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III. THE MARJOL SUPERFUND SITE

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Introduction

       The next section of the course deals with a public meeting held in July 1988 on the
progress of clean-up activities at a Superfund site in Pennsylvania. The site is at the Maijol Battery
Plant where, for many years, lead batteries had been split open (and the lead re-processed) and the
broken casings - with some lead remaining - had been dumped into a landfill. As a result of
activity at the plant and soil dispersion from the dump site, many homes near the site have elevated
levels of lead in their soil. The high lead poses a special risk to children, who come in greater
contact with the exposed soil through their play and who are more susceptible to risks posed by
elevated lead levels.

       The high lead levels at the site have been known since the late 1970's and recently EPA has
begun remedial action. The meeting was the second one held in the area since January 1988. The
site was not on the Superfund's National Priority List (NPL) at this time and was being handled by
the on-scene coordinator (OSC).
              Video  Segment  -  Marjol Superfund Site
       The first segment of the Marjol tape is from a televised "town meeting" held in September.
This brief segment of tape gives some background on the situation at the site. As you watch the
first piece of tape, keep in mind what "outrage factors" would be driving the citizens of the
community. Since the problem has been going on for some time, there is likely to be mistrust
between the community and the EPA and state Agencies involved in the clean-up activity. Also,
the higher risk posed to children will increase outrage associated with the question of fairness.

       The second part of this segment shows the Superfund OSC addressing the audience. The
meeting occurred in July 1988 when it was very warm, and began with a long rather technical
discussion before the site coordinator began. As you watch the tape keep the following questions
in mind:
Risk Communication Workshop                                                   Marjol-1

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             Discussion  Questions -  Marjol Superfund  Site
      The EPA Regional Administrator had, on the advice of the on-scene coordinator, recently
      sent a letter to the residents which included some inaccuracies concerning earlier blood
      levels of lead in the area. This has lead to a great deal of consternation among the citizens
      and town leaders. How does the OSC handle this matter and respond to concerns raised by
      the letter?
  2.  What were the EPA representative's expectations and goals for the meeting? Were they
      reasonable?
  3.  What is your reaction to his declaration that he wants to allay the citizens' concerns?  Is this
      effective?
   4.  Is the EPA representative effective when he notes that he has only seen one other site, at
      which there turned out to be a real health risk, and now this site may make two?
   5.  What is your reaction to his relationship with the audience?  Referring back to the Ladder of
      Citizen Participation, how is he dealing with the public?
Risk Communication Workshop                                                   Marjol- 2

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             Video Segment  -  Marjol  Superfund Site
      The next tape shows a heated discussion between the OSC and a woman in the audience.
The woman is clearly upset about the fact that her children had high blood lead levels in the late
1970's, and she feels that not enough was done about it. One of her children has a learning
disability and it is clear that in her mind the lead is responsible. Clearly, she is angry and wants to
vent some of her aggression at those officials she feels are responsible. She starts in by saying that
the EPA and state officials, because they are educated, would never live in the area while the
remediation work is being done.

      Her first question is straight forward and hard hitting - "why should we believe you now?"
             Discussion  Questions - Marjol Superfund  Site
   1.  Ignoring the specifics of this case, consider how you would respond. What do you say to
      someone who flat out says he/she doesn't believe what you're saying?
   2. What is driving this woman's outrage?  Knowing that, how would you change your
      response to her question?
             Video Segment - Marjol Superfund  Site
      The next and final segment of tape shows a continuation of the woman's questioning of the
OSC. Are you man enough, she challenges him, to tell us the truth? As you watch his response,
keep the questions on the following pages in mind.
Risk Communication Workshop
Marjol-3

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             Discussion Questions  - Marjol Superfund  Site
  1.  Did the site coordinator adequately address the woman's concerns? Could he have, given
      the confrontational manner of her questioning?                              •« - '••••   -
  2.  What guidelines can you develop to help you deal with situations in which you find
      yourself in confrontation with the audience?
  3.  What did the citizens (or at least those that we saw on the clips) hope to accomplish? How
      did this compare with what the EPA rep was trying to accomplish?
  4.  What is your reaction to the OSC's body language? The room arrangement?
Risk Communication Workshop                                                Manpl- 4

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   5.  What should you do when your expectations of what should occur differ from the public's?
      What can you do prior to the meeting to decrease the possibility that this will take place?
      What can you do at the meeting? How could you find out the public's expectations?
What are some of the key lessons that can be gained from the Marjol tapes?
   »  Plan carefully and be aware that what you say will be filtered through the public's
      own perceptions
   •  Know your audience and try to address their expectations
   •  Be sure to tailor your own agenda and objectives to meet the public's
   •  Be aware of your body language and the messages it sends
   •  Listen carefully to the audience! Tailor your responses to meet their concern
   •  If your objectives for the meeting are not the same as the audience's - do all you
      can (even to the point of changing the nature of the meeting) to meet the public's
      needs.  In the long-run, you will have to  address their concerns in order to get to
      yours.

             Additional  Readings in Resource Section  •
             Marjol Superfund  Site
      The Lethal Legacy of Lead Poisoning
      Public Meeting Check List
      Public meeting - Typical Questions  and Sample Responses
Risk Communication Workshop                                                  Marjol- 5

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                 Perception of  Information Sources*
                        Amount  Rec'd    Trust  '  Knowledgeable
                           \ A Lot       % A Lot   	% Verv
News  Reporters               27           27          17


Environmental
Groups                        21           40          53


Friend/Relatives              7           34           9


L£PC                           6           28 /         33


State Government              6           12        *  29
People  You Know
Who Work for a._ .
Chemical Industry             5           19          30
Local  Government              5           11          22
Federal  Government            4           12           36
                                       t

Chemical. Industry
Officials                     3            8           53
Doctors                        3          46           27

u«ms3aaaaaaa««aava««3aassasaas3M*«s«a*««SM»MMS3«a3aa3a3a
*   Comparisons of trends  only;  no significance tests conducted.



   from Public Knowledge and Perceptions of Chemical Riaka In Six Communities:
         Analysis of A Baseline Survey       EPA 230-01-90-074 January 1990

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IV. DEALING WITH THE MEDIA/ HANDLING TOUGH
               QUESTIONS

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Introduction

      During this section of the course, we will discuss the role of the media in risk
communication efforts and will also review some ways to handle "tough" questions, whether you
get them during a media interview, at a public meeting, or at another forum.

      Our efforts here are obviously not meant to substitute for the other types of training
available on how the Agency expects its personnel to deal with the media.  Still, there are some
lessons that can be easily reviewed concerning the way that you use the media to communicate
your Agency's messages, and the way that media uses you.

      You should remember that the need to meet the needs of the media is one of the seven
cardinal rules (#6). Among the guidelines stressed for this rule are the following:

   •  Respect reporters' deadlines

   •  Provide information tailored to the needs of each type of media and include your
      messages

   •  Follow up on stories with criticism or praise

   •  . Try to establish long-term relationships with reporters

   •  Define your message and repeat it
              Video  Segment -  Dealing with  the  Media
       "The next video clip is of a presentation given by a San Francisco reporter (Tom Vacor) at a
Risk Communication conference in 1986. Do you agree with his key points? How could the
Agency do a better job with the media?

       A copy of his speech is included in the resource section.
Risk Communication Workshop                                      Dealing with the Media-1

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     o
     >r*    Discussion Questions -  Dealing  with the
             Media
   1.  Is the media (print or television) your ally or your adversary in trying to communicate with
      the public?
   2.  How well/poorly does your office use the media? How can you use the media to
      communicate with the public and advance your goals?  Can EPA do what the public interest
      groups do in working with the media?
             Handling  Tough  Questions
      When faced wi»b fv1^ questions (during an interview, on the telephone, or at a public
meeting), it's often helpful to try to determine the type of question that is being asked in order to
avoid traps or pitfalls that may be awaiting you. It is also essential to prepare your key messages
which represent the Agency's viewpoint. These messages should be included in each of your
answers. You shouldn't spend too much time thinking about the kind of question - you do after all
have to answer it  However, it might be helpful if you could identify what "underlies" the
question. This is an example of "ACTIVE LISTENING", looking beyond the specifics of the
question to identify the underlying theme/objective of the questioner.

      In its course on Risk Communication and Public Involvement, EPA's  Region IX provides
a list of 8 situations in which you might find yourself and some suggested responses. These
"solutions" should not be taken dogmatically but rather as suggestions.
Risk Communication Workshop                                     Dealing with the Media- 2

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             Discussion  Questions -  EDB  Role  Play
      The potential interview questions noted below should help you get started in preparing for
the interview.
   1.  How can you justify allowing the continued use of this material when it can have the drastic
      effects that we saw in the video clip?
   2.  What other problem chemicals haven't you told us about?
   3.  Were you protecting the public when you failed to announce publicly that you found this
      chemical in flour destined for the school lunch program? Why didn't you warn parents so
      that they could tell their children something very simple - like don't eat the bread.
   4.  How much EDB is safe?
Risk Communication Workshop                                     Dealing with the Media- 8

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             Video Segment  -  News  Broadcast  on EDB
      Watch the following clip from a news broadcast on the problem EDB might pose. As you
watch, you should assume that you are the official spokesman for EPA on pesticide issues and that
you will be interviewed by the person who put together this newscast.


The Mock Interview

      After the clip is over, you will split up into small groups. In your groups you will prepare
both questions and answers for an interview between the reporter who put together that piece and
the EPA chief of the Special Review Branch. When we get back together, each group will ask
questions of the others.

      Consider that this broadcast aired in December 1983, so that the Agency has moved to
suspend the use of the chemical on soil but has yet to act on its use as a grain fumigant. Keep the
following list of items in mind in order to assist in your preparation for die interview:

   •  What will be your objectives in the interview?

   •  What is your strategy for achieving these objectives?

   *  What facts are critical?

   •  Who is your audience?

   •  What message(s) do you want to convey?

   •  How will you evaluate how well you have done?

      Be sure to identify what you want to accomplish during the interview. Think of two to
three key points and be sure to emphasize them whenever appropriate.  These are your key
messages.
Risk Communication Workshop                                      Dealing with the Media- 7

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   EDB Background

   •  Ethylene DiBromide (EDB) is now classified as a B2 probable human carcinogen.  It is an
      insecticide and fungicide that was used as a furnigant in soils, on grain and on citrus from
      the mid 1950's through 1984. It was an effective and widely used chemical on much of the
      nation's grain. The silos it was stored in were also treated with EDB

   •  No tolerance was set for EDB since when it was first registered it was presumed that there
      was no residue left on the fruit or grain by EDB application

   •  In the late 1970's, the EPA was aware that residues of EDB were being found on
      grain products and the chemical was also being found in ground-water systems

   •  On 9/30/83, EPA announced  an emergency suspension of soil uses of EDB, thereby
      halting approximately 90% of the use of EDB nationwide

   •  In October, 1983, the Agency prepared a cancellation order for use of the chemical on
      citrus, but it was appealed by users

   •  In December  1983, Florida, after finding residues of EDB in grain products in
      supermarkets, set a statewide tolerance of one part per billion (1 ppb) and started removing
      products with levels above the tolerance from the shelves

   •  A number of other states also set limits: Massachusetts (10 ppb), California (300 ppb)

   •  Under FIFRA, the Administrator could announce an emergency suspension of EDB that
      would have stopped all use of the chemical. However, in order to take this step, the
      administrator  would have to make a determination that during the time the chemical was
      being reviewed, it would pose an unacceptable imminent hazard

   *  A separate determination would have to be made as to how to handle the existing food
      supply that had been treated

   •  In late 1983, EPA was not convinced that the data supported a cancellation of the use of the
      chemical on grain, although the Agency had cancelled the soil use to eliminate ground water
      contamination.

   •  In late 1983, the Agency requested information from die states and other sources with
      regard to the establishment of a tolerance level for EDB.  The Agency could only issue a
      guidance because of an exemption from tolerance that had been given EDB in 1956 when it
      was believed  that the pesticide left no residue.

   •  In February, 1984, Administrator Ruckelshaus announced a ban on all use of EDB on
      grain and that a decision GU ciuus would be forthcoming. With regard to treated grain he
      established three different guidance levels:

           for raw grain (900 ppb)

           for uncooked products (ISO ppb)

           for ready to eat products (30 ppb)
Risk Communication Workshop                                       Dealing with the Media- 6

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  8.  "No comment." "No comment" is not the same as "I don't know," "No comment" can
      be stated a number of ways. If you do not know the answer to a question, state that you do
      not know the answer.


      Example: "We have heard that ABC Industries, a large employer in the area, may be
               required to perform extensive corrective action to keep this facility in
               operation."


      Solution:  If the answer is "no comment," it can be done smoothly. For example, "EPA
               has not yet made a decision about the extent of corrective action that will be
               required.  We will be sure to inform you as soon as we have reached a
               decision."
             Video Segment -  Handling  Tough  Questions
      The following clips show examples of people being asked and then addressing "tough
questions." The first comes from a meeting held to inform citizens and answer questions about the
AS ARCO smelter which we'll be discussing in more detail tomorrow. The second clip comes
from a Superfund meeting at a site on Long Island. As you view the clips, think of how well the
respondents did.
             Role  Play - TV Interview on  Ethylene
             DiBromide

   For the following small role play exercise, we will be looking at a case involving a pesticide,
ethylene dibrpmide - or EDB. The purpose of the exercise is to gain some experience in dealing
with the media and handling tough questions. In addition, it's intended to illustrate the importance
of planning for an interview and dealing with it in accordance with the seven cardinal rales. For
preparation, review the brief background piece on EDB that follows on the next page of this
section.
Risk Communication Workshop
Dealing with the Media- 5

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  4.  The empty chair situation. In this situation, the interviewer quotes an opponent or
      person with a different point of view who has criticized your view, but is not present.


      Example:   "Dr. Ralph Smith has said that this facility is a serious health hazard."
                 Or, "Congressman X says EPA's handling of the permit application has been
                 inadequate."


      Solution:   You can respond simply "I have not heard those remarks," or "I believe the
                 facts will show..." You should make sure NOT to attack an opponent who is
                 not present  Be willing to review the information and then comment on it


  5.  The broadside attack.  This is the "ad hominen" argument, in which you are attacked
      directly.


      Example:   "You are deliberately withholding information aren't you?"


      Solution:   The best advice is to deny it straight out, if it is not true, or to be candid if there
                 is some truth in it: "We only withhold information that we consider confidential
                 and which may adversely affect the drafting of a permit for a facility." - You
                 should also point out the ways (meetings, fact sheets, etc.) that you are
                 attempting to get information out


  6.  The hypothetical situation.  This technique involves the interviewer asking a
      hypothetical question - a "what if' question.


      Example:   "What if contamination is discovered in the ground water below the facility?
                 Will EPA deny the permit application?"


      Solution:   The best advice is to point out that "we can't speculate on what we might do
                 until all the facts are in." However, you should also note what you're doing  to
                 ensure that you're gathering all the information.


  7.  Inconsistency. If you or your organization has changed opinions or policies over time,
      you might be asked about that change.


      Example:   "When the facility's permit application was called in, EPA said it would notify
                 the community of any deficiencies in the application. But you found
                 deficiencies and did not tell us."


      Solution:   You should clearly explain the reasons for the change, whether it was due to  a
                 change in policy or circumstance. For example, "Our intentions remain to keep
                 the community well-informed as the permit is developed. But the deficiencies
                 we have found so far in the permit application are administrative and minor."
Risk Communication Workshop                                       Dealing with the Media- 4

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  1.  The "set-up." A long preamble precedes a question, sometimes loaded with
      misinformation or a "when did you stop beating your wife" question.


      Example:  "Considering the low regard that residents have for EPA, how do you, as part
                of EPA's team developing a permit for the ABC Industries facility, expect
                people to believe you are not selling out to ABC Industries?"


      Solution:  One solution is to break in politely to challenge the premise. (Do not nod your
                head when the question is being asked - viewers will think you agree with what
                is being said.)  The second approach is to wait until the question is finished,
                then go back and knock down the preface: "Yes it may be true that some people
                are suspicious of EPA's negotiations with private companies, but in fact, the
                permit conditions for the ABC Industries facility requires extensive corrective
                action." Or simply, "What you've said just isn't true. Let's look at the facts."
                You may also want to concede that there may be cause for people to question
                what you were doing before, but that they should look carefully at what you're
                doing now.


  2.  The "either...or" situation.  The interviewer poses two unacceptable alternatives.


      Example:  "Either you are misinformed,  or you are protecting someone..." Another
                example: "Now were those irresponsible statements due to incorrect information
                or were they part of a deliberate attempt to mislead the public?"


      Solution:  One solution is to answer the question directly: "Neither. The real issue here
                is..." and move on to the points you want to make. Or you can just ignore the
                trap and respond the way you want


  3.  Irrelevancy. In this situation, you are called upon to answer a question in an area
      unrelated to your area of expertise. Asa result, you may be quoted out of context.


      Example:  "Ms. Jones, as the EPA regional permit writer for the U-Dump landfill, what do
                you think EPA should include in the permit conditions for the Brown Industries
                storage facility?"


      Solution:  You might simply remark that it is not your area of expertise, then launch into
                some information regarding EPA's actions at the U-Dump landfill. - You may
                also want to direct them to someone who knows more about the area they're
                questioning.
Risk Communication Workshop
Dealing with the Media- 3

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   What  to do when you disagree with the  Agency
   position

      Now let's look at a different question. How do you believe that one should respond when
he/she disagrees with the Agency position they have to defend? Some at EPA were caught in this
situation when they believed the Agency should be taking bolder action.

      In "Improving Dialogue with Communities": A Short Guide for Government Risk
Communication", (See Resource Document) Caron Chess, Billie Jo Hance and Peter Sandman
note that: "If your personal position does not agree with agency policy, do not mislead the
community. Instead, try modifying the agency position or having the task reassigned. Or find a
way of acknowledging the lack of consensus within the agency.  Misrepresenting the situation or
dodging questions about your position will obviously reduce your and the agency's credibility."

      Do you agree? Can this be done?
             Video Segment  - McNeil-Lehrer  Interview
      As you watch the next clip, which shows Paul Lapsley of the pesticides office at EPA
being interviewed on McNeil-Lehrer after the Ruckelshaus press conference, keep the following in
mind:

   •  Did he do a good job? Why? How does he do with regard to the Seven Cardinal
      Rules?

   •  Was he prepared? What were his key points or messages?

   •  Did he meet the concerns of the public?

      In the attached resource document you have a short piece written by Paul Lapsley which
describes his views on how to prepare for an interview.
             Video Segment  • Ruckelshaus Final Word on
             EDB
Risk Communication Workshop                                   Dealing with the Media- 9

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          Additional  Readings in Resource Section-
          Dealing with the Media / Handling Tough
          Questions
  •  Preparing for the Interview by Paul Lapsley
  •  Presentation by Tom Vacor on the Role of the Media in Risk
     Communication
  •  Do's and Don'ts for Spokespersons
  •  Telling Reporters About Risk
Risk Communication Workshop                             Dealing with the Media-10

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V.  EXPLAINING TECHNICAL ISSUES

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Introduction

       One of the more important problems facing the risk communicator is trying to explain
highly technical problems to the public. This is still what many people think defines risk
communication - "can you tell me how to explain 1 in a million better or how to explain a risk
estimate of 4 per million?" This is obviously very important - you have to be able to give people
information they need in a way they can use. However, as we have seen, it is not all there is to
risk communication.  The goal of risk  communication is to provide the individuals
with  information in a manner that  is meaningful to them!

       When explaining technical matters to the public, it is very important that you fashion the
presentation to ensure that it meets the needs of your audience, and not just your needs. Often the
public expects an answer to the question, "Is it safe?"

Uncertainty and Timing
                                                *
       Associated with the issue of explaining technical issues are two related issues - deciding
how to address scientific uncertainties when communicating scientific results to the public and
deciding when to release information to the public.

    Uncertainty
    As discussed earlier, the risk assessment process yields uncertain results. The use of animal
data, the models used to estimate dose-response and exposure figures, all raise questions about
how "hard" the results are.  Uncertainties and questions about data and conclusions reached about
them characterize almost all risk decision-making efforts.

    At a Risk Communication Conference in 1986, Frank Press of the National  Academy of
Sciences discussed the ubiquitous nature of uncertainty in science, saying "It is  important to
understand that uncertainties are not unique to matters of risk. They are really what drives all of
science. If there were certainty, there would be no science."

    As a communicator, you have to acknowledge these uncertainties and explain what you are
doing to try to limit them. Recognize that others will reach different conclusions, looking at the
same  information, and the public will often be receiving conflicting views of the same  information.

    Think, for example, of the situation the Agency faced with regard to alar, a chemical used on
apples. Environmental groups were using the same data as EPA, but reaching different
conclusions.

    You must be willing (and able) to discuss the procedures used to develop information, where
uncertainties lie in the process and the efforts underway to resolve them. The Agency does not
have the only answer to a problem, but you have to have a defensible one. You should be
prepared to discuss how you've reached your conclusions, the differing conclusions that others
have reached, and why  you think yours is right

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   Remember - There wiU always be uncertainty.  As one county official told researchers from
Rutgers University, "Environmental epidemiology makes economics look like an exact science."

   For more information on uncertainty refer to a memorandum from EPA Deputy Administrator,
F. Henry Habicht II, on "Guidance for Risk Characterization for Risk Managers and Risk
Assessors" in the resource document.
   Timing
   One of the easiest ways to lose trust and credibility with an audience is to withhold, or be
perceived as withholding, information. Remember the EDB tape? One of the strongest
indictments made about EPA was the implication that the Agency knew about problems but wasn't
acting on them, or informing others. Whether it is true or not, being perceived as withholding
information is obviously very damaging to your credibility.

   If you want people involved in the process (no matter where they are on the Ladder of Citizen
Participation) then you have to give them information in a timely manner, in a way that is
meaningful to them.  You want to get the best information out to the public as quickly as possible.
Decisions on when to release information, how to do so, and who should receive it, should all be
part of a risk communication plan. We will discuss the importance of these plans, and what they
should include, in the next chapter.

   There will obviously be circumstances when you can't release information, whether for legal
reasons or concerns you have about its accuracy. Note there is a difference between recognizing
uncertainties about your data and questioning the data's accuracy. Release what you can and let
people know why you can't provide other data and when you might be able to.  Keeping the public
informed will enhance their feeling of control and, as we discussed earlier, lower the "outrage"
they may be feeling.

   Please refer to the Resource Document for a list of Ten Reasons to Release Information Early,
developed at Rutgers.
              Discussion  Questions  -  Explaining Technical
              Risk
    1.  What do you think are the biggest problems you'll face in explaining a technical issue (such
       as a risk assessment) to the public? How can you plan to overcome them?
    2.  How can you explain that the risk estimates the Agency assigns to various chemicals or to
       an overall site (as in Superfund) generally exaggerate the potential risk. How does this
       over estimate of the potential risk affect policy?
Risk Communication Workshop                                 Explaining Technical Issues -2

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       What are some general guidelines that should be used in communicating technical matters to
       the public? What advice would you give to a colleague about preparing a presentation for
       an intelligent, but not scientifically trained public. After we develop a list together
       in class, you'll receive a handout  on general guidelines to  follow in
       presenting technical  information.
                   Risk Comparisons
       A well-thought comparison can be an effective tool for helping put risks into perspective
and help an audience better understand technical information. However, you should be warned
that it is very difficult to come up with a comparison that can really work.

       In general, it is important that you carefully think through any comparison that you want to
use and that whenever possible pre-test it (e.g., through informal interviews or focus groups).
There are no absolute rules or guarantees about what is or is not an effective comparison. You
must be as diligent in discerning the appropriateness and accuracy of a proposed comparison as in
providing any sort of technical information. Be especially cognizant of your audience and their
concerns and only use a comparison that addresses those concerns adequately!

