardous waste (CERCLA) Underground storage tanks
Non-hazardous (solid) waste sites
Looking at the ranking results within media, rather than across media, we found
divergences between risk and EPA's current program effort:
o In the air program, more resources are devoted to criteria pollutants and
air toxics than to indoor air and radon.
o In the water quality area, nonpoint sources and habitat modification cause
the greatest problems. Yet the bulk of program resources are devoted to
municipal and industrial point sources, with some resources devoted to
wetland protection.
o In the waste programs area, CERCLA, RCRA and to a lesser degree UST
receive the most attention. Yet accidental releases and other sources of
groundwater contamination seem to pose equal or larger risks.
63
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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.
Why is there a substantial mismatch between the level of risk
that a problem poses and the level of attention it gets from EPA?
The answers at the Regional level are the same as at the national
level. First, resource levels tend to be more closely aligned with
how serious environmental problems have been perceived to be in
the past, rather than the risks they pose now. EPA's priorities
throughout the organization are determined far more by public
opinion and its embodiment in statutes than by risk. Despite our findings that the relative
risks associated with hazardous waste sites are low; the public clearly fears them and
wants them cleaned up. They also want hazardous wastes managed safely, so that more
dangerous sites are not created. For various reasons, indoor air pollution, radon and
pesticide residues (until very recently) have not aroused the public consciousness.
Public opinion often does not correlate well with risks as estimated by technical
experts. This is because risk estimation is complex. Evaluation and comparison of the
risks caused by different environmental problems is complex even for professionals, as
is clear from the time and effort put into these projects. There may also be a
fundamental difference in perspective between individual citizens and a government
agency. Citizens tend to take a more personal view in evaluating risks, while a
government agency must take a more societal view, often coping with problems that
affect large numbers of people. The public considers qualitative aspects of risks, e.g.,
"is it voluntary?", that are not factored into our rankings.
A second reason for the mismatch between risk and resources is controllability.
Resources line
up with past
risks and public
opinion more
than current
residual risk.
64
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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.
Of course, some problem areas have low residual risk because
effective control programs are in place that have reduced high
risks to acceptable levels. The rankings produced thus far are
based upon risk alone, and priorities for action or budget resources
must depend on many more factors that we have not considered
yet: public opinion, statutory mandates, cost, and controllability.
Some problems
have low
residual risk
because of
effective
' control
programs.
We should
continue to
study the
mismatch
between risk
and resources.
We nevertheless believe that the mismatch between risk and
resources is cause for concern and additional study. EPA's
business should be to obtain real results for our program efforts -
- to work on the most serious environmental problems facing the
Nation and to reduce real risks.
Level of Confidence in Ranking Results
Participants are
confident of
their results.
As noted earlier, the results of the Regional Comparative Risk
Projects should be viewed more as informed professional judgment
than as scientific risk assessment. The data used was very limited,
and some of the methods were novel, imperfect, and judgmental.
Despite these limitations, the participants are comfortable with
their relative rankings of the problem areas.
When work group participants were asked whether they would recommend redoing
65
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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 in the projects have noted a number of areas
where their conclusions are particularly uncertain, and where
additional data and or analysis would improve the rankings. The
problem areas for which rankings are uncertain are not necessarily
the areas for which the available data are most limited or of
poorest quality. In several cases, the work groups identified
problem areas for which data was poor but a ranking could
nevertheless be assigned confidently. For others, better quality data was available but the
problem still could not be ranked confidently because of the absence of a single key piece
of information.
Many of these perceived gaps in data and analysis are similar to those mentioned
by the Unfinished Business participants.
In conclusion, the participants in these projects recognize the imperfections in
what they have done, but believe that the rankings of the problem areas reflect their
relative risks reasonably accurately, and they believe the knowledge gained about the
risks associated with different problem areas was definitely worth the effort.
Project participants did believe that it would be very worthwhile to update the
data and knowledge base and to re-analyze and re-rank the problem areas on a periodic
basis, perhaps every four or five years, to revise risk-based priorities in light of new
information and especially to identify emerging environmental problems.
The
participants
noted where
additional data
or analysis
would improve
the rankings.