       In trying to determine the appropriateness of a comparison, try to see it through the
perspective of your audience. Will this help them better understand the situation at hand?
Remember, that should be the goal of the comparison - to help your audience understand the
situation and participate in making the decision.

       No risk comparison will be successful if it appears to be trying to settle the acceptability
question since "acceptability" is a value question, not a technical one. Your job is to help the
public reach its own decision on the "acceptability" of the situation. You can try to help put data
into perspective - it is then up to the recipient to decide how he/she wants to use that information.

       Be careful:  An inappropriate comparison, which the audience finds "off the wall" or
patronizing or otherwise wrong can turn the audience off so they will not hear your message.

       Two articles in the resource document, entitled "What Do We Know About Making Risk
Comparisons?" and "What Should We Know About Making Risk Comparison?" discuss whether
the use of certain types of comparisons are more effective than others.
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             Discussion  Questions -  Risk Comparison
   1.  What makes a comparison work for you?
   2.  What effective examples do you have of comparison? Ineffective?
             Video Segment  - ICE Minus
      The next segment of tape shows small portions of a press conference at which Jack Moore,
EPA's Assistant Administrator for Pesticides and Toxic Substances at the time, is discussing the
Agency's decision to permit on-field testing of a genetically altered bacteria (ICE minus) that will
inhibit the freezing of strawberries. In addition, Steven Lindow, the lead scientist on the ICE
Minus experiment is seen explaining the nature of the experiment to the public.

      Consider the following questions when viewing the tapes:
      What did you think of Mr. Moore's presentation, especially with regard to the seven
      cardinal rules?
Risk Communication Workshop                               Explaining Technical issues -4

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      What is your reaction to Mr. Lindow's assertion that "no deliberate introduction" of a
      species has led to problems? Do you agree? Did you find the statement helpful or
      distracting?
      Did you like his "comparison of the genetic change to the bacteria to removing one piano
      key?" What about his graphics? What is your reaction to his statement that you should,
      have faith in the scientists?
             Video  Segment - State of California
             Epidemiologist

      In this next tape, a California doctor, Lynn Goldman, is shown talking to a group of
individuals at a meeting concerning possible contamination of drinking water from industrial
pollution. As you watch, consider whether she is an effective speaker. Why or why not?

   •  How does she do with regard to the seven cardinal rules? With regard to the list we've
      developed as guidelines for explaining technical risks?

   •  How does she say, "It's safe?"
             Additional Readings in Resource  Section -
             Explaining  Technical  Issues
   •  What Do  We Know About Making Risk Comparisons?

   •  What Should We Know About Making Risk Comparison?

   *  Explaining Environmental Risk:   Some Notes on Environmental Risk
Risk Communication Workshop                              Explaining Technical Issues -5

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 GENERAL GUIDELINEB FOR COMMUNICATING TECHNICAL ISSUES

1.   Don't underestimate the ability of the public
     to assimilate technical information.
     Remember—if you give people a reason to
     learn (a stake in the decision)  they can do
     so.

2.   Find out what risk information people want
     and in what form.

3.   Anticipate and respond to people's concerns
     about their personal risk.

4.   Take care to give adequate background when
     explaining risk numbers.  Use language that
     is as down to earth as possible.

5.   Provide information that helps respond to
     their concerns and which is neither too
     complex or patronizing.

6.   Put data in perspective and try to express
     the risk in different ways.

7.   Explain the process, i.e., the Agency's risk
     assessment procedure by which the numbers
     were derived.

8.   Use graphics to help make your points.

9.   Collaborate with other credible experts.

10.  Use language consistent with the expertise of
     your audience and avoid the temptation to
     lapse into jargon.

11.  Take care when comparing environmental risk
     to other risks.

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VI. PLANNING FOR RISK COMMUNICATION

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Introduction  -  Why do you  need a risk communications plan?

       In order to provide the public with the opportunity to participate meaningfully in
agency decision-making, the public must be involved early in the process (see cardinal rule
#1).  This will not happen  on its own, but the Agency must plan for and actively seek this
participation.

       It is important to recognize that an effective communication program is an analytical
one, requiring the identification of goals and objectives, activities to reach those goals,
ways to evaluate the degree to which the goals have been met, and mechanisms to allow for
changes resulting from the evaluations. As we saw in the MARJOL case, communications
cannot be simply left to the last minute. Rather, the Agency must recognize that the
communications strategy is critical to the success of the risk management process.  In the
absence of effective planning and preparation, communications problems such as those
seen in the MARJOL meeting can undermine all the good work that the Agency is doing at
a site or in developing a rule.

       The need for effective communication planning has broader implications than the
preparation for and assessment of a particular communication event such as a public
meeting or a media interview.  That is certainly important, but we are referring to a view of
communication planning that is part of the whole decision-making process. Obviously
planning is necessary to ensure the effectiveness of specific events (like a public meeting),
but it is also critical in a broader sense to help the Agency, other government entities, and
other interested parties work together to reach the best possible management decision.

       In its brochure on the Seven Cardinal Rules for Risk Communication, EPA offers
the following guidelines to meet the second Rule: to Plan Carefully and Evaluate Your
Efforts. Begin with clear, explicit risk communication objectives - such as building
relationships, providing information to the public, motivating individuals to act, stimulating
response to emergencies, or contributing to the resolution of conflict Evaluate the
information you have about the risks and know its strengths and weaknesses. Classify and
segment the various groups in your audience. Aim your communications at specific
subgroups in your audience. Recruit spokespeople who are good at presentation and
interaction. Train your staff - including technical staff - in communication skills; reward
outstanding performance.  Whenever possible, pretest you messages. Carefully evaluate
your efforts, learn from your mistakes, and seek the  advice of risk communication experts.

       Points  to  consider:

   1.  There is no such entity as "the public"; instead, there are many publics, each with
       its own interest, needs, concerns, priorities, preferences, and organizations.

   2.  Different risk communication goals,  audiences, and media require different risk
       communication strategies.
Risk Communication Workshop                               Planning for Risk Communication-1

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What constitutes  an effective plan?

       The following list will serve as the starting point for group discussion on
developing a communications strategy. It comes from work done at Rutgers University
and discussed in Planning Dialogue with Communities: A Communication Workbook.
which is included in its entirety in the resource section.

       Determine your goals - depending on  the situation

       Be clear on what you hope to accomplish

       How do we define success?

       Identify  your audiences and their  specific concerns

       It is important to identify all those who may be interested in your activity or who
       can provide you with information: set priorities among the groups, establishing a
       core group that will be directly involved and others that will not be so directly
      .involved.

       Design your messages to meet those concerns

       Think of satisfying the audiences needs - not only yours.

       Choose the best methods to reach  people

       For some groups, informal meetings are best  Be sure you know how you intend
       to reach people.  What are the biggest roadblocks?

       In order to ensure you reach people who might not usually be involved, you should
       cast as wide a net as possible.  This is important to ensure equity.

       Too often agencies choose the methods they want to use first, before they've
       identified the audience they want to reach.

       Coordinate internally

       Practice the same risk communication principles on others in your agency as with
       the public.

       Plan  for evaluation

     -  How to build in procedures to evaluate how you're doing and make changes based
       on the results of the evaluation.
Risk Communication Workshop                              Planning for Risk Communication-;

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              Evaluation
       As we have pointed out, evaluating how your communications plan is going and
making changes in your plan to help meet its goals and objectives is an integral component
in a risk communication strategy.

       This type of evaluation, identifying the degree to which the communication
activities are successful in reaching goals and objectives, is referred to as an outcome
evaluation. Evaluation techniques can also be used in the beginning stages or during plan
development, to pre-test materials to see if they are appropriate for  the targeted audience,
and during the implementation of the plan to see how the planned activities are proceeding.
These types of evaluations are referred to as formative and process respectively.

       The type of evaluation used at any given stage in the plan development and
implementation will depend to a great extent on the time and resources available. For
example, in the pre-test or formative stage, techniques can range from readability tests that
evaluate the clarity of a particular article to the use of focus groups, which can be used both
to test the applicability of materials and presentations and to learn more about audience
perceptions, beliefs, and needs. The formative evaluation should help determine the
clarity, comprehensibility and completeness of the materials.

       The table on the following page, adopted from "A Guide to Practical Evaluations,"
an EPA document prepared by Michael J. Regan and Williams Desvousges of the Research
Triangle Institute, shows some of the techniques that can be used for formative, process, or
outcome evaluations.

       It's not important that you memorize the technical names for these different
evaluation techniques, but it is important that you are aware of the  kinds of evaluation
options that are available so you can decide which best suit your needs.

       For more information on all these types of evaluation, the reader should see "A
Guide to Practical Evaluations", an EPA document prepared by Michael J. Regan and
William H. Desvousges of Research Triangle Institute and also, in the Resource
Document, "Evaluating Risk Communication Programs," by Mark Kline, Caron Chess and
Peter Sandman.
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           Discussion Questions  -  Planning  for  Risk

           Communication

  1.  What evaluation tools have you used in your work? Which have been most
     successful?
  2.  Are there limits on your ability to do more evaluation?
Risk Communication Workshop                         Planning for Risk Communication- 4

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Radon  *  An Example of Effective  Planning  and
             Evaluation
      The Surgeon General warns that radon is the second leading cause of lung cancer in
the U.S. today, behind smoking.  It is estimated that radon causes between 7,000 - 30,000
deaths/year - more than from fires, airplane crashes, or firearms. Approximately six
percent of the homes in the U.S. are estimated to have elevated radon levels. Radon is
radioactive gas formed from the natural decay of uranium found in rock and soil. Radon
enters homes through crzcl:: and other holes in the foundation and can become trapped and
accumulate to high levels. While radon is one of the nation's more serious environmental
health problems, it is also one of the easiest to avoid. It is relatively easy .to determine
radon levels in a home, and elevated levels can be reduced simply and at a cost comparable
to other minor home repairs.

      In 1987, an EPA taskforce of senior managers and technical experts ranked
exposure to indoor radon, along with worker exposure to chemicals, as the highest cancer
risk out of 31 environmental problems examined.  This scientific ranking, however, is in
sharp contrast to public perception. Annual Roper polls consistently find that, in terms of
perceived risk, people rank indoor radon at or near the bottom of 25 environmental
problems. While people are aware of the radon problem, they do not perceive it as a
serious health risk. The attached newspaper article by Diane White of the Boston Globe,
"What a Gas!," provides a humorous look at the public's perception of radon.
              Video Segment  -  The  Radon Problem
       The following video segment is from NBC nightly news and provides some
background on the radon problem.


Radon Risk Communication

       Educating people and encouraging them to change their behavior is a difficult task.
Although public awareness of radon has been raised, about 70 percent of the U.S.
population over 18 years old now say they have heard about radon, public apathy remains a
major obstacle to radon risk reduction.  Only about nine percent of the homes in the U.S.
have been tested for radon. There are several reasons why radon poses difficult risk
communication problems.

       •     There is no physical evidence of radon. You can't see it or smell it.

       •     Radon is primarily an indoor threat and people do not feel threatened in their
             homes.

       •     Radon doesn't cause symptoms. The effects of elevated radon levels are
             only manifest indirectly and over a long period of time.
 Risk Communication Workshop                             Planning lor Risk Communication- 6

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              The public is saturated with information on cancer-causing agents and tend
              to ignore new warnings.

              People tend to be less concerned about risks they can control, such as
              radon, than risks that are imposed by others, such as living next to a
              hazardous waste site.

              People have no one else to blame for the problem. The individual home
              owner must take action to test and remediate a radon problem.
                                      What a  gas!
                                      by Diane  White
                        The Boston  Globe,  September  17, 1988
       Here I sit trying to work myself into a state of alarm about radon.
       Radon is dangerous, I know, even life-threatening. I've read the stories in the newspapers. I've
seen the reports on TV.
       Radon is an invisible, colorless gas that can seep into houses through foundation cracks.
According to one expert, living with a high radon level in your home "should give people as much
concern as living next door to a hazardous waste facility."
       In spite of that, I'm having a problem taking the radon threat seriously. It's the name, Radon. It
sounds like something our of a third-rate science fiction story.
       The giant Ixmyrr raised his fist menacingly. 'Here on the planet Narthex we have ways of dealing
with human scum such as you," he thundered.  "Earthlings, prepare to diet  Open the chamber of no
retuml Release the deadly radon!"
       Couldn't they call it something else?  Radioactive gas.  That's what it is, according to the reports
in the newspaper.  Naturally occurring radioactive gas.
       The possibility that radioactive gas may be seeping into the basement, radioactive gas that may
cause lung cancer, has a galvanizing effect. But radon? Radon in the cellar? Forget it. It's dumb of me, I
know, but there it is, Radon. It sounds like a new fabric.
       Radon. The miracle fabric for all your nuclear winter needs. All natural.  Made in the U.S.A.
       Some words have their own power, quite apart from what they may mean. Consider a headline
that appeared in one paper this week: "Peril Seen From Radon."
       Peril is a word that's difficult to take seriously.  People in peril don't seem to be in real trouble.
But people in danger? That's different.  "Danger Seen From Radioactive Gas." Cause for alarm.  But
"Peril Seen From Radon"? Radon. It sounds like a high-tech company.
       RADON. Where safety is our least important product.
       That story, and others, reported that radon is a carcinogen. There's another word that says less
than it means.  It sounds like something you add to gasoline to make your car engine run more smoothly.
       But "Radioactive gas causes cancer." That has a certain impact. "Radon is a carcinogen." The
words seem to bubble up and float away. Radon.  It sounds like a post-post-punk, prenuclear rock
group.
       Now here's Radon with one from their new album.  "It's A Gas.'
       I called a friend to ask what she's doing to combat the menace of radon.  She laughed. Then
she said she'd had the house tested and the radon level is far too high.
       She has a radon  remover in the living room. There are plans to dig a tunnel under the
foundation of the house to release the radon fumes. She's already spent hundreds of dollars. Her
family's heath is threatened. It's no joke. So why are we laughing? Radon.  The word. It sounds like a
cockroach spray.
       / knew I had a problem the day roaches seized control of my kitchen and presented me with a list
of non-negotiable demands. Then I discovered Radon.
       I have no imagination.  It's obvious.*If I did, t wouldn't have any trouble comprehending that
radon, despite its silly name, is a serious threat. But I cant help it. Radon. It sounds like Japanese movie
monster.
       Far beneath tf?e city, deep in the sewers of New York, it fed on deadly radioactive gas until it was
bigger than Donald Trump's ego!  Radon! You've seen "Radon vs. King Kong," and "Radon vs.
Rambo." Now see "Radon vs. The American Public. * Coming soon to your very own homel
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      In an effort, to overcome these obstacles, EPA and others conducted research on
potential solutions. This research produced the following findings:

      •      While people may disregard information about risks to themselves, they are
             much more likely to respond to information about the potential risks of
             radon to others .in their households.

             Concise prescriptive recommendations are more effective in encouraging
             public action than longer, more general messages.

      •      Radon messages should personalize the risks by comparing radon risks to
             more familiar risks (e.g., x-rays, illnesses, accidents)

     , *      The public will be more likely to respond to streamlined radon testing
             recommendations that do not require a year-long radon test
              Video Segment  - Radon Public  Service
              Announcements
       Using this information, EPA initiated a program to use public service
announcements (PSAs) to reach the public and encourage more testing for and fixing of
radon.  The goal of the program was, again, to increase the level of testing and risk
reduction.

       The PSA campaign was conducted in three segments with evaluation occurring after
each segment. The EPA decided to use an advertising campaign since evidence from
research indicated that radon had become old news and advertising could make a difference
and encourage people to test for radon. In addition to the PSAs, a hotline (I-800-SOS-
RADON) was established to answer questions about radon.  In designing the first wave of
advertising, EPA used research that indicated they should:

       *      relate the risk to others in the household

       •      personalize radon with relevant, tangible comparisons and

       •      use a strong and unsettling message.

       The result was the "X-Ray" PSA.

Campaign Wave I
       As you watch this PSA, think about how-effectively the message is communicated.
How would the public react to the ad? Is the message consistent with the research
findings? Is the PSA memorable? What information is retained?

       EPA did an outcome evaluation to assess the success of the "X-Ray" PSA, and
determined that public awareness of the risk of radon increased by 14%. The analysis of
campaigns designed to get people to take specific actions, like anti-smoking and seatbelt

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use, indicates that PSA campaigns must be in place for several years before large scale
public behavior change will be observed.  In addition, some scientists thought that the X-
ray image was too graphic and disturbing, and EPA was concerned about the lack of
support from these scientists for these ads.

       As a result, a second set of PSAs were developed which have a more humorous
tone. EPA attempted to be just as effective with a lighter approach.

Campaign Wave n
       As you watch these PSAs, think about how effectively the messages are
communicated. How would the public react to the ads? Are the messages consistent with
the research findings? Are the PSAs memorable? What information is retained? How do
these ads compare to the "X-Ray" PSA.

       In an evaluation of the second wave of PSAs, it was found that they were not as
persuasive as the X-Ray PSA. While these PSAs did a better job at describing the ease of
testing, some public health experts believed that they were too light hearted and that the
health problem posed by radon deserves more serious treatment

Campaign Wave Tfl
       The third stage of PSAs was developed that consisted of a more dramatic message,
combined with a lighter "twist"  The idea was to combine the successful elements of the
first 2 waves.

       As you watch this PSA, think about how effectively the message is communicated.
How would the public react to the ad? Are the messages consistent with the research
findings? Is the PSA memorable? What information is retained?  How does this ad
compare to the "X-Ray",  "Bird Lady", and "Mountain Goat" PSAs?


Campaign  Evaluation for All PSAs

       •      In media tests of TV commercials, all of the Radon PSAs ranked in the top
              10% in terms of recall and attention. The Gas Mask actually ranked in the
              top 2% of all ads tested. It is believed that having the viewers read the
              information at the bottom of the screen as well as well as hearing it spoken,
              resulted in greater recall.

       •      People (media outlets) use the PSAs

              The  1 -800-SOS-RADON hotline has received 250,000 calls to date. This is
              more calls than any other EPA hotline. In addition, State Radon offices and
              affiliate organizations like the American Lung Association often place local
              numbers on the PSAs and receive thousands of calls annually.  We also
              know that viewers may. not call, but will ask for a radon test next time they
              buy a home or test their home directly.

       •      16% of hotline callers have had their homes tested for radon.

       •      National surveys estimate that 70% of the population is aware of the radon
              problem and 9% have tested for it Compared to other attempts to change
              behavior (e.g., seat belts and smoking) the radon campaign has been highly
              successful.

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      This case demonstrates the importance of planning, evaluating, and changing your
message (plan) in response to what you learn during the evaluation.  At each step, EPA
conducted research which identified the best way to reach its objective, produced
advertisements, ran them, evaluated the ad, and created a new ad in response to what they
learned. The same approach should be used with any communication program.
            Additional  Readings  in Resource  Section -
            Planning for Risk Communication
   *  Focus Group Techniques
   •  EPA Title 111 Focus Group Results
   •  Focus Groups and Risk Communication:  The Science of
      Listening to Data
   •  Planning Dialogue with Communities:   A Risk Communication
      Workbook
   •  Evaluating Risk  Communication  Programs
   •  Rhetoric  and Reality:   Risk Communication in Government
      Agencies
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VII.  ASARCO CASE STUDY

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Introduction

       It is My 1983 and the EPA has just issued a proposed rule (including alternative
approaches) for regulating the emissions of arsenic from the ASARCO copper smelter
located in your region. Even though a specific approach is presented in the rule, the
Administrator has made it clear in no uncertain terms that he wishes the final rule to take
into account the public's desires. While the final decision will be his, he is more than
willing to change the proposed rule based on public comments.

       Much of the key information about the ASARCO copper smelter and the proposed
regulation is included in the attached case study and appendices.

       In reading the attached material we ask that you keep a few basic questions in mind:

   1.   What constitutes "the public"? What public is the Agency trying to involve?

   2.   What are the key facts from the public's perspective and from the EPA's
       perspective?

   3.   Why is EPA involving the public and what is EPA' s objective?

   4.   What strategies should the Agency follow to achieve those objectives?

   5.   What particular messages is EPA trying to convey to specific individuals
       and how will you present them?

   6.   What is the specific program for involving the public?

   7.   How should EPA evaluate its efforts?
              Development  of a Communication Strategy
       After the review of the case material, we will use the facts presented in the case to
develop a communications strategy.
              Role  Play
       Later in the day, we will conduct a mock public meeting during which time EPA
will present the background of the proposed rule to the public and learn first hand of the
public's concerns. The following material will provide the background information for the
role play.
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Background
              The  Smelter


       The ASARCO/Tacoma copper smelter is located in Ruston, Washington (see Figmre.
1). The facility is situated in an industrial area adjacent to Tacoma and bordered to the
north by Puget Sound.  Across Puget Sound, downwind from the smelter site, lies Vashon
Island, a more rural, middle to upper-class neighborhood where many vocal citizens
opposed to the smelter reside.  The Tacoma/Ruston area, a more urban and blue-collar area,
is where many of the smelter employees and other concerned citizens live.

       The ASARCO/Tacoma facility is the only U.S. smelter to process ore with a high
arsenic content. Built in 1890 as a lead smelter, the facility was bought by ASARCO in
1905 and was converted to a copper smelter in 1912.  Since the conversion of the facility,
the smelter has operated as a custom smelting operation, using copper feed ores with an
average arsenic concentration of 4%, much higher than the typical 0.6% arsenic
concentration for ore used at other U.S. copper smelters. For this reason, the facility is
able to produce commercial arsenic as a by-product of its smelting operation. The
ASARCO/Tacoma facility is the only U.S. producer of arsenic, accounting for one third of
all the arsenic used in the United States. The facility, however, is also responsible for
approximately 23% of the total national inorganic arsenic emissions, and is the only such
source of airborne arsenic in the area.
              Arsenic  Emissions
       Arsenic emissions occur at several points during the production of copper.
Fugitive, or ground-level emissions occur during the transfer of copper ore between the
major steps of production. Of primary concern are the fugitive emissions of arsenic that
occur when the molten ore mixture is sent from the furnace to converters. Gases collected
from the furnaces and the hoods enter the pollution control system, and arsenic, SO2> and
particulates are removed partially by means of a flue gas cleaning system. These
pollutants, however, are still present in tall stack emissions after going through the flue gas
cleaning system. The greatest risk is from the fugitive emissions because they enter the
environment at a relatively low altitude and are not easily dispersed.
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                             TAOTA
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              Pollution Control  Investments
      For the past fifteen years, the facility has been involved in numerous legal battles
with the Puget Sound Air Pollution Control Agency (PSAPCA) over SO2, particulate, and
arsenic controls (the PSAPCA had been delegated authority from the state).  These disputes
began in 1968, when PSAPCA adopted enforceable ambient and stack concentration
standards for SO2- From 1968 to the present, ASARCO has implemented several
environmental controls, yet all the while has petitioned for variances and extensions on
meeting the standards.

      In 1981, PSAPCA required ASARCO to install secondary hooding on the smelter
converters.  This requirement was associated primarily with SO2 and particulate controls,
although the installation of hoods would also greatly reduce fugitive arsenic emissions.
The converters, where the sulfur is burned out of the molten copper mixture, account for a
large proportion of the fugitive emissions of gases. Primary hoods capture most gases
released, but secondary converters that would cover the primary hoods would catch
additional emissions. These secondary hoods would play a particularly important role
when the converters were rotated to receive and dispense the molten copper, at which point
the primary hoods are less effective. While ASARCO installed one secondary hood, the
company has delayed the installation of additional hoods.


 «.:'?.
   ' •.•.    ASARCO's  Economic  Position
       As EPA develops a proposed standard for arsenic, questions have arisen as to the
strength of the ASARCO/Tacoma facility's financial position. According to a 1981
assessment by Robert Coughlin (an EPA Region X Economist), the Tacoma facility has a
limited economic life, probably of less than five years. This is due primarily to
overcapacity within the copper industry and overcapacity within ASARCO itself. A
number of copper smelters have opened overseas, including one that uses high-arsenic feed
ore. This has led to a decrease in the availability and a resultant increase in price for the
imported high-arsenic feed ore  The increased world-wide competition contributes to the
reasons why several ASARCO facilities, in the U.S., including the Tacoma facility, are
operating far below capacity. Along with this overcapacity within the industry and the
increasing price of high arsenic feed ore, another major factor affecting the fate of the
Tacoma facility has been the increasing cost of environmental compliance.

       In Tacoma, the smelter plays an important economic role.
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       The AS ARCO smelter employs approximately 600 people and contributes
       $20 million in goods and services and $2 million in taxes to the area.

       An additional 500 jobs in the area are indirectly related to the smelter
       operation. Plant closure would therefore have a significant impact on the
       community.
               Arsenic Regulatory Status


       Arsenic was designated as a Hazardous Air Pollutant (HAP) under Section 112 of
the Clean Air Act (CAA) in 1980. The National Cancer Institute and the National Academy
of Sciences classify arsenic as a carcinogen based on a statistically significant link between
high occupational arsenic exposures and skin and lung cancer. In addition, inorganic
arsenic is well known as an acute poison to humans in high doses.

       In response to a suit from the state of New Jersey objecting to arsenic emissions
from a New York glass manufacturing plant, a United States District Court in New York
directed EPA to propose a national arsenic standard. As part of this effort, EPA was
directed to promulgate a separate standard for the AS ARCO/Tacoma facility, the only
copper smelter to process high-arsenic ore and the largest single source of arsenic
emissions in the U.S.

       According to the language of the Clean Air Act, standards for hazardous air
pollutants such as arsenic must be based on an "ample margin of safety". For carcinogens,
however, an "ample margin of safety" appears paradoxical. As we discussed earlier,
EPA's approach assumes most carcinogens demonstrate a dose-response relationship at all
doses. In other words, any exposure to arsenic may increase the likelihood of cancer, with
the risk increasing as exposure increases. To reduce arsenic emissions to a zero level,
therefore, would require the closure of all facilities.
                                           -----       '            '          "\
r      EPA therefore has taken the approach of implementing the requirements of the
Clean Air Act by controlling emission sources to the level that reflects the Best Available
Technology (BAT). The selection of BAT is based on an assessment of the best controls
available, considering the economic, energy, and environmental impacts.  EPA will then
decide if further controls are necessary due to unreasonable residual health risks. This
approach has been ernbraowTby William Ruckelshaus, EPA Administrator.. However,...  ..
EPA cjfl iir^c^e^tarrdardslh^t^beyond BAT if, in the language of the statute, it is
necessary to ''protect the public health...with an ample margin of safety."
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       In the case of the ASARCO/Tacoma smelter, the potential impacts of EPA's
proposed standard are great.

   »   Stringent emission requirements would have high compliance costs and
       could force the plant to close, thereby cutting off a major employer and
       revenue source for the community.

   •   With moderate controls, the remaining health risks posed by the smelter are
       higher than riclrc •'"ociated with other regulated hazardous air pollutants.

       For this reason, EPA is trying to gather public input to assist in the determination of
whether BAT controls are acceptable, or whether more stringent controls are necessary due
to potentially unreasonable residual health risks.  EPA has decided to consider the costs of
the various alternatives and to assess the health effects and risks to the maximum exposed
individual (MEI) and the entire exposed population.

   Related Superfund  Activities

       While EPA has been developing a proposed standard, EPA has also been
conducting studies related to arsenic and cadmium concentrations in the soil, sediment, and.
sand of the area and arsenic in the urine of school children. The Washington Department of
Ecology (DOE) and EPA agreed to an investigation of contamination in the area designated
as the Commencement Bay Nearshore Tideilats Superfund Site.  Parts of Ruston, Tacoma,
and Vashon Island, along with the adjacent bay areas, are included in this site designation.
Soils in Ruston and Vashon Island are known to contain arsenic and cadmium in amounts
great enough to warrant concern about eating vegetables from contaminated soil.

       Following the designation of the Commencement Bay Nearshore Tideflats as a
Superfund site, the DOE planned investigations to identify sources of arsenic and cadmium
contamination. Once the sources and problems are identified, remedial measures will be
conducted. One investigative task is clearly related to the ASARCO smelter. The DOE,
along with the Tacoma-Pierce County Health Department, is trying to determine the
exposure pathways by which arsenic is appearing in the urine of children who live close to
the smelter.  This investigation will address the possible exposure through inhalation of
arsenic in the air due to emissions and re-suspended dust as well as possible exposure
through ingestion of contaminated vegetables, drinking water, and soil.  Cadmium
contamination is also being investigated.
           j.
       Other Superfund investigations focus on the extent and risk of contamination of
aquatic life and sediment in the water.  An analysis of seafood is also anticipated as part of
this inquiry. EPA is keeping the ASARCO smelter proposed regulations separate from the
Superfund activities.
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EPA  Proposed  Arsenic  Standard

      In its proposed rule EPA employed a three-step approach to determine the control
requirements being proposed.

   1.  A determination whether BAT is in place for all emission points

   2.  Selection of BAT for emission points identified as needing standards

   3.  Investigation of alternatives

      The recommended standard would require Best Available Technology (BAT) on
converter fugitive emissions. All other emission sources at ASARCO are believed to be
controlled to the level of BAT. The installation of two additional secondary hoods would
fulfill the BAT requirements for converter fugitive emissions.

      The proposal includes the following language which specifies the Agency's interest
in public involvement in the standard setting process:

      "As now written, this proposed regulation would leave some of the residents of
Tacoma exposed to a relatively high estimated risk of lung cancer when compared to the
risk around other sources of arsenic. The Administrator is especially eager to hear
comments from the residents of Tacoma on whether this remaining degree of risk is
appropriate and how this decision should be made."
                        EPA  Risk  Calculations
       EPA's calculation of the human health risk of developing lung cancer from arsenic
exposure provides the basis for the draft of the proposed standard for the
ASARCO/Tacoma facility.  The proposed rule focuses only on cancer risks to the
population from air emissions of arsenic. Other health risks and ecological risks are not
specifically addressed. In part these risks are excluded because EPA is in the process of
addressing them through Superfund activities. The ASARCO site was included in the area
designated as the Commencement Bay Nearshore/Tideflats Superfund Site in April 1983.
Superfund studies and risk assessments are currently underway to examine the risks
associated with arsenic and cadmium already present in the soil.

       In conducting the risk assessment, EPA evaluates the hazard associated with
arsenic, evaluates the health risks resulting from different levels of arsenic as described
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through dose-response estimates (the unit cancer risk factor), and estimates population
exposure levels. EPA then characterizes the risk and the cost of controls, and alternatives
to the proposed controls. Each of these steps is discussed in the following sections.

       Brief descriptions of the results of some studies based on Tacoma data that provide
more information to the risk assessment follow:

    •   Enterline and Marsh observed a cohort of 2802 workers at the AS ARCO
       smelter from 1940 to 1964. Their study did not statistically confirm a dose-
       response relationship for lung cancer, except when all retired workers were
       included in the data set

    •   A 1978 study  of lung cancer mortality, conducted  by the Fred Hutchinson
       Cancer Research Center, failed to document excess cancers within the
       Tacoma population associated with arsenic exposure from the smelter.

    •   A 1977 cohort study on lung cancer by Pinto et al. reflected a dose-response
       relationship as shown through urinary arsenic levels. This dose response
       relationship was also dependent on the duration and intensity of arsenic
       exposure.

    •   In the 1970s, the DSHS confirmed the presence of arsenic in the urine and
       hair of children living near the smelter. The concentration of arsenic
       declined with  distance from residences to the smelter. Samuel Milham,  of
       the DSHS, indicated that although high levels of arsenic existed in the soil
       and in children's urine and hair, there was no evidence of any adverse
       health effects  associated with the presence of arsenic.

    •   The Puget Sound Air Pollution Control Agency indicated that the average
       urinary arsenic levels in Ruston and Vashon (reported at 36 and 23
       micrograms/liter, respectively) were  significantly higher than a control
       group in Olympia (with a reported level of 12 rnicrograms/liter).
                         Hazard Identification
       As we discussed, during the Hazard Identification stage, the assessor wants to
determine whether the chemical can, in large doses, result in a specific effect, such as an
increase in the risk of cancer. Evidence from occupational exposure data from smelter
workers indicates that a direct link exists between high arsenic exposures and lung cancer.
The risks were shown to increase with an increase in cumulative arsenic exposures.
However, the carcinogenicity of arsenic in humans is not well understood. Some animals
appear to have a dietary need for arsenic although this need has not been demonstrated in
humans.
          	       ~                          	             		I
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       Other noncarcinogenic health effects have also been documented including nerve
damage, hemoglobin synthesis impairments, and hearing loss in children.
              Dose-Response  Evaluation

       The dose-response relationship for arsenic was identified using data from the
studies of lung cancer incidence in workers exposed to high levels of arsenic. These
effects found at the higher occupational exposures are mathematically extrapolated to lower
concentration levels. These lower concentrations more nearly reflect the exposure of
people around the ASARCO smelter.

       Using a linear extrapolation, EPA calculates the expected (modelled) response at
doses lower than the occupational levels. This linear extrapolation represents an "upper
bound" (e.g. "conservative") estimate of the probability of developing cancer from
inhalation at low doses in that the actual risk is unlikely (95% confidence) to exceed the risk
estimated using the linear extrapolation.
  K & Jw      Exposure Evaluation
      *» ^

    HIB W
       Total exposure is determined by dispersion modelling estimates of the arsenic
concentration in the ambient air surrounding the smelter combined with data for the
distribution of the 370,000 people living within 12 1/2 miles of the smelter.

       Emissions: Fugitive source emissions are too difficult to measure and therefore are
estimated. The stack emission rate used in the analysis, however, is derived from emission
tests.

       Dispersion: EPA uses a model to calculate the dispersion of arsenic emissions
within a 12 1/2 mile radius of the facility. The complex geography of the area and
imprecise meteorologic data make dispersion calculations difficult. Because of these
difficulties, and EPA's relatively high calculation of emission rates, the modelled results of
ambient concentrations are higher than the actual measurements of arsenic concentrations.

       Population Location: Census data estimates of population location within the 12 1/2
mile radius are combined with the modeled ambient concentrations of arsenic to determine
die population exposure.

       Exposure Duration: The estimated exposure level assumes that individuals are
exposed to a constant average concentration of arsenic for 24 hours per day for a lifetime of

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 70 years.  For workers at the smelter, this average concentration exposure represents an
 underestimate of exposure levels, yet for residents spending time outside of the Tacoma
 area, this exposure level represents an overestimate. This estimate of exposure is based
 solely on inhalation of arsenic emitted by the smelter through stack and fugitive emissions.

       According to EPA estimates, the proposed standard, requiring the installation of
 additional secondary hoods, will significantly reduce arsenic emissions. EPA's estimates.
 however,  are significantly different from ASARCO and PSAPCA estimates.

       EPA estimates that fugitive arsenic emissions will be reduced from 134
       million grams (Mg) per year to 24 Mg per year.  (Total emissions will
       thereby be reduced from 282 Mg to 172 Mg.)

       ASARCO's estimates of emissions, prior to the installation of controls, are
       much lower (Table 1). ASARCO calculates that total emissions, without
       secondary hoods, are closer to 53 Mg (59 tons).

       PSAPCA calculations indicate that total emissions are 93 Mg before
       controls.

       Ambient monitoring data around the facility provide some additional indication of
 the concentration of arsenic in the air. These data, however, are limited in quantity and also
 show major differences.

       ASARCO's monitoring stations in Ruston indicate that the concentration of
       arsenic in the air is approximately.0.2 to 0.9 micrograms per cubic meter.
       (The OSHA standard for arsenic concentrations is 10 micrograms per liter.)

       According to a newspaper account of ASARCO's description of the data,
       EPA calculates that the level of arsenic in the air near the smelter is
       approximately 10 to  30 rnicrograrhs per cubic meter.

       This difference between the ambient data and modelled data may be attributable to_^
 the fact thatEP.Alsjmodeluses input based on assumptions about emissions and
 dispersion, and cannot precisely predict thTeffects of complex geography and
Tne^arolog^. ffa3diHon7EPA dpesnTknow the location of ASARCO's monitoring
 stations, which may be located at more distant points.

       Although EPA uses estimates of ambient concentrations ranging up to 30
 micrograms per cubic meter, this highest value is used only to calculate the risk to the
 maximum exposed individual. In EPA's exposure model, concentration levels at which the
 majority of the population is exposed are less than 0.05 micrograms per cubic meter.
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                                 TABLE  1
              ANNUAL ARSENIC  EMISSION ESTIMATES
                       OF THE ASARCO SMELTER
    Current   Emissions
       (million  grams)
EPA's Estimate:
Stack:                      148
Fugitive:
  converters
  others
Total:
ASARCQ's Estimate:
Stack:
Fugitive:
  converters
  others
Total:
 PSAPCA's Estimate:
 Stack:
 Fugitive:
  converters
  others
 Total:
 120
_J4
 282
  37

   8
   1
  53
  64

   5
   4
  93
                   Emissions   After   Controls
                         (million  grams)
EPA's Estimate:
Stack:
Fugitive:
 converters
 others
Total
ASARCO's Estimate:
Not applicable
(none made)
PSAPCA's Estimate:
Not applicable
(none made)
 148

  10
_J4
 172
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                        Risk  Characterization
       Annual cancer incidence associated with arsenic emissions from the ASARCO
smelter is the product of the total population exposed around the smelter and the unit risk
number, divided by 70 years (total population exposed x unit cancer risk/70 years).  Based
on EPA's modelling of emissions and resultant exposure estimates, and an estimate for the
unit risk factor for arsenic, the health effects at levels proceeding and following installation
of controls are calculated.

       The maximum lifetime risk represents the probability of a person contracting cancer
who has been continuously exposed during a 70 year period to the maximum (30 fig/nr*)
arsenic concentrations from the smelter.  The average lifetime population risk represents
this probability for an individual who has been continuously exposed to an arsenic
concentration of approximately 0.5 (ig/iTr.

Total inorganic arsenic
emissions
Average lifetime car.v.c. ;\*,C
Maximum lifetime cancer risk**
(for the Maximally Exposed
Individual -MEi)
Lung cancer incidence within
12 1/2 miles of the facility
BEFORE BAT
311 tons/year
2X10"4
A range of 2.7 - 37 per 100
with a best estimate of 9 per
100
1.1 - 17.6/yearwithabest
estimate of 4 per year
AFTER BAT
189 tons/year
4X10"5
0.58 - 9.2 per 1 00 with a best
estimate of 2 per 100
0.2 - 3.4/year with a best
estimate of 1 per year
Annual background lung cancer rate in the Tacoma area is 71 - 94
*The mean concentration of arsenic in the air is calculated as 0.05 ug/m3
"The maximum concentration of arsenic in the air is calculated as 30 ug/m?
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   UNCERTAINTIES  IN  RISK CALCULATIONS

          The process of calculating these risks for the population around the smelter involves
   many assumptions and uncertainties. So while these estimates of risk are a useful tool in
   the decision-making process, MUCH CAUTION SHOULD BE EXERCISED TO AVOID
   RELYING TOO HEAVILY ON THE NUMBERS PRESENTED ABOVE. These
   numbers have considerable uncertainty for the following reasons:

          1)  MODELING ASSUMPTIONS - Measurement of air concentration of arsenic
   around the ASARCO plant have not been done thoroughly; however, the measurements
   that have been obtained indicate lower concentrations than those predicted by the dispersion
  f model. Arsenic emissions data from the smelter used in the dispgraon_rnodel are not
  . precise._Inmanv caseslhese emission rates^vere based on assumptions rather than actual
   einissioTTtests  TCFisnespeciallvjrue.fotf
   calculating concentration yet are veryjdtfficult to measure. Also,"es~timates~of how these
  ^-S^nic-ernissions-rnix'with'thTambient air are hard to determine because of the complex
   geography and lack of specific weather data for the area around the smelter.  These
   problems may explain why the ambient monitoring around the smelter shows lower
   concentrations of arsenic than EPA's dispersion model predicts.

  /"       2)  EXPOSURE ASSUMPTIONS - A principal assumption is that.all.persons-living
/ within the 12 mile radius of the smelter will remaiffin the same~location for a 70 year
/   lifetime and are exposed to a constant, average concentration of airborne arsenic. This
.   assumption could result in large overestimates of arsenic exposure for those who spend a
\   lot of time away from their residences and in underestimates for workers employed  at the
   smelter. Additionally, exposure to arsenic from resuspension of arsenic bearing dusts from
   city streets, empty lots, and playgrounds has not been taken into consideration.

          3)  UNIT RISK NUMBER - Because arsenic is a carcinogen, it was assumed that a
   linear relationship exists between exposure and risk. Simply stated, this means that a
   person who inhales one microgram of arsenic per cubic meter  of air is one-tenth as likely to
   get cancer as a person who inhales ten micrpgrams per cubic meter. If the relation ship
   between exposure and risk is not linear, a different unit risk number could result which
   would in turn change the lung cancer risk estimates made for the population around the
   smelter. It is unlikely that the actual cancer risks would be higher than those predicted by
   EPA, but they could be substantially lower.

          EPA is now in the process of reviewing the data used in calculating risk estimates,
   especially those data which relate to arsenic emissions  and dispersion modeling. If
   necessary, new data will be developed in these areas to permit EPA to better estimate risks
   to the smelter community.
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$$$
Costs
      EPA estimates the economic costs of the secondary hood control measures to be as
follows:

   •  $3.5 million in capital costs.

   •  $1.5 million in annual operating costs based on increased energy use.

      These costs are based on economic information provided by ASARCO. Assuming
that ASARCO could pass off all of the additional cost to purchasers, these costs would
translate into an increase in the price of copper of 0.8%.  It is estimated that the proposed
standards will not adversely affect the economic viability of the smelter or employment at
the smelter.


Alternatives

      As noted, EPA can do more than BAT. There are several other alternatives
currently being considered by EPA:

   •  Baghouse controls, (a method of catching paniculate matter within the
      emission control system, before its release from the stack) are considered to
      be expensive to install and ineffective against fugitive emissions.

   •  The use of ore with lower arsenic concentrations has also been considered,
      although this too would be costly for the company. EPA estimates that
      replacing only 15% of the total feed ore with low-arsenic material would
      result in a $2.8 million reduction in net income for the facility.

   •  Better smelting technology could be more effective but would require a great
      capital investment by ASARCO.


ASARCO and Community Attitudes

      The impacts of an arsenic standard for the AS ARCO/Tacoma facility are of concern
to many individuals and to the community as a whole. Because of the uncertainty in risk
estimates, the economic impacts, and the potential health effects associated with the draft of
the proposed standard, there will undoubtedly be a great deal of debate within the
community over EPA's actions. As would be expected, there was a wide range of public
opinion. This range is reflected in .the newspaper articles included in the Appendices.
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       Among the potential categories into which public opinion might fall are the
following:

   No additional  controls will  be needed

       A small group of people will probably feel that the facility should continue
operations without installing secondary hoods. These people will primarUy be employees
who feel that they are adequately protected and that no additional controls will be needed..: •

   Proposed BAT will provide adequate controls

       A greater number are expected to feel that the proposed BAT controls provide the
proper level of control. Included in this majority are ASARCO officials and managers, as
well as a number of residents. These people  believe that there is no evidence of a health
risk associated with the smelter, and any possible health risk is less important than the jobs
and economic benefits provided by the smelter. ASARCO employees and some nearby
residents have reported in the past that no  one they have known, employees or residents,
has developed lung cancer. They dispute the existence of a health risk. Many employees
have also expressed in the past that they feel  that there is a threshold level of safety
associated with arsenic exposure below which no adverse effects will be observed.

       ASARCO officials have indicated since the time PSAPCA issued its own
requirement for secondary hoods, that they are willing to install the proposed hoods once
they receive EPA's assurance that this will represent BAT.  They want assurances that no
additional requirements will be placed on the operation.  ASARCO has maintained,
however, throughout discussions with PSAPCA, that there is no significant health risk
associated with emissions. ASARCO is certain to assert that EPA's emission and exposure
estimates are too  high and overestimate any health risk.

       The mayor of Tacoma has already  indicated that the secondary hoods required by
PSAPCA seem satisfactory and that closure of the plant should be avoided. "Until I've
been shown specifically that there are indeed deaths being created by the emissions out of
ASARCO, I don't think the plant should be closed," said the mayor. He called ASARCO a
"good corporate neighbor", and indicated that it has not been a source of significant public
health risk.

       His view  is supported by Dr. Samuel Milham, epidemiologist for the DSHS.
"Unless you can demonstrate you're causing a public health problem, I think it would be
irresponsible to be closing the plant, and we definitely haven't been able to demonstrate
that."
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   Additional technical  controls will  be necessary

      Others in the community believe that EPA should require secondary hoods but
should also impose additional technically feasible controls. This opinion has been raised in
the past at PSAPCA hearings by a number of local regulatory agencies and environmental
groups, including Fair Share, the Tacoma City Council, and Tacomans for a Healthy
Environment Many of these people feel both jobs and health can be protected. PSAPCA
supports this position, and has already indicated that it would like EPA to go beyond the
secondary hood requirements it has already imposed.

   The facility should radically alter  or stop operations

      Finally, there are individuals who will probably urge EPA to require the AS ARCO
smelter to use low-arsenic feed ore or stop operation. These people perceive that a
significant health risk will always be associated with the smelter, even if control measures
are taken. Many of these people feel that the Tacoma area would benefit from the closure
of the smelter, perhaps through realizing its goal of becoming a high-tech center, rather
than remaining a home to industrial hazards.
              Developing  a  Communication Strategy
       You have been placed in charge of developing a communications strategy for the
region on the proposed smelter rule. We reviewed earlier the items that constitute an
effective plan and they are briefly noted below. Take the next 15 minutes and fill in the
following items from what you know in the ASARCO case.

   1.  Identify your goals for the risk communication.
   2.  Identify your audiences and their specific concerns. Identify the audience of most
       and lesser importance.
   3.  Design your message to meet the concerns of your audiences.
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   4.  Identify the best methods to reach people.
   5.  Identify the steps necessary for internal coordination.
   6.  Identify your plan for evaluation of the communication strategy.
   7.  What would be the major roadblocks to development and implementation of a
      communication strategy?
             Discussion  Questions
   1.  What steps might be taken to encourage effective communication with outside
      audiences and within the Agency?
   2.  When should you go beyond the communication required by statute?
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              Role Play  •  Public Meeting
       An informal public meeting sponsored by EPA is being held to discuss EPA's
proposed rule. The meeting should be opened by the EPA representatives, who should do
some basic planning using the planning framework identified earlier:  decide what they
hope to accomplish at the meeting; establish a format and agenda; prepare an introductory
statement; and so forth. The other participants should prepare their positions and consider
how they want to approach the meeting and what they hope to achieve.  Note ~ there is
nothing that prohibits participants from talking to one another to try and workout alliances
and strategies prior to the meeting. You will have been given descriptions of different
people who may be at the meeting. In the real world special interest groups, whether they
be environmentalists or representatives of the industry, are adept at controlling the process,
and that should be part of the process here.