66
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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
o Exposure data on indoor air pollutants,
o Health effects of airborne sulfates.
o Actual exposures to contaminants at and around waste disposal sites,
o Exposure data for damage pathways from waste sites other than groundwater,
o Actual (rather than modeled) data on pesticide residues on foods as consumed,
o Information on the total universe of toxic air pollutants in addition to the best-
studied pollutants. ' . ~
. o Data on the specific sources of the contaminants found in fish or drinking water
from surface waters.
o In addition, the work groups expressed substantial methodological uncertainty about
how,to assess non-cancer;risks and,how to aggregate cancer and non-cancer risks.
Ecological Risks
o Non-urban data on criteria air pollutant ambient concentrations.
' o Terrestrial effects of acid deposition,
o Ecological effects data and studies for air toxics.
o Survey of ecological damages from waste sites (CERCLA, RCRA and non-
hazardous).
o Data on the extent of discharge of contaminated groundwater to surface water,
o In addition, all three ecological work groups expressed great uncertainty about their
ecological comparative risk assessment methods and recommended that further efforts
•be made to develop a more systematic approach.
Welfare Risks
o Methods for valuing the aesthetic damages from pollution,
o'Methods for valuing the loss of unused but clean groundwater,
o Critical review of studies on welfare losses due to acid deposition,
o Methods for evaluating welfare losses from physical modification of habitats,
o 'The Region 3 work group also expressed a general regret at the small number of
studies monetizing welfare damages in most areas.
67
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B. Project Benefits
The Regional Comparative Risk Projects have allowed the
The best result participants to carefully and systematically evaluate and to rank the
will be to
improve the environmental problems facing their Regions using available data
way EPA and informed judgment. Although not perfect, the projects are the
allocates
resources. most rigorous and objective comparisons of the seriousness of
these environmental problems to date. The participants have
expressed confidence in their risk rankings. Both the management
of the participating Regions and the coordinators of the projects at Headquarters are
pleased with the progress thus far. But the ultimate test of these projects is their utility
in setting priorities. Will they improve the way the Agency allocates its resources?
The implementation phase of the projects — where we will develop, evaluate and
execute ways of reducing the risks we have analyzed - is now beginning. We are
preparing to use the project results in three processes:
o In the Regions' negotiations with National Program Managers. At separate
stages in the annual budget and management cycle, the Regions discuss with
National Program Managers what they believe the Agency's budget request should
be and then, after EPA receives its appropriation, they discuss what work will be
accomplished with the appropriated funds.
o In allocating the Regions' own discretionary resources. Subsequent to agreement
with National Program Managers on work to be accomplished, some amount of
resources will remain to be spent at the Regions' discretion.
o In dealing with the states. The Regions will negotiate directly with each state
what it will accomplish with Federal grant funds. In addition, the Regions can
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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.
In the meantime, the projects have already provided several
other procedural benefits:
1. A better understanding of Regional environmental problems
and potential new directions for the Regional Administrator,
Deputy, and other Regional managers. The comprehensive
purview of the Comparative Risk Projects gives these
managers a good information base for planning.
2. An understanding for the Regions of the relative risks of the environmental
problems facing them, and of the "anatomy" of risk for each problem. The
Regions now have better knowledge of which pollutants, pathways, source types or
geographic areas ("hot spots") contribute the bulk of the risk in each problem
area. This more detailed understanding will make it much easier for the Regions
to design initiatives targeted efficiently at the portions of problems that cause
particularly high risks.
3. An enhanced role for the Regions in national decision-making. In decisions
made at EPA Headquarters, whether on resource allocation, regulatory or
program policy issues, the Regions' role has traditionally been limited to some
degree because of their lack of analytical backup for their positions. The Regions
have offered opinions and arguments, but seldom supporting analyses. The
EPA has
reaped a
number of
benefits
already.
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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.
mrnrn^ jn chapter, we look toward the participation of additional
Future projects Regions and states in the comparative risk process, and discuss
can learn from
the current some lessons we learned during the first set of projects.
ones.