       In the actual case the EPA held a series of informal public meetings after the
proposed rule was published and prior to finalization. The EPA Administrator was willing
to revise the rule in response to the public's desires if they could clearly be identified. The
participants in this workshop have the opportunity to recreate one of those meetings.

       The role play will be conducted in one of two ways.  Either each member of the
class will receive a role (or roles) or the class may be divided into two groups. In the latter
case, each group will prepare to both conduct the meeting (take the role of EPA and the
state agencies) and to assume the role of those attending the meeting (general public, local
officials, activists, industry, etc.). Each group will be given the opportunity to run the
meeting and also to attend it

       You should assume the EPA proposed rule has just been published in the Federal
Register and the EPA is holding its first informal public meeting. The date is August 30,
1983. The meeting is scheduled to begin at 2:00.

       Good luck... and have some fun!
Risk Communication Workshop                                              Case Study -18

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APPENDIX A
Proposed Rule

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Federal Register / Vol. 48. No. 140 / Wednesday. July 20.  1983  /  Proposed Rules
                                                                                                        3312
1L INORGANIC ARSENIC EMISSIONS
P1OM FR1MARY COPPER SMELTERS
PROCESSING FEED MATERIALS
CONTAINING 17 PERCENT OR
GREATER ARSENIC
  The proposed standard* would
regulate inorganic arsenic emissions
from primary copper smellers that
    ess feed material with ea anmi
           material with an annual
avenge inorganic arsenic content of OJ
weight percent or more. The proposed
standards would require the use of best
eveilable technology (BAT) to limit
secondary Inorganic arsenic emissions
from copper converting operations.
Secondary Inorganic ai
era emiasioas that escape capture from
the primary emission control system.
The RAT for the capture of secondary
inorganic arsenic emissions from
converter charging, blowing, skimming.
holding, end pouting operations is a
secondary hood system consisting of a
fixed enclosure with • horizontal air
cut M.4. For collection of secondary
inorganic arsenic emissions. BAT is a
baghouse or equivalent control device.
The proposed standards era expressed
in terms of equipment specifications for
the capture system ead a "
         p articulate emission limit for
the collection device. Paniculate
emissions from the collection device
would not be permitted to exceed 114
milligrams of particalates per dry
standard cubic meter of exhaust gas
(mg/dscm). This limit reflects BAT for
collection of secondary inorganic
arsenic enrittHmt
  To determine the applicability of the
proposed standards to a primary copper
smeller, the Inorganic arsenic content of
the feed materials would be meenred
using the proposed Reference Method
IMA. To determine compliance with the
proposed particulata emission limit
Reference Methods 1.2. 9. and 8 In
Appendix A of 40 CFR Pert 80 would be
used. Continuous opadty monitoring of
gases exhausted from e paniculate
control device would be required to
ensure the control device is being
                       properly operated and maintained.
                       Continuous monitoring of airflow would
                       be required to ensure the secondary
                       hood system Is being properly operated
                       and maintained.
                         The proposed standards would affect
                       primary copper emelters that process
                       teed material having aa annual average
                       inorganic arsenic content of OJ weight
                       percent or more* This category la
                       defined aa hlgh^rsenkMhroughpot
                       smelters. The only existing primary
                                     and operated
                                     I ASARCO) aa
                                     Washington,
                                                              la owned
                       throughput smelter category
                       and operated by ASARCO. boorporated
                                 aad located tat Teooma.
                          ashington, The aaaual avenge
                       inorganic arsenic content of At lead
                       materialism! expected to bo facreesed
                       to 0*7 percent or above at any other
                               amelter. end ao BOW
                       an protected to be bufltFor this reason
                       only the ASARCO smelter located in
                       Tacoma. Washington (hereafter referred
                       to as the ASARCO-Tecoma smelter).
                       bee been analysed for the purpoee of
                       Ttlffi*!**1^ the health* eti¥tiU|'intnf**
                                        wimpectsofthe
                                       As will be discussed in the next
                                     eectfon, to facUltate refulatory analysis
                                     EPA has
                                                     into two <
within about 20 kilometers (UJ miles)
of the ASARCO-Teoome smelter would
be reduced from a raage of 1.1 to 17 J
incidences per yeer to a range of 04 to
9.4 Incidences per year. The proposed
standards would reduce the estimated
maximum lifetime risk from exposure to
airborne inorganic arsenic from a range
of 2J to V la 100 to a range of 0£9 to tJ
In 100. The maximum lifetime risk
represents the probability of a person
contracting cancer who has bees
exposed continuously during a 70-year
period to the maximum aaaual morgani
arsenic concentration due to morganic
arsenic omissions from the ASARGQ*
Taooma amelter. (These estimated
health impacts wen calculated baaed
oa a aomber of assumptions and contai
considerable motttainty aa discussed li
Part I of this preembie end in Appendix
EofthebeckgreuadJnforasttoo

  Application of the ooabols required
by the proposed standards would
Increase the amount of solid wests (Le.
collected particulate matter containing
inorganic arsenic) entering the
ASARCO-Tacoma smelter waste
disposal system by approximately 11
         (Gf) (11000 tons) per year.
         theASARCO-Tacomi
      te* approximately l«2Cg
                               separated t
                               industry in
                               s based OB
   i) per year of solid waste (taw
slag). The additional
                                     inorganic arsenic content of the amelter
                                     feed material Primary copper emeiters
                                     which process feed material with an
                                     annual avenge inorganic areente
                                     content less than OJ weight percent an
                                     addressed la Part ffl of this preamble.
                                       The proposed standards would reduce
                                     total Inorganic arsenic emissions from
                                     the ASARCO-Tecoma smelter from the
                                     current level of Stt megegrams (Mg) (911
                                     tons) per year to a level of 171 Mg (109
                                     tons) per year. Asa result of this
                                     reduction te Inorganic arsenic emissions.
                                     it is estimated that the number of
                                     incidences of lung cancer due to
                                     Inorganic arsenic exposure for the
                                     approximately 9704100 people living
                         of solid
 Bete generated can be handled by the
existing wests handling system et the
smeller. Because the 000030! systems
expected to be used to achieve the
proposed standards an dry systems.
then would be no water pollution
                                                               —irgy tmpects under the proposed
                                                             standards would be increased electrice
                                                             power consumption. The annul energy
                                                             requirement for the ASARCO-Tscom*
                                                             smelter to approximately 19x10*
                                                             kuowatt'hours per year fkWh/y).
                                                             * -*.*•»•	1	- _^	a	.   *  t
                                                             AddiUonal energy requirements et the
                                                             ASARCO>Tacoma amelter due to the
                                                             proposed standards an estimated to be
                                                             approximately IJXIO* kVYh/y.
                                                             representing aa inerasse in the annual

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33112
                Federal Register / Vol. 48. No. 140  / Wednesday. July 20,1983 / Proposed Rule*
ENVIRONMENTAL PROTECTION
AGENCY

40 CF* Part 61
National Emission Standards tor
Hazardous Air Pollutants; Proposed
Standards for Inonianfc Arsanfe

AO8MCY: Enviromnenlai Protection
Agency.
ACTION: Propoied rule and
announcement of public hearing. _

MMMAftr On June 1 IMa EPA listed
inorganic anenie as a hazardous air     '
pollutant wider Section 112 of the Clean
Air Act. Pursuant to Section lit EPA Is
proposing stprdards for the following
categories ol .«urces of emissions of
Inorganic arsenic high-arsenic primary
copper smellers, low-arsenic primary
copper smellers, and glass
manufacturing plants. EPA identified
other categories of sources emitting
inorganic arsenic: and. after careful
study, determined that the proposal of
standards for these categories of sources
is not wsrranted et this time. These
categories of sources are primary lead
smelters, secondary lead smelters.
primary sine smelters, sine oxide plants.
cotton gins, and arsenic chemical
manufacturing plants.
OATtss See "MJpsuuufr AWT
       MMN" below.
          :
WPOWkUTIOM" b«low.
See
oelow.
            m*o**UTtoN CONTACT:
                           tio«r
Public Hearings and Related Information
Dales
  Comment*. Comments must be
received on or before September 30.
1983.
  Public Heorim. Two public bearings
will be held. The first hearing will be
held in WasMnflon. D.C. on August 23.
24. and 211983. beginning at 930 a.m.
each day. Thla hearing will consist of
two separates cessions. The first session
will be for the purpose of receiving
comments on the bating of arsenic as a
harssdous pollutant The second session
will be for the purpose of receiving
comments on the content of the
proposed regulations. The order of Items
on the agenda of the second session will
be: (1| high-arsenic coppers smelters. (2)
low-arsinic copper smelters. (3) glass
manufacturing plants, and (4) others.
Persons planning to attend the first
hearing may call mrs. Naomi Durkee
(919) 541-8578 after August 18.1993. to
obtain an estimated time end date at
which etch subject will be sddressed.
  The second hearing will be held in
Tacoms. Washington, on August 30.
1983. This hearing will be for the
purpose of receiving comments on the
proposed standards for high-arsenic
copper smelters. This (tea* ng will be
held fromm 12.-00 noon to li*£0 p.m. and
may be continued on August 31.1983. if
necessary to allow all persons wishing
to speak an opportunity to do so.
  Aequett to Speak et Hearing. Persons
wishing to present oral testimony at the
first hearing must notify Mrs. Naomi
Ourkee by August 111983. at telephone
number (919) 541-8578 or mailing
address: Standards Development
Branch. MD-13. US. Environmental
Protection Agency. Research Triangle
Park. N.C 27711.
  Persons wishing to present oral
testimony at the second hearing must
notify Ms. Laurie Krai by August 23.
1983. st telephone number (206) 442-1089
or mailing address: Air Programs
Branch. U.S. Environmental Protection
Agency. Region X1200 6th Avenue.
Seattle. Washington. 98101.
Addresses
  Comment*. Comments should be
submitted (in duplicate if passible) to:
Central Docket Section (LE-13U US.
Environmental Protection Agency. 401M
Street S.W.. Washington. D.C 20480.
Specify the following Docket Numbers:
OAQPS-79-e  Ualinsefarawucaaa
  tUtenfcw* pollutant
A-atMO  Hi|h*rMnw end low-eraanic
  copper MMiitn
A-63-S CUwmnnufecturfof plant*
A-aa-e Secondary lead
A-43-10  Cotton tins
A-83-U  ZincMidtDlenta
A43-29  Primary sine primary I ad. arsenic
  chemical BMavlacttirinf
  Public Hearing. The public tearing to
be held on August 23.24 and 25.1983.
will be held at the Department of
Agriculture. Thomas |efferson
Auditorium. South Building. 14th and
Independence Ave, SW» Washington.
D.C.
  The public bearing to be held on
August 30.1983. will be held at the
Tacoma Bicentennial Pavilion. Rotunda
Room. 1313 Market Street Tacoma.
Washington.    .
  Background Information Document.
Background Information documents
(BID'S) for the proposed standards may
be obtained from the UJL Environmental
Protection Agency Horary (MD-35).
Research Triangle Park North Carolina
27711. telephone 919-441-2777. Please
specify:
  EPA 450/9-83-008* Inorganic Arsenic
Emissions From High-Arsenic Primary
Copper Smelters—Background
Information for Proposed Standai
  EPA 450/3~&M>10a Inorganic f
Emissions From Low-Arsenic Prii
Copper Smelters—Backg
Information for Proposed       i
  EPA 450/3-83-Olle Ino      /
Emissions From Class Manufacti
Plants*—Background Information
Proposed Standards.
  EPA 450/5-82-003 Preliminary
of Sources of Inorganic Arsenic.
  Dockett. Dockets containing
supporting information used in
developing the proposed standar
available for public inspection si
copying between 6:00 a.m. and 4:
Monday through Friday, at EPA'
Central Docket Section. West Tc
Lobby. Gallery l. Waterside Ma!
Street. S W- Washington. D.C. X
reasonable fa* may be charged i
copying. The following dockets i
available:
OAQPS-79-d  Listing efarienicas
  huxardoui pollutant
A-ao-«0 Hijh-trt«nic«ndlow.«r»
  copper MMlura
A-43-6 Class manafaeturinf plant
A-49-9 Sacendary toad
A-aa-io Gotten gins
A-av-11 Zinc oxide piam*
A-49-Z3 Primary sine primary lai
  chemical manufaciurinf

  The docket A-80-40. w
the supporting informal!
proposed standards for
low-arsenic copper smelters, w
available for inspection and co
the EPA Region X office in Seal
Washington. Persons wishing t
thie docket should contact Ms.
Krai at telephone number (208)
or et mailing address: Air Progi
Branch. U.S. Environmental Pn
Agency. Region X1200 6th AVI
Seattle. Washington. 98101.

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33124
      ••     i-,'  .  ><"•*    ....».          .    -,.'•   •
Federal'Register  /'Vol'. 48. No. 140  /  Wednesday: July 20.  1983 / Proposed Rules
imelier energy consumption of about 0.5
percent.
  For the ASARGO-Tacoma imelter.
capital and annuallzcd costs required to
meet the proposed standards would be
approximately $3.5 million and $15
million, respectively. The primary
economic impacts associated with the
proposed standards are projected
decreases in profitability for the
ASARCO-Tacoma smelter. It is
anticipated that the proposed standards
will not adversely affect the economic
viability of the smelter or employment at
the smelter. In addition, it is estimated
that tbe proposed standards could result
in an increase in the price of copper of
up to 04 percent.

Rationale

Selection of Source Category
  Copper smelting involves the
processing of copper-bearing ores
containing varying concentrations of
inorganic arsenic. EPA estimates that
current controlled emissions of
inorganic arsenic from primary copper
smeller* are 1.012 megagrems (Mg)
(1.116 ton*) per year.
  Several studies have assessed health
problems in communities where primary
copper smeller* are located. Increased
lung cancer has been reported among
male and female residents living near a
primary copper smelter located in
Anaconda. Montana (this smelter was
permanently closed in 1981). The
National Cancer Institute ha* released a
study showing excess mortality from
respiratory cancer in counties where
primary copper smelters are located.(M)
  TA initiated a study in 1977 of the
populations exposed to various amhi*>ni
air concentrations of inorganic arsenic.
This study, in summarizing 1974 data
collected by EPA's National Air
Sampling Network (NASN). show* that
the annual average concentration of
inorganic araenic for five urban areas
within 80 kilometer* of selected smellers
waa 10 time* greater than the annual
average for ail of the *ite* (In exeats of
290} in the nationwide network. At a site
within 16 kilometers of the ASARCO-
Tacoma smaller, the annual average
we* more than 29 lime* the national
average.
  Baaed on information provided by the
copper tmelting industry. EPA has
determined thai the ASARCO-Tacoma
smelter processes feed containing a
higher concentration of inorganic
araenic than any other primary copper
•mailer in the United Slates. The
ASARCO-Tacoma smelter Is a custom
•mailer. ASARCO purchases ore
concentrates from other mining and
milling producers to process at its
                        Tacoma smelter. Typically, feed
                        material containing on the average 4.0
                        weight percent inorganic arsenic is
                        processed el the ASARCO-Tacoma
                        smelter at the rate of 940 kilograms of
                        inorganic arsenic per hour (kg/h). The
                        level of inorganic arsenic concentration
                        in the feed muteriais processed al the
                        ASARCO-Tacoma smeller is an order of
                        magnitude greater than the level
                        processed al the other 14 primary copper
                        smelters. The second highest average
                        inorganic arsenic content in the feed
                        material processed el a domestic
                        smelter is 0.6 weight percent. The
                        second highest average process rale of
                        inorganic araenic at a domestic smelter
                        is approximately 170 kg/h. In fact, the
                        inorganic arsenic process rate for the
                        ASARCO-Tecoma smelter is
                        significantly greater than the combined
                        inorganic arsenic process rate of 623 kg/
                        h for the other 14 smelters.
                          Because of the potential for high
                        inorganic arsenic emissions and the
                        proximity of the population, calculated
                        risks and cancer incidence are
                        substantially higher for the ASARCO-
                        Tacoma smeller than for other smellers.
                        Consequently, the benefit* associated
                        with the application of specific control
                        technologies to the ASARCO-Tenma
                        smelter versus the other smelters are
                        significantly different whan considered
                        in term* of emission and risk reduction.
                        costs, energy, and other impact*. For
                        thi* reason. EPA believe* it is
                        reasonable for purpose* of regulation to
                        separate smelters into iwo source
                        categories based on the annual average
                        inorganic araenic concentration in ihe
                        feed.
                          The source category for high-arsenic-
                        throughput smelters is primary copper
                        smelters processing feed with an annual
                        average inorganic arsenic content of 0.7
                        percent or more. The value 0.7 percent
                        was selected based on the consideration
                        of the inorganic araenic content of the
                        faad malarial* protected al  the existing
                        smelters other than the ASARCO-
                        Tacoma smelter. The regulatory analysis
                        of the 14 existing smeller* which
                        process faad malarial with an annual
                        average inorganic arsenic content less
                        loan 0.7 weight percent i* presented it.
                        Part III of thit preamble.
                          EPA ha*, aa a matter of prudent health
                        policy, taken the petition that human
                        carcinogen* mu*t be treated a* posing
                        •ome riak of cancer MI any non-tone
                        level of exposure. Therefore. In
                        conjunction with the Administrator'*
                        determination that (1) than ia a high
                        probability that inorganic araenic i*
                        carcinogenic to human*, and (2) that
                        there i* significant public exposure to
                        inorganic araenic emissions from the
                        ASARCO-Tacoma  amelter. the
Administrator has determined that
inorganic arsenic emissions from hi$
arsenic-throughput smellers lire
significant nnd should be regulated.
  In making the decision to regulate
hixh-arssnic-throughput smelters, ih
Administrator considered whether o
regulations affecting high-arsenic-
throughput smelters were adequate
control atmospheric inorganic arsen
emissions. The Administrator has
concluded that existing regulations <
not adequate to protect the public hi
end welfare Ircm'sources uf inorgan
araenic emissions at high-arsenic-
throughput smelters with an ample
margin of safely. Baaed on an analy:
of the costs and impacts of more
stringent alternatives, it is the
Administrator's judgment that a
substantial reduction in inorganic
araenic emission* to the atmosphere
from the current level i* achievable
appropriate. Therefore. EPA has dec
to proceed with the development of
standards to control inorganic arsen
emission* from high-araenic-through
smelter* under Section 112 of the Cli
Air Act.
  EPA expects thai only the ASARC
Tacoma smeller would be in the higl
araenic-throughput smelter source
category. Should any other existing
smelter process feed materials havir
an annual average inorganic araenic
feed content above 0.7 weight percei
the smelter would become subject tc
proposed standards, in addition, the
proposed standards would also  appl
any new smaller processing feed
material* with an annual average
inorganic arsenic concentration of 0.
weight percent or more.
  Other than the ASARCO-Tacoma
smeller, no existing smelter is expec
to process feed material* having an
annual average inorganic araenic fei
content above 0.7 weight percent wr
ihe next 8 year*. Alto, II1* protected
thai no new domestic primary coppc
smelters will be built within the MX
yean. This protection it bated on El
conclusion that annual industry gro<
will be accommodated by existing
tmelten. which an pmenlly not
operating or an operating below
capacity.
Description of Smelling Process one
Emistion Points

  A primary copper tmalter it a faci
that produces copper from copper
sulflde on concentrates using
pyrometallurgical techniques. Thau
techniques an baaed on copper'* st;
affinity for tulfur and It* weak affln
for oxygen a* compared lo that of Ir
and other baa* metal* in the on. Th