^ Possible Resource Savings
Given the substantial resources needed to conduct a Comparative Risk Project
(see box on page 27), it is important for OPPE to evaluate where savings of time, staff
or money might be made. Here are some lessons.
o Work group size could be reduced, but only marginally since the expertise,
broad office representation, and checks and balances of the work group
process are critical to project success.
o Contractor support probably cannot be reduced much because work groups
cannot easily substitute for the risk assessment expertise and the consistent
treatment of problem areas that contractors provide. There was also a
considerable cost savings when a contractor prepared POAs or analysis
similarly for two or three Regions.
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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.
A comparative risk analysis will require substantial resources
from any Region or state that undertakes one. However, a project
sponsor should realize that such an investment will pay dividends
for many years. Once the initial investment is made, it would cost
little in future years to keep a Region or state informed about
risks and opportunities to reduce them. The staff would be
trained and knowledgeable about comparative risk and the data
base created would require less effort to update or improve than to generate initially.
' B. Issues Involving Project Design
Several aspects of project design differed across the three participating Regions.
In this section, we pose questions about alternative approaches and offer some answers.
Should projects analyze all national and global problems? The Regions did not
analyze some problems that were not likely to be addressed at the Regional level, e.g.,
global warming, ozone depletion, worker exposure to chemicals. While the Regions
Projects require
substantial
resources, but
benefit EPA
and states for
many years.
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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 l's
approach seems to have the advantage of providing a broad risk management analysis
of all the problem areas, suggesting which might provide the most fertile ground for
developing risk reduction initiatives. On the other hand, the Region 10 approach provides
a full analysis of individual initiatives, not broad problem areas, thereby moving faster to
selecting and implementing new projects as a result of the first year's comparative risk
work.
Whom to assign to work groups? For the project to work best, the work group
members should be among the better professional staff in the Region, who know their
programs well, and ideally have some experience and perspective across other programs
in addition to their current program. It is very important that each work group include
at least one member reasonably familiar with each problem area, someone who
understands how it causes risk, what data exists, and how that might be analyzed. It is
also useful for the work group to have several individuals who are experts in the type of
risk being analyzed. It is difficult for a work group to rely solely on contractors or OPPE
personnel for direction on how to establish its risk assessment methodology. It is
preferable if the work group itself has some expertise and can be led from within.
There has been some variation in approaches to work group membership. Region
10 included a state representative on each work group. Participation by these individuals
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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.
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VL Next Steps
In this chapter, we provide a brief discussion of the next steps for the Comparative
Risk Projects.
A- Implementing the Analytical Findings in the Regions
The real test of the success of the Comparative Risk Projects is their utility in
setting priorities. Most of the future work will come in translating the analytical findings
about comparative risks of environmental problems into improved decisions about
allocating resources to deal with them. Some background work has already been done
in Regions 1 and 10. Their risk management work groups have begun the process of
deciding which areas can be most effectively handled by the Region with specific
initiatives.
The three Regions plan generally similar activities for the second year of their
projects:
Developing initiatives. Each Region will develop a process
Regions will for generating and then analyzing initiatives for dealing with the
analyze ideas
to reduce risks. environmental problems. Each Region intends to ask to its
employees (and perhaps also states and the general public) to
suggest initiatives to reduce risks. They will encourage initiatives
targeted at the highest risk areas, but all initiatives will be welcomed. Those submitted
will be analyzed by the relevant program divisions in the Region, and perhaps by the
work groups to assess the likely risk reductions, cost and feasibility. The Region will
choose the best initiatives to implement.
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Evaluating allocation of resources. Initiatives will be
The Regions considered for whatever incremental funding becomes available to
will seek shifts
of resources to the Region. In addition, each Region will develop a process for
high-risk areas. evaluating resource shifts within its base programs, typically from
lower-risk problem areas to higher-risk ones. (Cost-effective shifts
may certainly be found within a single program area, possibly from a higher risk problem
area to a lower risk one.) The potential shifts will be evaluated like the initiatives. We
expect that resource shifts within the next year or two will be limited to those remaining
within the boundaries of a single media program. Cross-media shifts or shifts across
major EPA offices are too difficult to achieve institutionally at present.
Integrating the comparative risk process into existing program management and
accountability systems. Each Region has somewhat different processes for making
resource allocation decisions. Each will decide how to work in the comparative risk
process. The Regions will decide whether comparative risk will be an annual process,
an annual update, done every couple of years, or not done again. Region 3 intends to
use the comparative risk results and work groups to assist with its MERITS process,
used to allocate a pool of discretionary Regional resources derived from a lapse pool
and a small draw on the Regional programs. Region 10 intends to develop a similar
process for managing its lapse pool. Region 1 is considering adapting the Comparative
Risk Project to serve as the general strategic planning process for the Region.
Using the comparative risk results to participate more
Regions plan effectively in Headquarters priority-setting. Armed with the
to influence
Headquarters' comparative risk analyses, the three Regions intend to play a more
priorities. active role in discussions with Headquarters about both Regional
ancj national priorities. Regional presentations will be developed
for budget discussions with national program offices and for the spring Agency budget
planning meeting. The three Regions have used their comparative risk analyses to
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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.
Expanding and improving weak spots in the analysis. The
Regions 1 and Regional work groups have indicated the level of confidence with
10 will analyze
welfare risks. which they ranked each problem area. Each Regional project
^plans to further investigate problems which were ranked with little
confidence. In many cases the lack of confidence is due to the fact
that important information about the problem simply does not exist, in which case
research may be recommended. In other cases, the information may actually exist but the
work group did not have the time or money to acquire it. Each Region will improve the
data, analyses and risk assessments used in the first year of the projects for selected
problem areas where further work could alter the ranking of the problems. Regions 1
and 10 will also conduct some limited welfare risk analysis for their problem areas based
on the previous work of Unfinished Business and the Region 3 project.
Increasing State involvement. Each of the three Regions is now working with one
of their states on a State Comparative Risk Project (Pennsylvania, Vermont, Washington).
The Regions plan several additional activities to encourage more states to participate in
projects. Briefings will be given to state staff on project findings. Discussions will be held
with states on initiatives or resource shifts for high risk areas.
Risk Communication. Each Region will produce a document for public distribution
summarizing the project findings. A communications strategy will include presentations
on process and results to staff and management within the Region, in other parts of the
Agency, and to the public.
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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
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
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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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VII Conclusions
Each of these Regions devoted considerable effort to defining, gathering data,
analyzing, and ranking a comprehensive list of environmental problems. The risk analysis
framework integrated data and professional judgement in a consistent manner to allow
comparison and priority-setting among problems based on the human health, ecological,
and for Region 3, welfare risks they pose. The slight differences in methods used by the
three projects allowed us to learn about the relative strengths and weaknesses of different
methods.
The ranking results show that the relative seriousness of most problem areas is
fairly consistent across the three Regional projects and Unfinished Business. There are
important differences, however. Some are due to different definitions of problem areas
used, but most are due to differing conditions across the Regions. Regions also found
that even where the relative seriousness of problem areas is the same, the underlying
causes of risk may be different in different Regions. These findings support the idea that
EPA should consider risk management strategies that are customized to local conditions
for most effective environmental management.
The product of these projects is not just the rankings. The
analysis on each problem area that supports the rankings provides
insight about underlying causes of risk and often indicates what the
most effective solutions to these problems may be. These risk-
based solutions, when considered against risk management factors,
lead to an effective, feasible, and cost efficient strategy for
addressing environmental problems.
Risk analysis
provides
rankings and
insight to the
causes of risk,
indicating the
best solutions.
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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:
1-1. Criteria Air Pollutants
This problem arises when the concentration of a criteria air pollutant exceeds the ambient
standards required under the Clean Air Act to protect human health and welfare. The
criteria air pollutants are sulfur dioxide, total suspended particulates, carbon monoxide,
nitrogen oxides, ozone, and lead. Major sources of these pollutants are mobile sources-
-motor vehicles, and stationary sources—industrial, commercial, and residential fuel burning.
1-2. Acid Deposition and Visibility
This topic includes both wet and dry acid deposition. Acid deposition effects include
terrestrial impacts (e.g., forests, crops, soil), ecological impacts (e.g., streams, lakes),
potential drinking water impacts, and possible welfare impacts (e.g., building materials
and monuments). Visibility will also be considered. Visibility impacts are primarily the
result of long-range transport of sulfates, a key component of acid deposition.