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               Federal  RtgUter /  Vol. 4B.  No. 140  /  Wednesday. July 20.  1983 / Propoaed Rule*	331
purpose of smelting i» to separate the
copper from (he iron, sulfur. and other
impurities present "in the ore
concentrate.
  Primary copper smelting involves
three basic steps. First, the copper
sulftde ore concentrates an heated in a
roaster to remove a portion of the sulfur
contained in the concentrate. The solid
material produced by • roaster is called
"calcine." The calcine is loaded into
small rail ears (called "larry can"). This
operation is called "calcine
discharging.**
  The larry car* transfer itie cutcine to «
smelting furnace. At most smelters, raw
copper sulflde ore concentrate is
charged directly to the (melting furnace.
In the smelting furnace, the calcine or
raw. unroasted ore concentrate is
heated to form a molten bath containing
separate  layers of matte (an impure
mixture of copper and iron sulfide) and
slag (a mixture of nonmetallic
impurities). Molten slag is skimmed from
the upper layer of the bath and poured
from openings in the furnace walla
(called "ports") into inclined troughs
(called "launders"), which empty the
slag into a vessel mounted on a small
rail car (called a "flag pot"). This
operation is called "slag tapping."
Molten matte is poured from a aeeond
set of furnace port! into launder*, which
empty the matte into ladles. This
operation is called "matte tapping."
  The ladle ia transported by an
overhead crane to a copper converter.
The molten matte ia poured from the
ladle into a large opening on the top of
the converter vessel. Air is blown into
.'..v converter to first oxidise the iron
sulfide in the matte. The resulting iron
silicate slag is poured directly from the
converter mouth into a ladle. When all
of the iron i* oxidized and removed, the
remaining copper sulflde i* oxidized to
form a  high-purity copper product
(called'"blister copper"). The blister
copper ia poured directly from the
converter into • ladle for transfer to en
anode furnace (for further refining of the
copper) or directly lo the anode casting
area (for casting of the copper into
copper anode*).
  Roaster end ameltlng furnace ofljgeae*
ere produced by the combustion of fuel
and the reaction of materials ia the high-
temperature environments. Converter
offgases result from blowing air through
the matte end the reaction of materials
in the molten matte. Inorganic arsenic in
the ore concentrates is voletixed during
roasting, smelting, and converting, and
i* exhausted from the process
equipment in the
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ssra
Feds**!  Ragbtw / Vol. 4& No.  140 / Wednesday,  July  20. 1963 / Proposed Rules
thai BAT will remain in place and will
be property operated and maintained. A
primary consideration Is the existence of
other Federally enforceable standards. If
BAT is not In place on specific emission
points or if there is reason to expect that
BAT may not remain in operation, these
emission points are identified for
development of standards.
  The second step involves the selection
of BAT for the emission points at the
ASARCO-Tacoma smaller identified for
the development of standards. To select
BAT. regulatory alternatives are defined
based on demonstrated control
technology. The environmental.
economic and energy impacts of the
alternatives are determined. Based on
an auessmenl of these impacts,  one of
the alternatives is selected as BAT.
  The third step involves consideration
of regulatory alternative! beyond BAT
for all of the inorganic arsenic emission
points at the ASARCO-Tacoma smelter.
The risk of cancer incidence due to
inorganic arsenic exposure in the
population distributed around the
ASARCO-Tacoma smelter is estimated.
This estimated risk which remains after
application of BAT Is evaluated
considering costs, economic impacts;
risk reduction, and other impacts that
would result if a more stringent
alternative were selected. If the residual
risk is fudged not to be unreasonable
considering the other impacts or beyond
BAT controls, more stringent controls
than BAT  are not required. However, if
the residual risk is fudged to be
unreasonable, then an alternative more
stringent than BAT would be required.
Determination of the Adequacy of
Current Controls
  Inorganic arsenic emission sources at
the ASARCO-Tseome smelter are
currently controlled using a variety of
capture and collection techniques.
Capture techniques are used to gather
and confine secondary inorganic arsenic
emissions  and to transport them  to a
collection  device. Collection techniques
are used to remove Inorganic arsenic
from process offgaae* and captured
gases prior to venting the gases to the
atmosphere. Each taofgaaic arsenic
emission source at the ASARCO-
Tacoma smelter was examined by EPA
to determine the extent to which
inorganic arsenic emissions ere
currently controlled and whether the
level of control represents BAT.
  Controls currently in place at the
ASARCO-Tacoma smelter collect
inorgenic arsenic emissions in the
roaster, smelting furnace, converter, and
anode furnace process offgases. During
these process operations, inorganic
arsenic is volatilized and emitted as a
                         metallic oxide vapor in the process
                         offgases. By cooling the process
                         offgases. the inorgenic arsenic vapor
                         condenses to form inorganic arsenic
                         particulates. which can be collected in a
                         conventional paniculate control device.
                         Because of the high-inorganic-anenic
                         content of the feed materials process at
                         the ASARCO-Tacoma smelter, the
                         concentration of inorganic arsenic in the
                         process offgases greatly exceeds the
                         inorganic arsenic saturation
                         concentration at gas temperatures less
                         than 121* C (ZSO'F). Consequently, for
                         process offgases cooled to temperatures
                         below 121* C inorganic arsenic emission
                         control levels can be achieved that
                         approach the performamce capability of
                         a control device for collecting total
                         paniculate matter.
                          Roaster process offgases at  the
                         ASARCO-Tacoma smelter ere cooled to
                         e temperature less than 121* C and the
                         inorgenic arsenic particulates ere
                         collected in a baghouse. The smelting
                         furnace process offgasee are cooled to e
                         temperature of 92* C. and the inorganic
                         arsenic particulates are collected in an
                         electrostatic predpitator. Converter
                         process offgases are exheusted to e
                         liquid SOt plant or a single-contact
                         culfuric acid plant Because the presence
                         of solid and gaseous contaminants can
                         cause serious difficulties in the
                         operation of the SOt or add plants, the
                         converter process offgases are first
                         cleaned by passing the gasee through a
                         water spray chamber,  an electrostatic
                         precipitator. scrubbers, and mist
                         precipitators. This gas cleaning process
                         removes over 99 percent of the
                         contaminants, including inorganic
                         arsenic from the offgases prior to
                         entering the SOt or acid plants, in the
                         event that the volume of converter
                         process offgeses exceeds the capacity of
                         the SOt and add plants or when the
                         plants an not operating, the excess
                         converter offgasee ere diverted to en
                         electrostatic predpttator. This
                         electrostatic predpitator alao serves aa
                         the full-time control device for the anode
                         furnace process offgasee. Cooling of the
                         geses in the ducting lowers the gas
                         temperature to loss than 120* C prior to
                         entering the electrostatic predpitator.
                          Controls for inorganic arsenie
                         emissions from roaster, smelting
                         furnace, converter, and anode furence
                         process offgasee are IB place at the
                         ASARCO-Tacoma smelter m order to
                         comply with existing total parttoulete
                         emission regulations of the Puget Sound
                         Air Pollution Control Agency (PSAPCA).
                         These regulations an expressed in
                         tenns of very stringent process weight
                         paniculate emission limits. The
                         PSAPCA regulations an included as
                         part of the Washington State
implementation plan (SIP) for attaining
the Federal ambient air quality standard
for particulaie matter end therefore, are
Federally enforceable regulations.
  Roaster, smelting furnace, converter.
and anode furnace process offgases are
potentially significant sources of
inorganic arsenic emissions. Because of
the high inorganic arsenic vapor
concentrations in the process offgases HI
a high-arsenic-throughput smelter.
cooling of the offgases to below 121* C
results in condensetion of the vapor to
form psrticulstes. Thus, collection of the
inorganic arsenic pertieuiates in
properly designed and operated
particulate control devices can
effectively control the emission  to the
atmosphere of inorganic arsenic in the
process offgases. The types of control
systems currently used at the ASARCO-
Tacoma smelter to collect inorganic
arsenic from process offgases achieve
inorganic arsenic collection efficiencies
greater than 96 percent.
  The control systems in place et the
ASARCO-Tacoma smelter to control
roaster, smelling furnace, converter, and
anode furnace process offgss inorgenic
arsenic emissions represent the best
demonstrated level of control
considering economic feasibility.
Therefore, the roaster, smelling furnace.
converter, and anode furnace process
offgases are already controlled  using
BAT. Existing Fedeselly enforceable
regulations require the controls to
remain in place and to be properly
operated and maintained to reduce total
paniculate matter emissions. These
regulations serve to assure that BAT for
inorganic arsenic will remain in place.
Therefore, additional standards based
on BAT are not  necessary at this time
for smelter roaster, smelting furnace.
converter, or anode furnace process
offgases.
  Existing controls in place at the
ASARCO-Tacoma smelter significantly
reduce the quantity of inorganic arsenic
emissions from the arsenie trioxide and
metallic arsenic manufacturing
processes. Arsenie laden offgases from
the Godfrey roasters pass through the
arsenic kitchens when arsenic  trioxide
condenses OB the walls of the chambers
and is collected as a product Gases
Dossing through the kitchens an vented
to a baghouse. The temperature of the
gases at the inlet to the baghouse is less
than 121* C Offgases from the metallic
arsenic furnaces are also vented to the
same baghouse. inorganic arsenic
emission points at conveyors, charge
hoppers, storage bunkers, and the
barreling and carioading stations are
controlled by capturing the emissions
using local hoods and venting the
-------
               Federal Register / Vol. 46. No.  140 / Wednesday. |uly 20. 1983 / Proposed Rules
                                                                    3312
emissions to several small baghouaes.
These control* are in place at the
ASARCO-Tacoma smelter to comply
with PSAPCA arsenic and paniculate
regulations and with the U.S.
Occupational Safety and Health
Administration (OSHA) inorgitnic
arsenic worker exposure standard
  The composition of thrtotal
paniculate matter emiasiont from the
arsenic manufacturing processes at the
ASARCO-Tacoma smelter is inorganic
arsenic particulates. All inorgHnic
Mrsenic emission points are controlled
by collecting the paniculate emissions
using baghouses. The major process
offgae streams are combined and vented
to a new baghouse installed in 1982. The
baghouse design represents the most
advanced level of paniculate matter
collection technology demonstrated to
Hale. Additional reduction inorganic
arsenic emissions is not possible using
available control technology. Therefore.
EPA considers the controls at the
ASARCO-Tacomfc smeller arsenic
manufacturing plant to be BAT. Since
these controls are required by Federally
enforceable regulations. EPA is not
developing additional BAT standard*
for arsenic manufacturing processes at
this time.
  The major source of secondary
arsenic emissions at the ASARCO-
Tacoma smeller it the convener
operations. ASARCO has recently
installed a prototype control system on
one of the three converters used at the
smeller for copper converting
operations. (A  fourth converter is used
as -  Hiding furnace only.) A secondary
hood system consisting of a fixed
enclosure with a horizontal air curtain i*
used to capture the secondary inorganic
arsenic emission*. The captured
emissions are vented to an electrostatic
preeipitator (designated by ASARCO as
the No. 2 ESP}. The company i* planning
to install similar secondary hood
system* on the other two converters end
to vent the captured emissions to the
No. 2 ESP. However, regulation* do not
exiat that would specifically require the
use of BAT to limit eeeondary inorganic
arsenic emiaaiona from converter
operations. Became of the potential lor
converter operation* to enit urge
quantities of eecoodary inorganic
arsenic, and becauee of the
demonstrated availability of controb for
the*e emission* EPA decided to develop
atandarda baaed, aa a minimum, on BAT
for secondary inorganic areenic
emiaaiona from converter operation*.
  Smelting furnace secondary inorgmnic
arsenic emiaaiona from matte tapping
and alag tapping are captured and
collected at me ASARCO-Ts
smelter. Copper matte or slag flows from
ports in the furnace walls through a
launder which directs the molten
material to a point where it is
transferred to a ladle or slag pot. At the
ASARCO-Tacoma smelter, the matte
tapping launders are enclosed by
semicircular covers. Slag lapping
launders are covered by fixed hoods
mounted above the troughs. Local
exhaust hoods are mounted about 1
meter (3 feet) above each tap port At
each launder-to-iadle transfer point for
matte tapping, a retractable exhaust
hood is used to capture emissions
generated at the ladle. An overhead
crane places the ladle on the floor in
front of the launder. The hood is then
lowered over the ladle prior to tapping
and is raised after the tap ia complete.
The overhead crane returns and picks
up the ladle of molten matte for transfer
to the converters. At each launder-to-
slag pot transfer point for sleg lapping.
large fixed exhaust hoods are mounted
above the slag pot transfer point The
captured secondary emissions from
matte tapping and slag tapping at e
vented to the No. 2 ESP.
  At the ASARCO-Tacoma smelter, all
emission points from smelting fumade
matte tapping or slag tapping are
enclosed or are covered by local
exhaust hoods. In EPA's judgment, this
capture system, if properly operated and
maintained, represents BAT for capture
of secondary emissions from smelting
furnace matte tapping and slag tapping
because no other demonstrated
technology can achieve a higher level of
capture efficiency. The capture system
ia in  place to fulfill a tripartite
agreement between ASARCO. OSHA.
and the United Steelworkers of America
(union representing workers at the
ASARCO-Tacoma smelter). The
   itroU
specific* the engineering
>d worker
cttcestobe
imptemeoted at the ASARCO-Tacoma
amaltar far achieving compliance with
the Federal OSHA inorganic arsenic
worker exposure standard and.
therefore, la Federally enforceable.^
Although not apeclfwd in the agreement.
the captured secondary Inorganic
                   > vented to an
The (aval of performance of this control
device la equivalent to the level of
performance of BAT for collection of
              ic amnk emissions.
  A haa no reeeon to betteva thai
ASARCO will not eonttoo* to property
operate and memtatam* electrostatic
that BAT is to place at me ASARCO-
Taooma smelter for captor* and '
collection of secondary Inorganic
arsenic emissions from smelting furnao
matte tapping and slag tapping.
  Roaster secondary inorganic arsenic
emissions from calcine discharge are
also captured and collected at th
ASARCO-Ttcoma smelter. Cat
gravity loaded into larry cars f
hoppers located at the bottom o
roaster. An exhaust hood is mounted o
either side of each hopper. A spring-
loaded top having three small openingi
covers each larry car. When the larry
car is positioned under the hopper, the
opening* in the car top align with the .
hopper outlet and the two exhaust
hoods. Because the top is spring-loadei
a tight connection is achieved between
the top and the hopper outlet and hood
During loading, an induced draft fan is
activated to ventilate the space under
the car top and to capture the emissior
generated by the loading operation. Th
captured secondary emissions are
combined with the roaster offgases pri
to venting to the baghouse. In addition
10 the local hoods located at the calcir
discharge point the calcine hopper an
is enclosed to form a tunnel-like
structure. This area is ventilated with
the exhaust air being combined with t
exhaust air from the local exhaust
hoods.
  The capture system used at the
ASARCO-Tacoma smelter for capturi
secondary inorganic arsenic emis on.
from roaster calcine discharge '
most advanced technology
demonstrated. In EPA's judgme     i
system represents BAT. Similar to thi
controls in piece at :he ASARCO-
Tacoma smelter for smelting furnace
matte tapping and slag tapping, the
calcine discharge capture system is ir
place to fulfill the tripartite agreemen
achieve the OSHA inorganic arsenic
worker exposure standard. The captu
secondary inorganic arsenic emission
are vented to the baghouse which hai
been determined to be BAT for
collection of inorganic arsenic emissi
from the roaster process offgases.
Therefore. BAT ia in place auhe
ASARCO-Taeoma smeller for captur
and collection of secondary inorganii
emissions from roaster calcine
discharge.
  To control secondary inorganic
arsenic emissions from the handling
transfer of flue duet the ASARCO-
Tacoma amaltar has implemented d*
bast control practice* available. All
conveyor systems are enclosed In d\
tight housings. Hopper and storage t
art equipped with dint lava) indicate
Dust-tight connection* are used to
transfer material from hopers and bi
to vehicles. This equipment Is
fulfill the tripartite agreement
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J3128
Federal  Regular  /  Vol. 48,  No. 140  /  Wednesday. July 20.  1983 / Proposed Rules
the OSHA worker exposure standard.
Because BAT is already required in
order to comply with existing Federal
regulations, additional standards based
on BAT are not necessary at this time
for miscellaneous sources of secondary
inorganic arsenic emissions at high-
arsenic-throughput smelters.
  The anode fumances in operation at
the ASARCO-Tecoma smelter are of an
atypical design that Is not used at
anyother primary copper smelter located
in the United States. Secondary
inorganic arsenic emissions (perhaps up
to 0.1 kg/h) escape to the atmosphere
from a large opening in the anode
furnace wall This opening allows the
fumance operators to perform activities
necessary for refining the blister copper.
Secondary inorganic arsenic emissions
from the anode furnace could
conceivably be captured using an
elaborate secondary hood system.
However, the effectiveness of such a
theoretical capture system is uncertain
considering the design of the anode
furnaces and the nature of operations
required to operate the furnaces. EPA
believes that any capture system
designed to provide the necessary
access to the anode furnaces would
impose very high costs. Based on the
email reduction in total smelter
inorganic arsenic emissions that would
be expected to result from controlling
anode furnace secondary emissions, it is
EPA*i judgment that the coats for
installing controls to capture the anode
furnace secondary inorganic arsenic
emissions are excessive. Therefore. EPA
IM* determined that  the existing
equipment represents BAT and, as a
result ho standards are being developed
at this time for secondary inorganic
arsenic emissions from anode furnaces.
  In summary, roaster, smelting furnace.
end converter process  offgeses aa well
aa anode furnace, arsenic plant aad flue
dust handling sources are Judged to be
currently controlled using BAT. Also.
secondary inorganic emissions from
roaster calcine discharge, end smelting
furnace matte tapping  and slag tapping

These controls an required by existing
Federally enforceable  reguletions or are
expected by EPA to remain la place and
to be properly operated and maintained.
With the exception of the prototype
secondary hood on one converter, no
controls are currently la place to limit
secondary emissions from the
converters. Therefore, because cepture
technology has been demonstrated. EPA
decided to develop standards based, as
a minumum. on BAT for secondary
emissions from converters.
Selection of BAT for Converter!

  Control Technology. Primary
converter hoods capture process
emissions during converter blowing
periods: but. during charging, skimming.
holding, or pouring operations, the
mouth of the converter is no longer
under the primary hood, and converter
emissions escape cepture by the hood.
There ere three alternative control
methods for capturing secondary
emissions from converter operations: (1)
fixed end retractable secondary hoods.
(2) air curtain secondary hoods, and (3)
building evacuation.
  Four domestic smelters currently use
fixed secondary hoods to capture
converter secondary emissions. These
hoods are attached to the upper front
side of the converter primery hoods.
Mora complex retractable secondary
hood designs an used et one domestic
smelter and smelters in (epen. Visuel
observations made at two domestic
copper smelters showed that fixed end
retractable  secondary hoods captured a
portion of the secondary emissions from
converter operations. However, the
capture efficiencies of existing fixed and
retractable  secondary hood designs an
fudged by EPA to be leu than 90
percent
  A more advanced method for the
capture of converter secondary
emissions is the use of aa air curtain
secondary hood Walls an erected to
enclose the aides aad the back of the
ana around the converter mouth. A
portion of the enclosure beck well is
formed by the primary hood Openings
at the lop aad la the front of the
enclosure ellow for movement of the
overheed crane cables aad Mock, and
the ladle. Edgee of the wells in contact
with the primary hood or the converter
veeaal an sealed A broad horizontal
eirstreem blows across the entire width
of the open space et the top of the
enclosure. Tale airstreamts called an
-eir curtain." The air curtain is produced
by blowing compressed air from a
narrow horizontal slot extending the
length of a plenum etong the top of one
of the side walla. The eir is directed toe
receiving hood along the top of the
opposite aide well An Induced draft fan
la the ducting behind the receiving hood
palls the airs tream into the hood. When
the converter ia tolled out away from

skimming, or pouring, the air curtain
aweepa the converter oflgasee and
emissions which an generated by
materiel transfer between the converter
and the ladle into the receiving hood
The captured emissions an then vented
to a collection device or released
                                                               directly to (he atmosphere through a
                                                               stack.
                                                                 The air curtain secondary hood has
                                                               been demonstrated as an effective
                                                               method for capturing converter
                                                               secondary emissions. For the past 3
                                                               years, air curtain secondary hoods ha'
                                                               been in place to control converter
                                                               secondary emissions at copper smelie
                                                               in Japan. A prototype eir curtain
                                                               secondary hood was installed in 1561
                                                               one of the converters et the ASARCO
                                                               Tecoma smelter.
                                                                 in January 1983. EPA conducted e t<
                                                               program designed to eveiuate the
                                                               effectiveness of the capture of
                                                               secondary emissions by the prototype
                                                               eir curtain secondary hood at the
                                                               ASARCO-Tecoma smelter. The captui
                                                               efficiency of the system was evaluate!
                                                               by performing e ges tracer study end
                                                               visuel observations. The gas tracer
                                                               study involved injecting a gas tracer
                                                               inside the boundaries of the fixed
                                                               enclosure end meesuring the emount i
                                                               the ges tracer in the exhaust gases in
                                                               ducting downstream of the enclosure
                                                               receiving hood The capture efficiency
                                                               wee then calculated by a material
                                                               balance of the inlet and outlet tracer \
                                                               mass flow rates. Based on the results
                                                               this test program, EPA believes en air
                                                               curtain iecoadary hood-is capable of
                                                               achieving an overall capture efficienc
                                                               of 99 percent
                                                                 Capture of converter secondary
                                                               emissions by building evacuation ia
                                                               accomplished by coatrolling the alrflc
                                                               pettems within the building housing i
                                                               converters end by maintaining a
                                                               sufficient air change or ventilation ral
                                                               Control of airflow in the ventilated ar
                                                               is obtained by isolating it from other
                                                               arees aad by the proper design and
                                                               placement of Inlet end outlet opening;
                                                               Proper location and sizing of Inlet em
                                                               outlet openings provide effective eirfl
                                                               patterns so that the secondary emissi
                                                               cannot escape to adjacent areas or
                                                               redrculete within the aree.
                                                                 EPA believes thet a well-designed
                                                               building evacuation system should b<
                                                               capable of achieving at least 96 perci
                                                               capture efficiency of secondary
                                                               emissions. However, the building
                                                               evacuation systems currently used In
                                                               aoa-ferrotis metallurgical industry hs
                                                               not demonstrated this level of contra
                                                               building evecaatlon system Je being
                                                               vaed at the ASARCO copper, lead at
                                                               zinc smelter located la El Paso, Taxe
                                                               to capture eecondary emissions from
                                                               copper converters and a zinc smeltin
                                                               furnace operated inside a building.
                                                               While preventing the venting of
                                                               secondary emissions to the ambient
                                                               outside the building, see of the build
                                                               evacuation system at the ASARCO-:
-------
               r goers, i
                                 /  vgi.
                                                       *OCV4«t«*««<>*iji J*»>,f  <*>•"
Paso smelter hat resulted in etareted
concentrations of inorganic arsenic
lead and SO*, inside the building in
addition to excessive heat buildup. To
alleviate these unacceptable working
conditions, building openings have been
increased and roof ventilators designed
for emergency use only have been
operated routinely. As a result of
increasing the number of building
openings, the capture efficiency of the
building evacuation system has been
decreased. The building evacuation
system as presently operated at the
ASARCO-E1 Paso smelter achieves a
capture efficiency of less than 95
percent.
  The control technology for the
collection of secondary inorganic
arsenic emissions is based on the
cooling of the exhaust gases to condense
the inorganic arsenic vapors to form
particulates. and the subsequent
collection of the inorganic arsenic
purticulatea in a conventional
paniculate control device. Beghouse and
electrostatic precipitator control devices
are currently used at primary copper
smelters to collect secondary inorganic
arsenic emissions as well as paniculate
matter emissions.
  To evaluate the efficiency of a
conventional paniculate control device.
EPA tested the baghous* in place at the
ASARCO-E1 Paso smelter used for the
collection of secondary emissions from
the converters. Emission measurements
for inorganic arsenic end total
participates were conducted at the
r*«t,house inlet and outlet for three test
runs. At the baghouse outlet Inorganic
arsenic concentrations ranged from
0.015 to 039 milligram per dry standard
cubic meter of exhaust gat (mg/dscm).
The corresponding total paniculate
concentrations at the baghouse outlet
ranged from 1.1 to 11.8 mg/dscm. Cea
temperatures et the baghouse inlet were
leaa than SO*C (112*F). The inorganic
arsenic collection efficiency was over 99
percent for two of the test rune end wet
greater then 94 percent for the third test
ran. The teat molts showed that the
overall average inorganic ersenic
collection effldemy of the beghouse for
three test run* was 96 percent EPA
concluded from the tests  that a properly
designed, operated, end maintained
baghouse or equivalent paniculate
control device can achieve e collection
efficiency of et leeet 98 percent for
inorganic aiyenic.
  Regulatory Alternatives. To determine
the level of control that reflects BAT for
control of converter secondary
emissions, technical alternatives were
identified for reducing inorganic arsenic
emissions from the ASARCQ-Tacoma
smelter.
  For the purpose of analysis, these
alternatives are identified here and in
the background information document
as Regulatory Alternatives I and II. For
Regulatory Alternative 1. no national
emission standard would be established
for inorganic arsenic emissions from
high-arsenic-throughput smelters. No
additional controls beyc.id the controls
already in place at the ASARCO-
Tacoma smelter to comply with existing
regulations (e.g. Washington Slate
implementation plan. OSHA inorganic
arsenic worker exposure standard)
would be required. Regulatory
Alternative I corresponds to the
baseline level of control.
  Regulatory Alternative II represents
control of secondary inorganic arsenic
emissions from convener opertions et
the ASARCO-Tacoma  smelter. This
alternative is besed on capture of the
secondary emission* using a secondary
hood consisting of a fixed enclosure
with e horizontal eir curtain. The
captured secondary emissions would be
vented to e baghouse or equivalent
control device for collection.
  Regulatory Alternative I (beseliae
case) would not change the existing eir
end non-eir quality environmental
impacts of operations el the ASARCO-
Tacoma smelter. Total inorganic arsenic
emissions from the ASARCO-Tacoma
smelter would remain at the current
level of 282 Mg (311  tons) per year. In
addition, there would be no energy or
economic impacts associated with  this
alternative.
  Regulatory Alternative 0 would
reduce total inorganic arsenic emissions
from the ASARCO-Tscoma smelter by
110 Mg (121 urns) per year to e level of
172 Mg (189 tons) per year. The amount
of collected paniculate matter
containing Inorganic arsenic would be
approximately 11 gigagrams (Cg) (11000
tons) per veer. This would Increase the
amount of solid waste generated et the
ASARCO-Tacoma smelter from 182 lo
193 Cg (2004100 to 2UOOO tons) per year.
•n Increase of •bout 8 percent. The
additional solid waste can be handled
by the smelter's existing solid waste
disposal system. Because the alternative
is based on use of en electrostatic
precipitator. • dry paniculate collection
device, there would be no water
pollution impact
  The energy Impacts of Regulatory
Alternative II would be increeaed
electrical energy consumption. To
operate the control system specified by
the alternative, annual electrical energy
consumption would be 1.3X10*
kilowatt-hoars per year (KVVh/y). Total
 smelter energy consumption is
 approximately 2.9X10* kWh/y. Thus.
 Regulatory Alternative II would increc
 the total ASARCO-Tacoma electrical
 energy consumption by 0.5 percent.
   The capital costs for installing the
 control system specified by R       r
 Alternative II is $3.5 million.
 represents a major capital ex       f
 for ASARCO. However. ASARCO is i
 major publicly held corporation with •
 good credit rating and good access to
 financing. Even considering the
 possibility of additional capital
 expenditures for control equipment fc
 the two ASARCO low-arsenic-''
 throughput smelters (the ASARCO-El
 Paso sod Kayden primary copper
 smelters are addressed in Pert III of t
 preamble), it is EPA's determination I
 ASARCO would be able to obtain thi
 necessary capital lo install the contn
 system at the ASARCO-Tacoma
 smelter. The annualized cost lo
 implement Regulatory Alternative II
 estimated to be S1J million. If ASAR
 chooses to ebsorb the costs by reduc
 its profit margin, toe profitability of I
 ASARCO-Tacoma smeller could be
 reduced up to 0 percent If ASARCO
 chooses to maintain its normal profit
 margin and attempts to recover the i
 by increcsing copper prices, the pric
 increase would amount to 04 to 04
 percent
   In summary, under Regulstory
 Alternative IL total smeller      i
 arsenic emissions would be
 39 percent from 282 Mg per
 Mg per year. The reduction in em
 would be achieved with • small Inc
 in the amount of solid waste genera
 at the smelter. There would be no *
 pollution impact Energy consumpu<
 the smelter would be slightly increa
 The primary economic impacts
 associated with this alternative are
 prelected modest decrease In
 profitablity for the ASARCO-Tacoc
 smelter and a possible small increa
 the price of copper, to EPA's (udgrn
 this alternative would not adverse!
 affect the economic viability of the
 ASARCO-Tacoma smelter or
• employment at the smelter. Becaus
 significant reduction In inorganic
 arsenic emissions from the ASARC
 Tacoma smelter is achievable with
 reasonable economic, energy, and
 air quality environmental impacts.
 selected Regulatory Alternative II
 BAT.
   it should be noted that the level
 control selected as BAT is  based t
 the Adminstrator's best judgemen
 the information available at this M
 As discussed later, comments and
 information are being request    o
-------
33190
rooenj Register/  voi.  +0.
                                                                  *«'/
 additional control measure*. The final
 dedaion on BAT will reflect
 consideration of these comments and
 may. therefore, include measure* (e.g..
 production curtailments or Improved
 operating and housekeeping practices)
 which are not now Included in
 Alternative II.