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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.
t
1-7. Industrial Point Source Discharges To Surface Waters
"Point sources" are sources of pollution that discharge effluents into surface waters
through discrete conveyances such as pipes or outfalls. Discharges may result in
contamination of fish and subsequent exposure of humans. Point sources have been
divided for this project into industrial (this category) and POTW sources (#8). Pollutants
of concern include total suspended solids, BOD, toxic organics (phthalates and phenols),
toxic inorganics, such as metals, and thermal pollution. Typical sources of discharge
include coal and ore mining, metal finishing, pulp and paper processing, and iron and
steel production. Such facilities discharge to surface waters under NPDES permitting;
facilities discharging to surface waters are required to have such a permit. Substantial
double-counting with #10—Estuaries, Coastal Waters, and Oceans.
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1-8. POTW Discharges To Surface Waters
Hie discharges from municipal sewage treatment systems (POTWs), including industrial
"indirect dischargers" connected to POTWs, often travel to surface water. Discharges may
result in contamination of fish and subsequent exposure of humans. Combined sewer
overflows (CSOs) are included here also. The pollutants are similar to those in #7 but
POTWs are also a major source of ammonia, chlorination products, and nutrients.
Double-counting is possible with all categories relating to surface water (#'s 7, 9, 10, 11).
1-9. Nonpoint Source Discharges To Surface Waters
Pollutants that reach surface waters from sources other than discrete conveyances for
effluents, as in #7 and #8, are nonpoint pollutants. This includes runoff from
agricultural, urban, industrial, silvicultural, or even undisturbed land (including pesticides)-
-particularly construction and logging sites and areas of hydromodification, surface
discharge of ground water, releases from contaminated in-place sediments, and air
pollutants that settle into the water. Discharges may result in contamination of fish and
subsequent exposure of humans. Possible pollutants vary a great deal, though they include
most point source pollutants mentioned in #7 and #8. Storm water carries a large
amount of solids, nutrients, and even toxics. Double-counting may occur with the air
pollutant categories where deposition is included and with discharges to surface water
categories.
1-10. Discharges To Estuaries, Coastal Waters, and Oceans Form All Sources
This problem area includes a wide variety of pollutants and sources that reach such
waters and may result in contamination of seafood and subsequent exposure of humans.
Specific sources can include ocean dumping of wastes, air deposition of criteria and
A-4
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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).
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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,
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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
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exposure. There may be double-counting with Drinking Water (#12), Indoor Air (#5),
and Hazardous Air Pollutants (#3).
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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.
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Indoor Air All indoor exposures to air Occupational exposure
Pollutants pollutants for example:
Other Than Radon Asbestos, Formaldehyde,
Tobacco, CO, NOX,
pesticides.
Radiation Other
Than Indoor Radon
Naturally occurring,
manufacturing, radioactive
waste disposal, indoor
radiation other than
radon, non-ionized
activities (microwaves, high
tension lines, etc.).
Medical x-rays, CERCLA
sites, cosmic rays exposure
in aircraft, exposure from
ozone depletion,
occupational exposure,
nuclear power plant
accidents.
Impacts of
Industrial Point
Source Direct
Discharge of
Wastewater on
Surface Waters and
Air
Pollutants in wastewater
generated by all privately-
owned sources that are
directly discharged to
surface waters (including
wetlands) through discrete
conveyances or volatilized
to air.
Discharges to or from
publically-owned treatment
facilities, treatment
sludges, groundwater
impacts from wastewater
treatment, and physical
impacts from discharges of
dredge and fill material.
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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
Hazardous Waste at
RCRA Facilities
All discharges to air, soil,
surface water and
groundwater from active
and closed RCRA
facilities, waste
transportation, and illegal
disposal/lack of capacity.
Discharges to wastewater
treatment plants and
criteria air pollutants.
3-10. Hazardous
Substances at
CERCLA Sites
NPL sites and potential
NPL sites. Illegal
disposal/lack of capacity.
Discharges to wastewater
treatment plants and
criteria air pollutants.
3-11. Solid Waste
Management
Multi-media discharges to
air, soil, surface water and
groundwater from all
household, municipal, and
industrial waste not
regulated by RCRA as a
hazardous waste,
treatment sludges,
transportation, and illegal
disposal/lack of capacity.
Discharges to wastewater
treatment plants and
criteria air pollutants.
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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 Residues on and in food Surface water runoff,
Contamination and applicator exposure. 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
sensitive terrestrial habitats
such as: dam building,
strip mining, highway
construction.
Chemical impacts from
disposal of dredge and fill
materials.
3-17. Acid Deposition
All damages caused by
wet or dry deposition of
acidic compounds from
the atmosphere.
Primary impacts of sulfur
oxides, NOX, and VOCs.
3-18. Operation and
Maintenance of
Water Supply
Facilities
All water treatment
facilities and distribution
networks.
Contamination in the raw
water.
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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 S02 and NOz - a wide variety of industrial, commercial
and residential fuel combustion sources.
2 Note: In ranking this problem, the Human Health Work Team decided to exclude
the effects of PM10, including it instead under hazardous/toxic air pollutants.
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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
f
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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.
20-11. 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
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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), Hazardous/Toxic Air Pollutants (#3), and discharges to
surface water (#*s 7, 8, 9).
10-14. Hazardous Waste Sites - Abandoned (Superfund)
This category includes hazardous waste disposal/contamination sites that are not covered
by RCRA, but by Superfund. Generally, they are inactive and abandoned. They can
include sites on the National Priorities List (NPL), those deleted from the NPL, those that
are candidates for the NPL, any additional sites that states may be addressing, and any
other abandoned sites. As with active hazardous waste sites, these sites may contaminate
ground and surface water, threaten nearby residents with direct exposure to toxic
chemicals, and pollute the air, through direct discharges to water sources and air, soil
migration, and runoff. Pollutants may include TCE, lead, toluene, chromium, PCBs and
numerous other hazardous chemicals, some in unidentified quantities and mixtures. There
may be some double-counting of the risks from this problem with those from Drinking
Water (#11 and #12), Hazardous Air Pollutants (#3), and discharges to surface water
(#s 7, 8, 9).
10-15. Non-Hazardous Waste Sites - Municipal and Industrial
Includes two major types of waste sites - municipal and industrial - containing primarily
non-hazardous wastes.
The municipal waste site universe consists primarily of 16,000 open and closed municipal
landfills, municipal sludge and refuse incinerators, and municipal surface impoundments.
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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 chloroflururcarbons (CFCs) and nitrogen dioxide from industrial
processes and solid waste sites could significantly reduce the ozone layer.
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10-23. C02 and Global Warming
Atmospheric concentrations of carbon dioxide (C02) are projected to increase over the
next century due to an increase in fossil fuel combustion and a decrease in tropical
forests. Higher levels of C02 may raise climatic temperatures globally, raising the sea
level.
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Appendix B. Combining Different Types of Risk.
Although we are not covering the results of the Pennsylvania State Comparative
Risk project in this report, it is worth noting that the Steering Committee for this project
did combine the separate risk rankings from the work groups. A key to doing so was
asking the work groups to provide rankings that were cardinal as well as ordinal. With
the cardinal rankings, the Pennsylvania Steering Committee had quantitative information
available on the degree to which a high-ranked problem area was more risky than a low-
ranked problem for a single type of risk. Pennsylvania combined their three separate
health, ecological and welfare rankings by:
1. Deciding that each variety of risk was equally important
2. Normalizing each separate risk ranking by giving the highest ranking problem
a score of 100, and giving the other problems a normalized score equal to
the percentage that their raw risk score is relative to the raw risk score of
the highest ranking problem.
3. Adding the normalized scores for the three types of risk for each problem
in order to obtain an aggregate score. The aggregate risk ranking was based
on this aggregate score.
This process gave Pennsylvania a satisfactory final ranking of their environmental problems
based on all three types of risk.