 Consideration ofEmittion Reduction
 Beyond BA T end Decition on Boii* for
 Pnpoted Standard*.
   After Identifying BAT. EPA
 considered the estimated residual health
 risks and possible control alternatives
 that would reduce emissions to rales
 lower than that achievable with BAT.
 The health risk is expressed by the
 number of incidences of cancer due lo
 inorganic arsenic exposure in the
 population distributed around the
 ASARCO-Tacoma smelter. Based on
 epidemiologies! studies. EPA derived a
 unit risk number for exposure to
 airborne inorganic arsenic The unit risk
 number is a measure of potency
 expressed ss the probability of cancer in
 a person exposed to 1 ug/m • of
 airborne inorganic arsenic for a lifetime
 (70 yean). Annual cancer inddence (the
 number of cases per year) associated
 with Inorganic arsenic emission* from
 »he ASARCO-Tacoma smeller is the
 product of the total population exposure
 around the smelter and Ihe unit risk
 number divided by 70 yean. Total
 exposure is determined by dispersion
 modeling estimates of the inorganic
 arsenic concentration in the ambient air
 surrounding the smeiter combined with
 data for the distribution of Ihe estimated
 "".ODD people living within about 20
 kilometers (124 miles) of the ASARCO-
 Tacoma smelter. For the current level of
 inorganic arsenic emission* from Ihe
 ASARCO-Tacoma smelter, the annual
 cancer inddence i* estimated to range
 from 1.1 to 174 ease* per year. With
 BAT In place et the ASARCO-Tacoma
 smelter for all of the significant
 inorganic asenic emission point* it is
 estimated that die annual cancer
 Inddence would be reduced lo a range
 of 04 to 3.4 case* par year. Application
 of BAT would reduce) the estimated
 maximum lifetime risk from exposure to
 airborne inorganic arsenic from a range
 of 2J to 37 in 100 to a range of 048 lo 9.2
 in 100. The maximum lifetime risk
 represents the probability of a person
• contracting cancer who has been
 continuously exposed during a 70-year
 period to the maximum annual inorganic
 arsenic concentration duo to inorganic
 •ramie emissions from the ASARCO*
 Tacoma smelter.
   All known control alternative* wen
 examined with the particular emphasis
 on the further contol of secondary
                                      emissions, which on the baiis of
                                      modeling remit*, cause the highest
                                      ambient exposure and resultant health
                                      risks. This examination, which included
                                      evaluation of controls used on smellers
                                      in both the United Stales and Japan as
                                      well as the possibility of technology
                                      transfer from other source categories.
                                      identified no demonstrated
                                      technological controls more efficient
                                      than thoM Identified as BAT. Therefore.
                                      the remaining alternatives an limited  to
                                      two basic categories: (1) production
                                      Umltetlons or curtailments and (2)
                                      limitations on the smeller Inorganic
                                      arsenic throughput.
                                      Impact* of Control* Beyond BA T
                                        Without specific and detailed
                                      knowledge of all economic information.
                                      which is known only to ASARCO. EPA
                                      cannot estimate with certainly the
                                      extent to which production curtailment
                                      or limitation on inorganic arsenic feed
                                      rale may be affordable. The smelter is
                                      currently operating under a production
                                      curtailment program designed to limit
                                      ambient sulfur dioxide (SOt) levels. This
                                      program, which EPA believes to achieve
                                      at least a corresponding effect on
                                      ambient inorganic arsenic
                                      concentrations, currently results in
                                      production curtailment of approximately
                                      30 percent. When converter controls an
                                      In place, the amount of curtailment
                                      needed may be less but is expected to
                                      be not less than 20 or 2S percent. Thus.
                                      while further curtailments may be
                                      possible, it is doubtful that the degree  of
                                      curtailment necessary lo significantly
                                      reduce risk (e.g, a SO percent additional
                                      curtailment would reduce the estimated
                                      maximum risk from a range of 0M to fl-2
                                      in 100 to a range of O28 to 44 In 100)
                                      would be affordable.
                                        An analysis of the importance of high*
                                      inorganic-arsenic feed to the economic
                                      viability of the ASARCO-Tacoraa
                                      smelter loads to the conclusion that the
                                      smelter would probably dost if high-
                                      inorganic-arsenie-contact materials
                                      could not be processed. High*inorganic>
                                      anenic-content copper on concentrate
                                      and lead smelter by-products represent
                                      •bout one third of the feed material
                                      Input to the ASARCO-Tacoma smelter.
                                      If forced to discontinue use of these feed
                                      materials. ASARCO would need to
                                      compete with other copper smelling
                                      companies for additional supplies of
                                      copper on. In the bee of Japanese
                                      competition and current copper on
                                      shortages, it is questionable whether
                                      sufficient supplies of low-ersenic-
                                      eontent copper on concentrate could be
                                      obtained at prien that would allow
                                      profitable operation. Mora Importantly.
                                      the use of hlgh-inorganlc-arsenic feed
                                      allow* ASARCO to produce arsenic
                                                              trioxide and metallic arsenic. EPA
                                                              estimate! that the tale of arsenic
                                                              trioxide and metallic arsenic represent!
                                                              about 10 to 15 percent of the ASARCO-
                                                              Tacoma smelter's total revenue and
                                                              could account for most of the profit.
                                                              Therefore, for purposes of this analysis.
                                                              EPA is concluding that any potential
                                                              means for limiting inorganic arsenic
                                                              emissions to the extent necessary to
                                                              significantly reduce risks would result i
                                                              dosure of the ASARCO-Tacoma
                                                              smelter.
                                                                The arsenic produced by the
                                                              ASARCO-Tacoma smelter supplies
                                                              about one third of the total nationwide
                                                              demand for arsenic. The remaining two
                                                              thirds is Imported and represents over
                                                              half of the world production outside thi
                                                              U.S. If ASARCO-Tacoma stopped
                                                              production of arsenic, the world arsenii
                                                              production capacity would have to
                                                              increase by 25 percent to makeup the
                                                              shortage, it is considered doubtful that
                                                              such  an increase would be possible eve
                                                              with substantial upward price pressure
                                                              The impact that this shortage would
                                                              have on industrial products (e.g..
                                                              pressure ireeied lumber) and
                                                              agricultural uses (e.g- cotton desiccant:
                                                              herbicides) has not been estimated.

                                                              Contideration of Health Ri*k*

                                                                As detailed in Section I of this
                                                              preamble, the estimated health risks
                                                              cited above associated with exposure i
                                                              ambient inorganic arsenic are at best
                                                              only a very crude estimator of the sctui
                                                              health effects. The degree of uncertain!
                                                              in these estimate is very large because
                                                              of the many assumptions and
                                                              approximations involved in their
                                                              derivation. Nevertheless, the estimated
                                                              risks due lo emissions from the
                                                              ASARCO-Tacoma smeiter are high
                                                              relative to other inorganic arsenic
                                                              source* and to other sources of
                                                              hazardous pollutants that have been
                                                              regulated. These levels, therefore.
                                                              provide a basis for serious question  as
                                                              to whether limiting emissions based on
                                                              BAT would protect public health and .
                                                              provide an ample margin of aafety.
                                                              Moreover, direct ambient exposure is
                                                              not the only potential health impact
                                                              since the Inorganic arsenic emitted Inti
                                                              the atmosphere accumulates on land
                                                              and In water resulting in other avenuei
                                                              of exposure. It should be noted that
                                                              primarily due to arsenic, the
                                                              Commencement Bay Near Shore Tide
                                                              Plata area (which includes the
                                                              ASARCO-Tacoma smelter) has been
                                                              proposed as a National Priority Us! Sii
                                                              by EPA under the Superfund program
                                                              (47 PR 58479, December 30.1882).
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Consideration of Impact* of Beyond
BAT

  Closure of the ASARCO-Tacoma
smelter would resultln severe social
and economic impact on the local
economy. Moreover, since the
ASARCO-Tscoma smelter is the only
domestic smeller capable of smelting
high-impurity copper ores and
production of associated by-products
including arsenic, closure of (he smeller
would result in a total toss of this
domestic production capability. Closure
of the smeller would eliminate the fobs
of about 500 ASARCO employees and
300 additional fobs ta the Trr—-• ••»*
Closure would also mean elimination of
$20 million per year in revenues to local
companies and $2 million per year in
Slate and local taxes.

Dfcition and Proposed Standards
  As detailed in Part 1 of this preamble.
under EPA's interpretation of Section
112. the smeller should be controlled at
least to the level thai reflects BAT and
to a more stringent level if necessary to
prevent unreasonable risk*. The
decision as to whether th* remaining
riaka are  unreasonable is based upon
consideration of the individual and
population risks and consideration of
the impacts, including costs, economic.
and other impacts associated with
further reduction of these risks.
  The primary purpose of standards
promulgated under Section Itt is to
protect th« public health. Th*
Administrator is concerned that the
estimated residua) risk after application
of BAT at ASARCO-Taeoma may be
u»t«asonabla. and. as such. ut*t
additional controls beyond BAT may be
warranted. As indicated earlier. EPA
has not identified technological controls
more efficient than BAT: therefore, ta
making a decision on an appropriate
control level of ASARCO-Taeoma. the
Administrator's consideration of beyond
BAT alternatives was limited to
  •eduction and arsenic throughput
 mitationa. These control measures
could further reduce amiestons of
inorganic arsenic aad associated health
risks. Arseate throughput for example.
could be limited to a level comparable
to a low-artento-throughput smeller
(less than 0.7 percent Inorganic araen'r
in th* total smelter charge), although
estimated health risk* would still be
expected to be higher for ASARCO-
Tacoma than for th* other smelters due
to its location in a highly populated
area.
  The Administrator believes that
control beyond BAT could result in
closure of the ASARCO-Taeoma
smelter. This would reduce th* smelter
E
                                                            contribution to the estimated health
                                                            risks to xero: but would also result in a
                                                            loss of jobs, a loss of domestic
                                                            production capacity in both the copper
                                                            and arsenic industries, and a loss of
                                                            revenues to local businesses and
                                                            governments. Certainly the impacts
                                                            associated with closure of the smelter
                                                            would be felt directly and immediately
                                                            by the local population, particularly the
                                                            employees of the smelter. With these
                                                            potential serious negative impacts, a
                                                            decision to require beyond BAT controls
                                                            must be carefully considered.
                                                              Given that the calculated health risks
                                                            estimated to remain after the application
                                                            of BAT would be the basis for a decision
                                                            to require beyond BAT controls and. in
                                                            this case, possibly causa closure of the
                                                            ASARCO-Tacoma smelter, the
                                                            Administrator believes it is necessary to
                                                            scrutinize the basis for these calculated
                                                            estimates as a part of the decision-
                                                            making process. The estimated health
                                                            riaka were calculated by combining a
                                                            unit risk estimate for inorganic arsenic
                                                            with the ambient concentrations of
                                                            inorganic arsenic predicted by modeling
                                                            and with population data for the area
                                                            surrounding the ASARCO-Tacoma
                                                            smelter. Aa discussed IB Part I of this
                                                            preamble and Appendix E of the BtO.
                                                            there an simplifying assumptions and
                                                            fundamental uncertainties inherent in
                                                            each of the components of the
                                                            calculation, resulting in a number of
                                                            uncertainties in the risk estimates.
                                                              Uncertainties in the unit risk estimate
                                                            exist due to a number of simplifying
                                                            assumptions. Among these is the
                                                            assumption that a linear relationship
                                                            exists between cancer risks and level of
                                                            exposure aad this relationship is the
                                                            same at the low levels of public
                                                            exposure as at the high levels of
                                                            occupational exposure. There ta no solid
                                                            scientific basis for any mathematical
                                                            extrapolation model that relates
                                                            carcinogen exposure to cancer risk at
                                                            the extremely low concentrations that
                                                            must be dealt with ta evaluating
                                                            environmental hazarda, Because its
                                                            scientific basis, although United, to the
                                                            best of any of the current mathematical
                                                            extrapolation models, the linear
                                                            nonthreshold modal baa bean adopted
                                                            bare as the primary basis for risk
                                                            extrapolation at low levels of exposure.
Additional

                                                                                      to tha
                                                            determination of the ualt risk estimate
                                                            are that all people ere equally
                                                            susceptible to cancer aad that persons
                                                            •re exposed continuously from birth
                                                            throughout their lifetimes (70 yean). The
                                                            Administrator believes that the
                                                            assumptions made ta determining the
                                                            unit risk estimate are reasonable for
                                                            public health protection ta thai they lead
to a rough but plausible estimate of the
upper-limit of risk. That is. it is not like!
that the true unit risk would be much
more than the estimated unit risk, but ii
could be considerably lower.
  Uncertainties in the ambient modelin
exist due to the limitations of th
dispersion model and the ass
end potential error in (he data i
the model. Limitations in the m
include its inability to account for the
variable operating condition* of the
smelter and variable meteorology, that
is. one  sat of operating and
meteorological conditions was assume
for modeling purposes. The
meteorological conditions used are
believed to be representative. Howeve
th* smelter operating conditions used I
the modeling do not account for the
frequent curtailment of operations no*
required at ASARCO-Tacoma to redui
emissions of sulfur dioxide, and
therefore, probably result la an
overestimate of ambient air
concentrations of inorganic arsenic
(since arsenic emissions would be
reduced as well). Also, the model doe!
not account for sources of arsenic ouY
than th* ASARCO-Tacoma smelter th
are ta the ana.
  In addition, there wan many toouu
the mod*! such as location of each
emission source at the smelter and tb
rat*, temperature, and height at whicl
those emissions an released to th*
atmosphere. Each of these teput
parameters is subject to error.
perhaps the most crucial
th* estimate of emission rates.
•mission rates used by EPA ware bai
on actual emission test data wheaevi
possible. Howtver. for some sources,
moat notably converter secondary
•missions, test data were not availat
at the time the estimates were made:
therefor*, some aMumptions wan m
for modeling and impact analysis
                                              ling a
                                              . The
purpoaea. The EPA assumed, for
instance, that converter secondary
Inorganic arsenic emissions were
approximately 15 parotat of those
measured ta th* primary converter
oflgaaa*. Preliminary results of testii
conducted la January 1883 oa coavw
No. 4 at ASARCO-Tacoma indicate
emissions may be significantly lass '
this.
  Additional uncertainties arise froi
th* us* of population data. Th* p*o|
d*alt with ta th* analysis an not
located by actual residence. They a
located" ta the Bureau of Census d
for 1970 (th* most recent available)
population centraids of census disti
Th* effect is that th* actual tocatiof
residences with respect to the  estin
•mbient air concentrations is aot ki
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and the relative locations used in the
exposure mod«J have changed lince the
1970 census. In addition, it it anumed
that people remain in the wmt location
for a lifetime (70 yean), the only
expoaurt of the population that occuri it
due to the ASARCO-Tacoma imelter.
and only persons within 20 kilometers of
the emission source are affected.
.  In summary, there is a high degree of
uncertainty in the estimated health risks
due to the many assumptions and
uncertainties associated with the
components of the estimates. While the
estimated risks aay be meaningful in a
relative sense, they should not be
regarded as accurate representations of
true cancer risks. Furthermore, it should
be noted that (1) ambient monitoring
data available for the Tacoma area
show significantly lower ambient
concentrations of inorganic arsenic than
those predicted by the model, and (2)
data on lung cancer incidence rates for
the ten largest cities in Washington for
the years 1970 through  1979 show that
Tacoma ranks filth, and the lung cancer
rates in Tacoma are below the national
average lung cancer rate.
  In light of the high degree of
uncertainty in the estimated health
risks, the apparent absence of further
control alternatives short of closure, the
serious negative impacts associated
with closure, and the absence of
comments from the affected public, the
Administrator cannot conclude el this
lime that the risks remaining after the
application of BAT an unreasonable.
Therefore, standards are being proposed
for the category of high-arsenic*
th"»
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 moif anic-artenic-conlent ore
 concentrate has the potential for higher
 inorganic arsenic emiuioni than a tow-
 morgsnic-arjentc-content-ore
 concentrate. The ASARCO*Tacoma
 imelter it • custom imeller proceuing
 ore concentrates shipped from domestic
 and foreign copper mines. An
 interruption or discontinuation in
 shipments from one supplier could
 change the average inorganic arsenic
 content of the total smelter charge
 processed at the ASARCO-Tacome
 smelter. Thus, the future inorganic
 arsenic content of secondary emissions
 from the ASARCO-Tacoma smelter may
 increase or decrease depending on the
 mix of suppliers selling ore concentrate
 to ASARCO.
  The potential variability in the
 inorganic arsenic content of secondary
 emissions from the ASARCO-Tacomg
 smeller increases the complexity of
 developing numerical emission limits
 specifically for inorganic arsenic.
 Emission limits frr inorganic arsenic
 based on a mass emission rate, process
 weight, or concentration format would
 establish an upper limit on inorganic
 arsenic emissions only. An inorganic
 arsenic emission limit based  on the BAT
 emission control requirements
 specifically for the ASARCO-Tacoma
 smeller based on current data might not
 require application of BAT is other ore
 concentrates were processed. In
 contrast. *  percent reduction format
 would require the application of BAT
 regardless of the level of inorganic
 arsenic content in the feed materials.
 However, high collection efficiency may
 not oe continuously achievable for the
 entire range of inorganic arsenic
 concentrations which could occur in the
 caQ«ured.£as streams from the
 secondary emission sources.
  As en alternative, an emission limit
 for total participates that reflects the
 level of control device performance
 necessary to achieve BAT for collection
 of secondary inorganic arsenic
 emissions can be developed. There are
 several advantage* to BSing a total
 paniculate emission limit to regulete
 inorganic arsenic emissions.  Pint total
 paniculate emissions from primary
 copper smelter operations remain
 relatively content regardless of the
 inorganic arsenic content el the ore
 concentrate. Thus. • total paniculate
 emission limit would require  the use of
 BAT for all high-arsenic ore
 concentrates regardless of variations in
 the inorganic arsenic content of the feed.
The second advantage to a total
 particulate  emission limit is that EPA
 Reference Method S can be used to
 determine compliance. This method is
 widely used: and because it captures
 larger quantities of particulates. It offers
 the potential for greater precision.
 Therefore, for these reasons EPA
 decided to develop standards for
 collection of inorganic arsenic emissions
 bused on a total particular emission
 limit.
   Mass emission rate, percent emission
 reduction, process weight rate, and
 concentration formats were considered
 by EPA for setting emission limits for
 the collection of captured secondary
 emission gas streams. All four of these
 formats provide viable alternatives for
 setting total particulate emission limits.
   A mass rate format would limit total
 particulate emissions per unit of time.
 However, this format would not reflect
 differences in production rates (e.g..
 amount of ore concentrate, calcine, and
 matte processed). The mass emission
 rate standard would only place an upper
 limit on the total amount of particulars
 emitted per hour or per day.
   A percent reduction format would
 specify a minimum percent reduction of
 total particulate emissions  across a
.control device. Determination of
 compliance with a percent  reduction
 standard requires measurement of hoth
 uncontrolled and controlled emissions.
 The measurement of emissions at the
 inlet :o control devices poses testing
 difficulties due to ductwork and control
 device configurations. The  ductwork
 modifications necessary  10 perform
 accurate inlet testing at the ASARCO-
 Tacoma smelter would significantly
 increase the cost of the compliance
 determination.
   A mass per unit production format
 would limit total parficulale emissions
 per unit of copper produced or smelter
 charge. Determination of compliance
 with a mass per production unit
. standard requires the development of a
 material balance or production values
 concerning the operation el the copper
 smelter. Development of this
 information depends on the availability
 and reliability of process data provided
'by the company. Gathering these data
 increases the testing and reeordkeepin?
 requirements and. consequently.
 increases the compliance determination
 costs.
   A concentration formal would limit
 total particulate emissions  per unit
 volume of exhaust gases discharged to
 the atmosphere. Compliance
 determination of concentration
 standards requires a minimum of data
 and Information, decreasing the costs of
 tasting and reducing chances of
 measurement errors. Furthermore.
 vendors of particulate control devices
 usually guarantee equipment
 performance in terms of pollutant
 concentration in the discharge gas
 stream. There ii a potential for
 circumventing a concentration standard
 by diluting the exhaust gases discharge!
 to the atmosphere with excess air. thus
 lowering the concentration of tot
 particulars emitted but not the
 mass emitted. However, for this
 application, this problem can be s   ed
 by specifying a measurement location.
 Therefore, because a concentration
 format would involve lower resource
 requirements and a less complicated ,
 compliance determination procedure
 than the other formats. EPA selected a
 concentration format as the most
 suitable format for the proposed
 standards  for collection of secondary
 emissions.
 Srlrrtian nf i\'vmttrial Emission Limit
 and Equipment Specifications

   The proposed standards are based
 upon the application of a secondary
 hood system to capture converter
 secondary emissions and a baghouse a
 equivalent particulate control device it
 collect the captured secondary
 emissions  from conveners.
   The format selected for the propose*
 standard for capture of secondary
 inorganic itraenic emissions from
 converters consists of equipment and
 work practice specifications. EPA
 believes that the prototype secondary
 hood design installed on convert    o
 at the ASARCO-Tacoma smelt
 capable of achieving a capture
 efficiency level consistent with      il
 the system is installed and operated
 properly. Therefore, the design and
 operation of this system were the bast
 for the equipment and work practice
 specifications.
   The principal components of the
 secondary hood system are a hood
 enclosure,  an air curtain plenum and
 exhaust hood. fans, and sufficient
 ductwork to convey the captured
 emissions to a control device. Becaus
 each secondary hood system must be
 custom designed due to variations in
 converter configuration and space
' availability. EPA chose not in specif)
 physical dimensions for the hood
 enclosure.  Instead. EPA decided to
 specify the design practices that are
 necessary  to follow in order to obtaii
 secondary hood system capable of
 achieving at toast a *5 percent captui
 efficiency. These design practices ar
 (t) the configuration and dimensions
 the hood enclosure art sited so that
 converter mouth, charging ladles,
 skimming ladles, and  other material
 transfer vessels ere housed within tr
 confines or influence of the hood dui
-------
each mod* of convtrter operation: (2)
tht back gf tht hood enclosure Is fully
endottd and staled against the primary
hood: (3) the tdfts of the hood tncioiur*
tide walls In contact with the convtrter
   •atl rttnain seeitd during each mode
 .. inverter operation: (4) tht size of the
opening at tht top and front of the hood
enclosure necessary for the entry and
egress of ladles and crane apparatus is
minimised to tht fullest extent practical:
and (S) tht hood enclosure is fabricated
in such a manner and of materials of
sufficient strength to withstand
incidental contact with lidlts and crane
apparatus with no damage.
  The air curtain is produced by
blowing compressed air from a narrow
horizontal slot extending the length of a
plenum along tht top of ont sidt wall of
the hood enclosure. The dimensions of
iNs slot and the velocity of the air
blown through the slot ere essential
design parameters for determining the
momentum of the air curtain. Sufficient
air curtain momentum must be
maintained to prevent emissions rising
from the converter operations inside the
hood enclosure Dram penetrating the air
curtain and escaping to the ambient air.
  To ensure that the owner or operator
has the capability of developing
sufficient momentum in the air curtain  lo
capture secondary emissions, the
proposed standards specify that the eir
curtain fan be sized to deliver a
minimum of 2&370 walls  (30 air
horsepower) at the slot
  After installation of an air curtain
secondary hood system, the owner or
operator would be required to operate it
at conditions optimum for the capture of
secondary inorganic arsenic emiesions
(see "Optimization of Secondary Hood
Air Curtain System-). In addition, the
owner or operator would be required to
visually inspect the components of the
system at least once every month end
maintain  each converter and associated
secondary hood system in a manner
consistent with minimising inorganic
arsenic emissions.
  Over a l«w«ek period. EPA personnel
observed tht ASARCO prototype
secondary head system during atl
converter operating modes. Baaed on
these uusaniUena. EPA concluded that
the work practices followed by the
individual converter and crane
operators can significantly impact the
amount of secondary emissions that era
captured by the secondary hood system.
To assure the maximum capture of
secondary emissions, the Administrator
is proposing five work practices to be
followed by the converter and crane
operators. These work practices are (1)
ait curtain and exhaust flow rales shall
or increased by the converter operator
to optimum conditions prior to raising
the primary hood and rolling the
converter out for skimming: (2) once
rolled out. the converter operator shall
hold the converter in an idle position
until fuming from the molten bath cesses
prior to commencing skimming: (3)
during skimming, the crane operator
shall raise the receiving ladle off the
ground and position the ladle as close as
possible to the converter to minimize the
drop distance between the converter
mouth and receiving ladle: (4) the rate of
flow into the receiving ladle shall be
controlled by the converter operator to
the extent practicable to mimimize
fuming: and (SJ upon completion of a
charge, the crane operator shall
withdraw the charging iedle from the
confines of the hood enclosure in a slow
and deliberate manner.
  The Administrator believes that it
may be appropriate lo specify minimum
time periods lo be associated with some
of these work practices, such as with (1).
(2). and (4) above. The public is invited
to comment on the need to specify
minimum times to be associated with
the proposed work practice standards
ens on what limes may be appropriate.
  ASARCO has slated it intends to
install air curtain secondary hood
systems (similar to the system already
in place on converter No. 4) on it*
converters that will remain in service at
iheTacoma smelter. EPA therefore
expects that ASARCO would meet
NESHAP requirement* for controlling
secondary Inorganic arsenic emissions
from converters at Tacoma by installing
air curtain secondary hood systems.
However, the proposed equipment
specification it not intended to preclude
the use of other secondary inorganic
arsenic capture systems which may be
as effective es an air curtain secondary
hood. Upon written application to EPA.
the use of an alternative secondary
inorganic arsenic capture system which
has been demonstrated to EPA'a
satisfaction to be equivalent in terms of
capture efficiency for inorganic arsenic
may be approved (tee "Equivalent
Systems for the  Capture of Secondary
Emissions from Convener Operaii> .is"
in Part III of this preamble}.
  To reflect the level of control device
performance necessary to achieve BAT
for collection of secondary inorganic
arsenic emiasions, EPA selected a
format specifying a martmtrm  allowable
total paniculate emissions Unit For
selecting the numerical value of the
limit EPA reviewed the paniculate
emission source test results for the
control devices  nidged to represent BAT.
The lest results  were discussed in the
Control Technology section of this part
of the preamble. These results consist of
e series of three consecutive sampi
runs for which the measured total
paniculate matter emissions at the
control device outlet ranged from 1
11.6 mg/dscm. The average value fi
three runs was S.I mg/dscm. The n
show that a control level of at least
mg/dicm can be achieved: and. mo
likely, control devices will achieve
significantly lower emission levels.
Therefore. EPA selected 11.6 rng/d:
as the proposed emission limit.
Selection of Emission Tut Methoo

  The use of EPA "efererce Metric
•'Determination of Paniculate  Emit
from Stationary Sources" in Appen
of 40 CFR Part 60 would be require
determine compliance with the
concentration standard for total
paniculate matter emissions.
Calculations applicable under Met
necessitate the use of data obtaine
from three other EPA test methods
conducted before the performance
Method 5. Method 1—"Sample and
Velocity Traverse for Stationary
Sources" must be conducted in ord
obtain reprensentative measureme
pollutant emissions. The avenge g
velocity in the exhaust stack is
meesured by conducting Method 2
"Determination of Stack Cas Velot
and Volumetric Row Rate—(Type
Pilot Tube)." The analysis of gaa
composition is measured by condu
Method 3— "Cas Analysis for Carl
Dioxide. Oxygen. Excess Air and I
Molecular Weight" These three te
provide data necessary in Method
convening volumetric flow rate to
flow rate. In addition. Method 4—
"Determination of Moisture Contei
Stack Cases" is suggested as an
accurate mode of predetermine HOT
moisture content
Selection of Monitoring Requinim

  Section 114 of the Clean Air Act
authorizes EPA to establish monitc
requirements for the purpose of
determining violations of standard
proposed under the Clean Air Act
monitoring data must be maintain!
such a manner to aa to be accessil
EPA.
  The performance of the equipnu
used to capture the secondary ami
from the coverlet operation* ia hig
dependent on flow rate. If the flow
is not measured, it ia not possible
either the operator or EPA to  detei
whether the equipment is properly
operated and maintained. Therefo
proposed standards require contit
monitoring of the time and air flov
through the air curtain systems, ai
keeping a log of times for each of i
-------
converter operations. This would allow
the correlation of recorded gi* flow
rat** with th« corresponding converter
operation.
  To help the AdmfrJstnlor determine
whether eech seconr'ary hood system is
being properly opertu-i end maintained.
measured airflow rates would be
compared to source specific reference
values established during the
optimization of each system for each
convener operating mode. (See
"Optimization of Secondary Hood
System".) To establish source specific
airflow reference values, the owner or
operator would determine the flow rites
that correspond to each converter
operating mode while the secondary
hood system is operating under optimum
conditions.
  The proposed standards for the
collection of secondary inorganic
arsenic emissions ere based upon a total
paniculate concentration limit One
alternative to monitoring the
performance of the collection device is
to periodically test  the collection device
using Method ft. However, this
alternative is costly and la not
considered reasonable. Continuous
monitoring of opacity or an operating
parameter of the collection device may
be used to indirectly monitor
performance by indicating whether or
not the collection device is operating in
the same manner as when it
demonstrated compliance during the
emission test Of these two alternatives.
monitoring opacity  is simpler to apply.
Therefore, the monitoring requirement
selected for the collection of secondary
b.....iie emissions is to continuously
monitor opacity using a
transmisaometer.
  To implement this monitoring
requirement it would be necessary to
establish a reference opacity level
against which futon performance of the
control system could be compared. To
establish die source specific reference
opacity leveL the owner or operator of
the source would be required to conduct
continuous opacity monitoring during
the emission teal. The opacity
monitoring results would be reduced to
6-minute avenges, and the opacity level
would be estabbsned at the 97-5 percent
                   i) of 00010181 or
log normal (whichever to more
representative) distribution of the 6-
minute avenge opacity values. This
opacity value would be the basis tor
determining whether the collection
device is continuously performing
effectively. Any monitored opacity
reading above the emission test opacity
reading would indicate that the
collection device may no longer be
meeting the proposed total paniculate
emission limit. A Method 5 test could
then be performed to determine
compliance.

Optimization Of Air Curtain Secondary
HoodSyttcm
  It is intended that the installation of
equipment specified in the proposed
standards for the capture of convener
secondary emissions will give the owner
or operator of each affected converter
the capability of reducing emissions to a
level consistent with the application of
BAT. In developing the equipment
specifications, the Administntor has
been specific for some requirements as
in the case of fan horsepower capacity,
and more general for others, such as the
dimensions of the secondary hood.
Some of the requirements an general
because unless then an any new
smelters, which is considered unlikely.
each Installation will be a ntrofit that
is, each air curtain secondary hood
system will have to be custom designed
to fit each existing convener. Due to
span limitations, existing pollution
control equipment already in place and
other considerations, the exact
configuration of each secondary hood
with air curtain system installed will
vary from smelter to smelter.  .
  Beyond hood configuration, the
performance of each air curtain  •
secondary hood system will depend on a
balance of several other parameters.
including the dimensions of the air
curtain slot the velocity of air through
the slot and the distance from the slot
to the offtake. These parameters an
adfustable in the MUM that they can be
attend in a relatively short time and at
nlatlvely small coat It la expected that
after the initial installation of each air
curtain secondary hood system, then
will be a "shakedown" or optimisation
period during which the proper balance
of system parameters will be determined
for each particular installation.
  For every air curtain secondary hood
installation, then wUI bo an optimum
set of operating conditions. beyond
wnich further "fine tuatag" of the system
will not result in mcnaaed capture
efficiency. Section lUMP) of the dean
Air Act state*; m part that tf the
Administrator promulgates • design or
equipment standard, "ha ahaUincjude a*
part of such standard sues requirements
as will assure the proper operation and
maintenance of any ouch ekment of
 Administrator's intent however, to
 require the owner or operator to open
 a system beyond optimum conditions
 (i.e.. et flow rates and power
 requirements that do not achieve
 additional capture) or to prevent
 operational changes that may      a
 the capture efficiency of the
  Authority for determination
 optimum conditions for each air     i
 secondary hood system installed to m
 the proposed standards would rest wi
 the Administrator. Due to the variable
 involved, and the fact each Installatio
 will be aite specific It is not possible i
 the Administntor to pmcribe In
 advance what will constitute optimus
. operating conditions for each air curti
 secondary hood Installation. Objectfv
 techniques, such as the tracer study
 used to evaluate the air curtain
 secondary hood system on the No. 4
 converter at the ASARCO-Tacoma
 smelter, an available to help determt
 csptura effeidcncy. However. • final
 determination of whether a system hi
 truly been optimised, or if not what
 steps should (or could) be taken to
 improve it will largely be a matter of
 fMdiM^KMOKt
 nnignmi.
  One approach the Administrator is
 considering as a method for determln
 optimum conditions for each air curti
 secondary hood installation would bi
 have eech system evaluated by a pai
 of persons with expertise In assassin
 visible emissions of air pollutan   Tl
 panel could be comprised of 3
 persons, including npnaanta
 industry. EPA and local air po
 cuniiul agencies.
  The panel would evaluate each ail
 curtain secondary hood aa follows; (
 the panel would review the plane an
 specifications of the system prior to
 installation: (2) the panel would agn
 on Initial operating conditions for uv
 system: (3) the panel would observe
 operation of the system during each
 mode of converter operation under t
 initial operating conditions. Eatimati
 the capture effectiveness achieved.
 based on
 fQCQfQAQ Ojf fTMB ptfMl QUBOQf IOT
 each mode of operation, n addition
                            i ami
operation" of an air curtain secondary
hood system includes operating the
system as dose to optimum conditions
as possible, and the owner or operator
would be required to do so under the
proposed standards. It is not the
achieved, tbe
density of visible emissions observe
and • qualitative aaseaas>enl of the
volume of th* emissions escaping
canton (04* light moderate, heavy
etc) would be recorded: (Abased c
this Initial evaluation, the panel wo
agree on whit modifications would
_ ^~ji—
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 53138
       Federal Register /  Vol.- 48.  No. 140 /  Wednesday. ,)uiy
 tytttm (•• in 3) after modification to
 compart its performance to pn-
 modifieation performance. After this.
 •ttpa 4 and 9 would be nptatad at
 needed until than was agreement
 among tha pant! ownbara that tha
 system had barn optimized. Tha panel
 would than recommend a tat of optimum
 operating condition* for that system to
thtAdn
inistntor along with
documentation of their evaluation. In the
event of disputes, panel members would
•ubnit Mpanta recommendations. The
Administrator would make a final
determination of the optimum conditions
bated on tha panel's recommendation
and supporting documentation.
  It subsequent to a determination that
i aystea has been optimized, an owner
of operator propoees to make an
additional modification to the system,
the panel would again be convened and
would observe the system both before
and after the change aa prescribed in (3)
above. The modification could be
approved by the Administrator if the
panel found It did not reduce capture
efficiency.
  The Administrator believes this
approach would essure that the air
curtala secondary hood system is
detigned and operating conditions
.established which will minimize
secondary inorganic arsenic emissions
to the greatest extent possible. but
would also allow the owner or operator
to make modifications to the system  that
would not reduce capture efficiency.
The public is invited to comment on the
need to evaluate the optimization of
each air curtate secondary hood system
•M on the panel approach being
considered by the Administrator.
Reporting and Aacanrftaepf '/$
  Owners or operators of sources
covered by the prop)
would be aabfect to the reporting and
propossd standards, as wofl as those
proscribed la the General Provisions
(SobpartA)of40CFRPert«l.Under
I «l.lQ oftho General Provisions, an
hntia* report BOM oacn existing source
AA ^K^M»iAK^ * — L^ ^—.L^—f^A^J A^^JlkJ^ ^Wk
H nqvBBo n oe svoanineo wnntnMi
days of the effective dati
 a>Bk^^^^^^bb^^BA M^ste^ta^^^ ^^s^k^dlb* ofc>^.i taW*
 tnrouanpoi ajDanata spoony Vmt me
 taitiaTreport required ia | «.10(a) will
 tadada tafarmaOcn on the weight
 percent inorganic arsenic to the total
 smelter charge. The proposed standards
 further require that each month the
 computation of a roittng annual average
 of tae iaorgsjiic arsenic content ot the
 total smelter charge be made and that
 the monthly computation of a railing
annual average of the Inorganic arsentic
content of the total smelter charge be
made end that the monthly
computations be recorded and dept on
site for at least 2 years; The monthly
computations would have to be reported
to EPA on an annual basis to ensure thst
applicability with respect to the
standards had not changed.
  Under Section 114 EPA is authorized
to establish reporting requirements to
determine whether there is a violation of
standards proposed under the Clean Air
Act Concern as to whether the systems
for the control of inorganic arsenic
emissions an continuing to matt the
proposed standards would primarily
arise when monitorial showed opacity
levels in excess of those determined
during the compliance demonstration or
airflow rates that vary significantly from
those established during the
optimisation procedure. Therefore, in
determining the necessary reporting
requirements, it was considered
reasonable to require reporting only
when such "excess emission'' conditions
exist. Reporting of these excess
emission conditions would be required
on a semiannual basis. Currently, only
                              tha
                                  of thin
            letting companies collect
any oi this information. In additioa.
then an no reporting requirements by
other governmental agencies for this
typo if Information which would result
in overlapping data requirements. The
types of information to be included in
the reports are discussed below.
  For the converter secondary hood
system, each semiannual report would
indicate: (l) the reference airflow rales
established for each converter
operational mode, tad (2) a racocd of
airflow rates for each day when the
airflow rates art Ins than 20 percent of
tha corresponding reference values.
  For the collection devices for
                              report would provides ill a record of
                              traMauasomotet reading* for each day
                              OB which the opacity exceeded the
                              reference opacity Unit determined it the
                              tine lh« coUectioa device demonstrated
                              compliance, and (2) the value* of the
                              emiaaion teat opacity Units.
                                         EPA bettevee that UMM reporting and
                                        to aa*i*l the Agency in (1)
                                                (Z) observing the
                                                             tionof
                              initial
                              standard
                 aiid (4) enforcing the
             the initial compliance
Office of Management and Budge!
(OMB) approve reporting and
recordkeeping requirements that quoli!
ei an "information collection request"
(ICRJ. For the purposes of
accommodating OMFi review, EPA
uses 2-yesr periods in its impact
analysis procedures for estimating the
labor-hour burden of reporting and
recordkeeping requirements.
  The average annual burden on high-
arsenic-throughput copper smelter* to
comply with the reporting and
recordkeeping requirements of the
proposed standards over the first 2
years after the effective date is
estimated to be 1410 person-hours.

Regulatory Flexibility Analysis
                                                                      The Regulatory Flexibility Act of 1«
                                                                      UFA) requires that differential Unpaci
                                                                     of Federal regulations upon small
businesses be Identified and analysed
The UFA stipulates that an analysis is
required if a substantial number of sm
businesses will experience significant
impacts. Both measures must be met:
that Is, a substantial number of small
businesses must be affected and they
must experience significant impacts, i
require an analysis. Twenty percent o
more of the small businesses la an
affected industry is considered a
substantial number. The EPA defining
of significant impact involves three
tests, aa follows: (1) prices of product!
produced by small entities rise 0 perct
or more, assuming costs an passed or
to consumers: (2) anauallzed Investmc
costs for pollution control are greater
than 20 percent of total capital spendii
or (3) costs as a parent of sales for
small entities era 10 percent greater Ui
costs ass percent of sales for large
  The Small Business Administration
(SBA) definition of a small business ft
Standard Industrial Classification (Sl(
Coda 3391. Primary Smelting and
Refining of Copper, Is 14X10 employee)
The ASARCO-Tacema smelter is own
by a company that haa man than un
employees. Therefore ASAROO does
not meet die SBA definition of a smali
business and thus no regulatory
flexibility analysts ia required.
                                 ins Paperwork Reduction Act (PRA)
                                :   O (Pub. L 86-611) requires that the
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  APPENDIX B
Newspaper Articles
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A-14 Tacoma, Sun.t July 17, 1983, The News Tribune
Smelter   battle
   Politics, economics  and  environmental issues
   are whirling around the Asarco controversy
  By JEFF WEATHEBSBY
  
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A-14 Tacoma, Sun., July 17, 1983, The News Tribune
Smelter    batt
 (Contlnuad from
  praeading page)
  Be said Asarco officials are
what presentations the company
will present to (he EPA.


    As ia tte past, the theme, bat-
      O^^^^MA4l I^M O^Med^MJ^t^^ J^H^^B
      msseo By tennony mm
doctors and university research*
en. is expected to be that smaUer
emission do not harm people. At
the 1981 variance hearing, Asarco
hired the Seattle public relations
firm of HID and Knowttoa to han-
dle publicity.
  Additionally. Asarco is likely to

does in tte area. It employs some
570 people, has a maittHmlUea
payroll,  pays  taxes and  makes
large puicjaau OB the local mar-
ket.
                      only
maaafactarer of anesse la the
'Tatted States.
  Pesticide manufacturers aad
                   ia their
proauKi* WWK
if they had to purchase Ike metal

have to pay for expensive poilu-
vime, juwttwitei W tsM^MeoAfr •eie^a'
  Briaa Baird. a BMBBberofTaho-

(THE), said he is already worried
aboot the Uad of campaign Asar-
co may wage.
        .ia setting a
 (to EPA policy) tndttJsoette coo-
 etivable- Asarco wooid Uaoch a
distorting  facts or
that suits their "
BaM.
  Be said he is
 or poblie  relatioaa
    Lindqnitti  the swelter maoa-
      aer, has a similar concern.
   -I hope it will be decided oa the
 scientific merits of the ease," be
 said. 1 think emotional appeals
   'U be made, based OB
   *e. This is inevitable in,
 tsinf like this.
 already heard one person call a
 radio talk show and complain it
 smeUed as  thonsh Asarco  was
 •frying doc*."
   On the other side, Baird
                             • I  hope it will be decided on  the scientific
                             merits  of  the  case.   !   think  emotionai
                             appeals will  be made,  based on  emotion
                             alone. This  is inevitable  in 'something like
                             this. 5                  '                            ;
                                                                  — Larry Undquist
                                                             Asarco smette* manager
                                                        of the smelter.
                                                          -I don't believe anyone is seek-
                                                        iaf total dosore of the mitt." said
                            the way in which public opinion is
                            shaped often by the party with the
                                            oney."
                                            don't  have
                                                          BaM said.-** win stand for
                              Bated said (be
                             will try to
                             daimtfbt by
                             wftMa BlMvMftBl llfea* ftfesat
                             Loaf Assortlrtnn aod
its Image. Instead of covering for
these fey* lisa Asarco. it should.
try to bring hi new industries to
take the place of the poUaters.
.  "We want Tacomc to be able to
                                                                          t>*l1
                                  may have
                             tohifjUictattaebe
                               Be added the
                                             > BaM said.
  BaM also suggested that the
smelter aad the publicity it has
                            ether data oa the i
                            iM^mm ITiitilt i f tt«
                            IMIIB ( UMM! UB*1
                            can prepare for the
                            cording  to  Bob Jacobsoe,  a
                                    i fo
                                    tactic of the
                                                        the city hopes the Tacoma Dome
                                                        win attract
                                                                  ; BaM said his or-
                                                                       ^M^^^ **- — ^^u^^aA
                                                                       want IBS worn

                                                        are wfUmf to take risks with their
                                                           - -    ^
                                                                     paay leans Taco-
                                                              ^^^ ^^^ilft^h^ -^-*- ^s^ *?•• ^i^^
                                                              are wuiiac to ale lor cm*
                                                                . the the afinfate effect
                                                             be enarreptsMy large.- be
                            OB the enriroemental

                            in the past by sem
                              Tor too  lons>
                                   tyhas
                              An effort likely will be made to
                             coovtoc* labor loaders that "the
                             Qttk fKilBOt OB OOUBttPB COfltTOaS &V
                             the creation of toes.." Baird said.
                              Perhaps in an effort to rccrett
                             allies. Asarco critics
                                                        afar groups will become involved in
                                                        the Tacoma smelter case.
                                          rtal issues. The    -This  is a nrecedeat.setting
                                          been suppwted  0808." he said. "It has never been
                                                           m the lap of the community
                                                              to say how much risk it is
                                                        wining to take. So it Is very im-
                                                        portant" for *****
-------
                    I. HOW COMMUNITIES SEE RISK
            Agency scientists and policy-makers are particularly confused and frustrated by
      public reactions to environmental risk. Tempers flare at a public meeting concerning a
      risk that the agency estimates might cause considerably fewer than one-in-a-million
      increased cancer deaths.  Yet people will smoke during the break and drive home
      without seat belts- risks far greater than those discussed at the public meeting. When
      agency scientists point out this apparent contradiction (ignoring the fact that smoking
      and driving without a seat belt are risks that people choose, not an environmental risk
      that chooses them), people become even angrier.  Conversely, risks that the agency sees
      as serious—naturally occurring radon gas in homes, for example—can be met with
      relative indifference by the public.