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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 - Comprehensive Environmental Response, Compensation, and Liability
Act
DDT
Dichloro-diphenyl-trichloroethane
DRA
Deputy Regional Administrator
EDB
Ethylene dibromide
EPA
Environmental Protection Agency
MERITS
Measurable environmental results initiatives
NPL
National Priorities List
OMSE
Office of Management Systems and Evaluation
OPA
Office of Policy Analysis
OPPE
Office of Policy, Planning and Evaluation
PCB
Polychlorinated biphenyl
POA
Plan of attack
POTW
Publicly Owned Treatment Works
RA
Regional Administrator
RCRA
Resource Conservation and Recovery Act
SPMS
Strategic Planning and Management System
THM
Trihalome thane
UST
Underground storage tank
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Appendix E. Supplementary Reading
National Comparative Risk Project
U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Office
of Policy Analysis. Unfinished Business: A Comparative Assessment of Environmental
Problems. Volume I. Overview. February, 1987. (Available from National Technical
Information Service, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Order
number PB88127048, $21.95.)
U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Office
of Policy Analysis. Unfinished Business: A Comparative Assessment of Environmental
Problems. Appendix I. Report of the Cancer Risk Work Group. February, 1987.
(Available from National Technical Information Service, 5285 Port Royal Road,
Springfield, VA 22161, (703) 487-4650. Order number PB88127055, $28.95.)
U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Office
of Policy Analysis. Unfinished Business: A Comparative Assessment of Environmental
Problems. Appendix II. Non-Cancer Risk Work Group. February, 1987. (Available
from National Technical Information Service, 5285 Port Royal Road, Springfield, VA
22161, (703) 487-4650. Order number PB88127063, $15.90.)
U.S. Environmental Protection Agency, Office of Policy, Planning and Evaluation, Office
of Policy Analysis. Unfinished Business: A Comparative Assessment of Environmental
Problems. Appendix III. Ecological Risk Work Group. February, 1987. (Available from
National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161,
(703) 487-4650. Order number PB88127071, $36.95.)
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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
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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
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Region 3
Robert Allen
Randy Pomponio
Sheila Briggs
Ron Preston
Henry Brubaker
Robert Reed
Maryann Bucknavage
Charles Rhodes
Jeffrey Burke *
Robert Runowski
Jon Capacasa
Charles Sapp
Gail Caron
Roland Schrecongost
Robin Cole
Dianne Sims
Barbara D'Angelo
Roy Smith
Joe Davis
Bruce Smith
Bruce Diamond
Henry Sokolowski
Richard Fetzer *
Rebecca Taggart
Alyce Fritz
Lawrence Teller
James Harper
Jean Thompson
Kim Hummel
Virginia Thompson
Greene Jones
James Topsale
Robert Kramer
Michael Vaccaro
Stanley Laskowski
Janet Viniski
Denis Lohman
Randy Waite
Paula Luborsky
Stephen Wassersug
Thomas Maslany
Carey Widman
Andy McErlean
Patricia Wilbur *
Tony Meadows
William Wisniewski
Israel Milner
Sidney Worthington
Bruce Molholt
Denis Zielinski
Alvin Morris
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Region 10
John Armstrong
Dave Kircher
John Barich
Amy Kyle
Dick Bauer
Ron Lee
Paul Boys
Jerry Leitch
Ken Brooks
Bub Loiselle
Robert Burd
Lee Marshall
Bob Coughlin
Nora McGee
Robert Courson
Lynn McKee
Dana Davoli
Phillip Miller
Mike Downs
Dede Montgomery
Bruce Duncan
Bill Mullen
A1 Ewing
Chris Noah-Nichols
Chuck Findley
Lane Nothman
Clark Gaulding
Gary O'Neal
Michael Gearheard
Bill Ross *
Wayne Grotheer
Chuck Shenk
Julie Hagensen
Bill Sobolewski
Gil Haselberger
Elaine Somers
Jan Hastings
Pat Storm
Mark Hooper
Dave Tetta
Duane Kama
Kathy Veit
Dru Keenan
Mike Watson
Greg Kellogg
Leigh Woodruff
Bob Kievit
John Yearsley
* Current and former project managers
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