            In order to reduce the level of hostility between agencies and the public, those
      who work within agencies need to understand  better how communities perceive risk.
      Agencies sometimes respond to unexpected community reactions by dismissing them as
      Irrational and concluding that the public is unable to understand the scientific aspects
      of risk. But when agencies make decisions that affect communities without involving
      those «*""•"*> "TM<«» they often ^*r-*t even angrier responses.

            to order to break this cycle, agencies might begin by recognizing that communi-
      ties are quite capable of understanding the scientific aspects of risk assessment.  The
      public" Includes doctors, chemists, and teachers, as wen as persons with less scientific
      background, who understand many of the technical Intricacies of risk. In fact, while
      government personnel may change over the course of an environmental problem, resi-
      dents of affected communities often remember studies, reports, and agency actions with
      an Impressive amount of recall.  Too often government assumes that because communi-
      ties don't agree with an agency action, they don't understand it.

            Because outbursts of citizen anger make agencies understandably uncomfort-
      able, they also tend to forget that public outrage can be extremely positive. In fact.
      most environmental agencies and a significant number of the laws they enforce are  the
      results of citizen campaigns, fueled by anger over environmental degradation. Funding
      for these laws, and consequently for agency staff, also depends In some cases on tough
      legislative battles fought by citizens. In addition, most agencies can admit to a number
      of environmental problems that wouldn't have  been uncovered were It not for commu-
      nity action.

            On the other hand, agencies particularly resent anger directed at them rather
      than at the environmental problem.  Unfortunately, agencies tend to act (often unwit-
      tingly) in ways that provoke such anger.


      FACTORS m COMMUNITY OUTRAGE

            Admittedly, public fears are often not well-correlated with agency assessments
     While agencies focus on data gathered from hazard evaluations, monitoring, and risk
     assessments, the public takes into account many other factors besides scientific data
     Collectively, it Is helpful to think of these non-technical factors as the 'outrage* dimen-
     sion of risk, as opposed to the "hazard" dimension more Cmiiltar to agency profession-
     als.  Because the public pays more attention to outrage than the experts do. public nsk
     assessments are likely to be very different from agency risk assessments. Ignoring the
•improving Dulogue with Comamities" written by CVM Chus. Bilbe Jo Hince. tad Peter Saadmu of (be Environment*!  CommutiK 4,.*
Rejetrcfa Progrtm it Cook College, Rutgers Univewiiy, 1987.
                                        17
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 varaDtes tnat mfljenee public perception- or worse, labeling them Irrational and then
 discounting them— Is guaranteed to raise the level of hostility between community
 members and agency representatives and will ultimately stand in the way of a success-
 ful resolution of the problem.

       Merely hammering away at the scientific information will rarely help. Most
 agency representatives can recall instances when explaining the science made little
 difference- or made people even angrier.  While it may be tempting to conclude from
 this that laypeople cannot understand risk assessment data, research in the field of risk
 perception, backed by much anecdotal evidence, strongly suggests that other factors
 are at work.  Below are some of the key variables that underlie community perception of
 risk:*

 a.     Voluntary risks are accepted more readtty than those that are Imposed. When
 people dont have choices, they become angry.  Similarly, when communities feel co-
 erced Into accepting nsks, they tend to feel furious about the coercion. As a result, they
 focus on government's process and pay far less attention to substantive risk issues;
 ultimately, they come to see the risk as more risky.

 b.     Risks under individual control are accepted more readily than those under govern-
 ment control Most people feel safer with risks under their own control. For example.
 most of us feel safer driving than tiding as a passenger.  Our feeling has nothing to do.
 wttii the dat&^our driving record versus the drtvtng tecuid of others. SlmHsiiy, people
 tend to feel more comfortable with environmental risks they can do something about
 themselves, rather than having to rely on government to protect them.

 c.     Risks that seem Jatr are more acceptable than those that seem unfair. A coerced
 risk win always seem unfair. In addition, a community that feels stuck with the risk
 and little of the benefit win find the risk unfair- and thus more serious. This factor
 explains, in part, why communities that depend on a particular industry for jobs some-
 times see pollution from that industry as less risky.
d»     Rude (n/uiinutJon thutcotnfyfrofn tntsttoorlfufttMfoefts nvrt i
(nan tnformattonjrom untrustworthy sources. If a mechanic with whom you have quar-
relled in the past suggests he cant find a problem with a car that seems faulty to you.
you will respond quite differently than If a friend delivers the same news. You are more
apt to demand justifii^auuu. jaiher than ask neutral questions, of the mechanic. Unfor-
tunately, on-going battles with communities erode trust and make the agency message
far less believable.

       Whfle the above factors are those most frequently stumbled over by government
agencies, social scientists have identified additional variables that are also likely to be
relevant to agencies dealing with the public about environmental health issues:

e.     Jttsfcs that seem ethically objectionable trill seem more rfeky than those thai don't
To many people, pollution is morally wrong. As former EPA Assistant Administrator
Milton RusseD put It. speaking to some people about an acceptable level of pollution is
like talking about an acceptable number of child molesters.
1 Baruch-Flschhoff. Paul Slavic, and Sarah Uehtenateln conducted much of the grraDd-hmktn£
                     > uiaJei •taodtegof rt«k pen
        DMlofne with Commaahm." written by Caroa Own. Billie Jo Haoee. tad faa Sudmu of the Eavinainesi*! Canmuaicjiioa
 Reward) Program a> Cook Collefe, Rutgers Uaivenity. 1987.
                                            18
-------
     /.     Natural rtsfcs seem more acceptable than art(/lctal risks. Natural risks provide no
      focus for anger; a risk caused by God is more acceptable than one caused by people.
      For example, consider the difference between the reactions to naturally occurring radon
      in homes and the reactions to high radon levels caused by uranium mine tailings or
      Industrial sources.

      g.     Exotic risks seem mare risky than familiar risks. A cabinet full of household
      cleansers, for example, seems much less risky than a high-tech chemical facility that
      makes the cleansers.

      ft.     Risks that are associated wtth other, memorable events are considered more
      risky. Risks that bring to mind Bhopal or Love Canal, for example, are more likely to be
     feared than those that lack such  associations.

            The greater the number and seriousness of these factors, the greater the likelihood
     of public concern about the risk, regardless of the scientific data. As government agen-
     cies have seen many times, the risks that elicit public concern may not be the  same
     ones that scientists have Identified as most dangerous to health.  When officials dismiss
     the public's concern as misguided, moreover, the result Is controversy, anger, distrust,
     and still greater concern. None of this is meant to suggest that people disregard scien-
     tific information and make decisions based only on the other variables—the outrage
     factors. It does suggest, however, that outrage also matters, and that by ignoring the
     outrage factors, agencies skew the balance and cause people to become still more
     outraged. This is the logic that leads to the guideline that follows.


     Pay as much attention to outrage factors, and to the community's concerns, as to
     scientific variables. At the same time, don't underestimate the  public's ability to
     understand the science.

            Agencies too often focus on the scientific  data and ignore the outrage factors.
     They pay the price for doing so. Insistence on dealing with the "right" risks, the "tight"
     way, may seem to many outside the agency as arrogant at best. If you fail to attend to
     the outrage factors and people's concerns from the outset you win often be forced to
     attend to them later, after you have angered the  public— a far more difficult situation.

            For example, communities which were not consulted during the decision-making
     process more readily fight agency decisions. Similarly, agency representatives have
     sometimes been shouted down when trying to present data because communities have
     felt their concerns were not acknowledged, much less addressed.

            Nonetheless, there are examples of agency successes.  The New York Department
     of Health asked office workers their concerns and gave them opportunities for  input
     following a fire that contaminated their office building wtth dloxln. Trust was built in
     the process. NJDEP listened to— and responded to— community concerns in Clinton
     where extremely high radon levels were found, leading to a community response to
     NJDEP that seemed far more positive than in many other instances. In Virginia, a
     developer involved the community in the risk assessment process, building sufficient
     credibility that when the risk assessment showed negligible risks, the results were
     believed. In most of these Instances of success, communities that were consulted about
     their concerns were also helped to understand* the science, and their understanding
             toi
"Improviaf Diatofue with Comimiwuw.' wrineo by Caroo Qieti. Bilbe lo H«nct, and Peter Sandman of ibe Environmental Communicant
Research Program at Cook College. Ringer* University, 1987.
                                        19
-------
       In short, response to risk Is more complex than a linear response to "the facts."
This does not mean that people don't need to know- or want to know- the facts.  It
means rather that agencies need to take Into account other factors as well.

                                       §§§


YES, BUT—


•      Our Job <* to protect public health. That means reiving on data, not deal-
ing with outrage/actors.

       There are basically three responses to this point:

       First. If you merely run with scientific information and Ignore the outrage fac-
tors, you will outrage the public.  As a result, risks the agency deems minimal will
become battlegrounds. Agencies will have less time for serious xisks.  In short, one way
         i- agencies wffl haw to deal with these factors.
       Second, in a democracy controversial issues are not merely determined by those
with technical expertise. For example, the experts in the Pentagon have great technical
expertise in weaponry, but few people, regardless of their political beliefs, feel that
American defense policy should be determined solely by the Pentagon.

       Third, data are not always complete, and management options are rarely perfect.
The public's raising other concerns can lead to better technical solutions.


•      |f It toere not for activist groups, there would be no outrage.

       As anyone who has tried to organize a community can attest, it is hard to create
outrage when none exists. 'Advocacy groups can focus or direct the community's anger,
but rarely create tt. In fact, most environmental activists count on government to create
the outrage. In many cases where environmental officials blame public-interest groups
for blocking solutions, the blame needs to be shared by the officials themselves, who
nnwtttmghr goaded the outrage by neglecting from the outset to listen to community
concerns. Instead of blaming citizens for not understanding risk, in short, agencies
might spend more time trying to understand citizen concerns.
        Dialogue with Communhiej,- written by Caroo Qteu. Billie Jo HUM, aad Peter Saedmu of the Eovirwiineaul CammuaJcuioo
Research Projr»n> at Cook CoHeje. Rutgen University. 1987.
                                       20
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                  .  tlAKINlINU IKUdl AINU L,KbU113iLH Y

            Agencies achieve trust. In large part, by being consistently competent, caring.
     and honest.  If you communicate with honesty and fairness, your audience will often
     respond in kind.  On the other hand, slick packaging with a veneer of honesty is easy to
     see through and more likely to undermine trust than to build It.  Jim Callaghan, who
     spent many years advising industry as senior vice president of the public relations firm
     of Hill and Knowlton. puts it this way: The onh/ way to achieve credibility Is to 'be
     credible."

            Of course, acting trustworthy is no guarantee that people will ultimately trust
     you. But if you fall to "be credible," you will virtually guarantee community opposition.
     In the form of both disagreement with the science and resentment of the agency.

                   Bnice Bentley. citizen participation specialist at the New York State
            Department of Environmental Conservation, points out that a key to building
            trust can be Involving people in decision-making. A controversy over what to do
            with PCBs in the Hudson River was fueled by the lack of trust resulting from the
            agency's failure to ask people about disposal of the PCBs. Bentley says. "We
            failed to Involve people In determining what the criteria for a site should be and
            then went ahead and selected the site.... By that time, people were not willing to
            buy into the criteria and certainly, therefore, not willing to buy into the site.*

                   Conversely, trust can be built by dealing with the public forthrtghUy.
            When a flre contaminated a Binghamton office building with dioxln, the New York
            State Department of Health decided to make all working sessions of the technical
            risk assessment committee open to the public and the media. The committee,
            which consisted of people from the city, union members, and technical people
            unaflUlated with the health department struggled with difficult questions openly.
            Although the meetings were not public Information meetings, there was time
            allotted for questions at the end of each session.  As Faith Schottenfeld, commu-
            nity relations specialist at the department, pointed out "It was really helpful for
            PCOPMf lO 'BMBf? iJRNF kJnFKs O§ IftliCFCxIlSDtUBC tDHKC' WC3EUC CHOI bCtBMBCflDL tOM9UG> C9DCM3rtlk 'VuCUBliQ it
            ccmetoniaktngdtfflcuftdtrtslons.*

            The guidelines in this chapter provide a framework for the more specific recom-
     mendations in other chapters.


     1.     Be aware of the factors which Inspire trust. Trust In an agency depends, in
     large part, on whether the agency: (a) seems competent* (b) seems caring; (c) encourages
     meaningful public Involvement:  (d) seems honorable and honest: and (e) takes into
     account the "outrage factors* which influence perception  of risk. (See Chapter 1.)  In
     essence. Instead of pushing the  public to trust them, agencies should strive toward
     acting consistently trustworthy.


     2.     Pay attention to process. In many cases citizen opposition focuses not only on
     agency action (or inaction), but also on the manner in which the agency proceeded
     toward that action. Try. whenever possible, to involve affected communities in agency
     action.
           Explain agency procedures.  Communities need to understand government's
             workings, y"1 yfffr^ffii need to show tlxat they oiiCT'ate in. WPT^X Vig^i*^ manner.
     Indicate how public input fits Into the piucess.
'Improving Dialogue with Communities." written by Caroo Cheu. Biliic Jo Haace. and Peter Sandman of the Environment*! Communicauoe
Research Program at Cook College. RiKgen Univenity. 1987.
                                          21
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   "People read the agencies and their actions more carefully than they read the details of
   the studies.... That's what we have generalized skill at" Baruch Fischhoff, leading
   researcher on risk perception, Carnegie-Mellon University. •
 4.     Be forthcoming with information and Involve the public from the outlet.  If
 you fail to disclose Information or Involve people early, the public is apt to mistrust the
 agency. The agency will then be put on the defensive. (See Chapter HI.)


 5.     Focv* on building tnut as veil at generating good scientific data. As
 explained In Chapter I, people's risk Judgments are seldom baaed solely on scientific
 information, but rather on a combination of the data, their perception of the Ask due to
 other variables, and their feelings about the agency.


 6.     Follow up. When your promises fall through the cracks, you might not notice,
 but those to whom you made the promises usually do. Make every effort to get back to
 people and check to see if your promises are becoming reality.  In particular, consider
 making sure that notes are taken at public meetings regarding commitments. Then
 write follow-up memos and take follow-up actions to make the promises happen.


 7.     Make only promises you are ante you can keep. It is often tempting to make
 unrealistic promises when  pressed by the public, or to promise something you genu-
 inely expect to deliver, only to find out later you can't. Consider explaining goals and
 the process leading to them rather than promising firm dates.  Providing regular prog-
 ress reports, even when progress is slow, can be very helpful. If you find you cant
 follow through on a promise you have made, explain fully as soon as possible rather
 than hoping people will forget.  They probably wont.
8.     Provide latomattoa Cboat muuax peopte'a • anti  Anticipate what people want
to know— and what they win need to know even if they dont ask for it. Take some time
to develop a list of problems, issues, and needs people might have, and prepare re-
sponses that address them. Keep in mind that different organizations and types of
people wfll have different needs- a pregnant woman may have different concerns than
the Chamber of Commerce. (See Chapter V.)


ft.     Get the facts straight. Although agency representatives work hard to provide
accurate Information, sometimes facts get jumbled or key Information is left out so
people later feel misled. Try to spot areas in advance where confusion might occur and
make an extra effort to be clear. If the effort falls, correct the mislmpression as quickly
as possible.


1O.    Try to coordinate with other agencies.  When communities get mixed mes-
sages, they are apt to feel confused and distrustful. To the extent possible, coordinate
agency messages. When agencies have honest differences, acknowledge them.


II.    Hake son to coordinate within yonr agency. Lack of coordination within the
agency creates- confusion and an. impression of agency tneptness. Responses to various
Issues shoukiteccmtsleritntnn ore dt^fcm to aac4h«r,tf
acknowledged and explained.

 "lavmtel Dialogue whh Comiraitiei,* written by Caroo Chen. BOlie Jo Huce. tad Peter Sndnu «f fee Environmental CommuaicKioa
 Raendi Projnm at Cook Colleie. Rajas Uiivenity, 19(7.
                                       22
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      12.    Don't give mixed messages. Risk issues are sufficiently confusing that any
      inconsistencies- or seeming inconsistencies- can make matters worse. For example. If
      you tell a community that risks are minimal and then take samples wearing protective
      gear, to reduce confusion, explain the seeming contradiction before you take the action.


      13.    Listen to what various groups are telling you. Try to foster mutual respect
      and consideration with all stakeholders In an Issue. Avoid offending any group, includ-
      ing activists. Agencies tend to overestimate the power of activist groups. These groups
      can't create outrage;  they can only nurture existing outrage.


      14.    Enlist the help, of orfutztthm* tbxt have credibility vita communities.
      Groups that have local credibility (not merely organizations which agencies believe
      should have credibility) can be Involved In helping explain risks. However, this ap-
     proach can't replace foxthrtghtness or more extensive community involvement.


      15,    Avoid "closed" meetings. While casual meetings— the routine turning of gov-
     ernment wheels-are rarely suspect, private meetings-those closed to the public- are
     more likely to cause distrust. The meetings agencies feel they can't afford for the public
     to know about are the very ones the public will probably eventually hear about. You
     may avoid many problems by keeping meetings open.


      16.    If yon are dealing with a situation tn which trust it low,  consider taking the
     following steps:

     a.     Review the outrage factors In Chapter I and the guidelines in this chapter.
            Consider which ones may have been violated.

     b.     Acknowledge the lack of trust: "I know you may feel I cant be trusted because
            the person who handled this case before me delayed in giving you the informa-
            tion...."

     c.     Indicate what steps you plan to take to prevent the trust-eroding actions from
            happening again: "In order to make sure you get information as quickly as
            possible,  I am going to send you bi-weekly updates about the status of the
            situation. These updates will include all new data."

     d.     Ask those who distrust you what they feel would make them more likely to trust
            you. To the extent possible, implement their suggestions.

     e.     Respond on a personal level, when appiuprtate (see Chapter IV).

     f.     Try to reduce  reasons for distrust by sharing information and involving the
            public in developing solutions (see Chapter IV).

     g.     Be patient. Dont expect all the people to trust you all the time, even if you feel
           you are totally trustworthy.

            Because it may take a lot of effort to recoup trust, expect to  go out of your way
     for people.  If you are the person who aroused the distrust, acknowledge your mistakes.
       "Because communities .don't trust us they forget what is logicaL The reason they don't
                                                      ;* Brace Bentley.Cttlzen Partici-
      pation Specialist. New York Department of Environmental Conservation.
•Improving Dialogue with Cominuaiue*.* wrinea by Caroo Oiesj. BilUe Jo Hance. and Pewr Sandman of tbe Environmental CwnHmnie».oo
Research Program at Cook College. Rutgers University, 1987.
                                          23
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YES, BUT....
•     It seems that no matter what we do, some people will never trust us.

      True. However, the fact that you can't earn the trust of aQ the people all the
time does not Imply that you should forgo the effort.  Check to make sure that- despite
a basic commitment to trustworthiness—you have not violated some of the basic prin-
ciples in this guide. The agency may also be confusing trust with agreement; people
can trust each, other's Integrity and still disagree on fundamental matters.
          TEN WAYS TO LOSE TRUST AND CREDIBILITY

        Take a good look at most risk communication "horror stories" and you'll
 probably find a major breakdown in trust between government representatives and
 the public they are supposed to serve. The next time someone comes to you with a
 sob story about communicating with the public, you might want to hand them this
 tongue-in-cheek list. Or better yet, hand It out before the damage is done.

 1.    Bon't involve people in decisions that directly affect their KM*. Then
        act defensive when your policies are challenged.

 2. ..    Hold onto Information until people ore screaming for it. While they are
        waiting, dcn'i tell them when they will get tt. Just say. These things take
        time," or "It's going through quality assurance."

 3.    Ignore peoples' feellngf. Better yet, say they are Irrelevant and irrational.
        It helps to add that you cant understand why they are overreacting to such
 -  N -    a small risk, ';£. , •>;-: 7^'lv :.-.:£-"~^:'. ,  • ' .,. ;'•  '. '•;;• ' ; : .'f ••; • " :;';i : •• ".:; -•-• • ;:- ^;;>x-;- .

 4. -    Don't follow up. Place returning phone calls from citizens at the bottom of
        your "to do" list Delay sending out the information you promised people at
        the public meeting.:   • :    ;

 0.    {f you make a mistake, deny It. Never admit you were wrong.

 ' «. *'   Jf you don't know the answers, fake It. Never say 1 don1! know."

 Tt'    Daft •peak plain English. When explaining technical Information, use
        professional jargon. Or simplify so completely that you leave out important
    ... •  Information,  Better yet, throw up your hands and say, "You people could
   O   not possibly understand this stuff."        , , ,   * " >* V, / -
 .-/  -    '^^M^c^i^--^^^-."  -  -  .       '-'   •  ^V/  .
 6. ,   PhweYitybttrsetriffce a bureaucrat. Wear a three-piece suit to a town
        meeting at the local grange, and sit up on stage with seven of your col-
    -\  leagues who are dressed similarly.                    :,
 '^
 9. -:    Delay talking to other oyencies involved- or other people Involved within
        your agency— so the message the public gets can be as confusing as pos-
        sible. :•_- ;:\ -  r.:-:.- .-=-...-.  .            :  ' . '• -v-V:!-•'.•=:.:  ,= . • . i; /   "


        and has begged not to, tend him or her out anyway.: It's good experience.
       Dulocnc wiA Comimmitie*.* wiinca by Oon Chetf, Bttlk Jo Hucc. Md Peter Sandman at (he Enviroameaa] Cocnmu(bc«,oo
Re«e«rcfa Propun it Cook CoHefe, ftatfen Uaivenity, 1987.
                                       24
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        HI. DECIDING WHEN TO RELEASE INFORMATION
             Perhaps no other aspect of agency communication of environmental risk is so
      closely related to the agency's credibility as its decision about when to share informa-
      tion with the public.  Agencies fear that releasing information early may lead to undue
      alarm or lead to disclosure of incorrect or misinterpreted data. Agencies also hold onto
      information while developing risk management options rather than going to the public
      empty-handed.

             But what agencies view as responsible caution, communities are apt to see as a
      •cover-up" or as bureaucratic intransigence.  When health risks are involved, regardless
      of the level of risk, communities find It difficult to accept any justification for withhold-
      ing information. Therefore, community anger over agency process may block possibili-
      ties for constructive dialogue over the risk itself. Moreover, waiting to release informa-
      tion until the agency has made Its management choices reduces the chances for com-
      munity participation in the risk management process, and thus lessens the chances of
      a solution acceptable to the agency and the community.
                    For example. Susan Santos, formerly with thy foir^'^'ivl pragmsi In
             EPA Region I and currently manager of the Risk Assessment Croup at E.C.
             Jordan Company, was once In a position where the release of test result* was
             delayed for three months while the agency analyzed an additional round of
             samples, interpreted the data, and decided whether EPA or state government
             should take the lead. By the time the agency let the community know the level of
             contaminants In their wells, residents were so upset with the agency that com-
             munication was extremely difficult. If not Impossible.

                    On the other hand. Bruce Bentley. citizen participation specialist with
             the Hew Yoric Depai Oiiem of Envlioimieiital Cunserrauun. teteof « county
             health department going door-to-door sampling wells for TCE and explaining the
             potential risk as soon as there was any reason for suspicion of contamination of
             private wells. Results of the tests were sent by mall. Informing residents of times
             for •availability sessions* with state and county representatives to answer ques-
             tions.  People were alerted to each step of the process before it happened, and as
             a result discussion with the community centered on the risk itself, not on the
             way people were treated.
             The following suggestions provide guidance about deciding when to communi-
      cate and steps to take If you decide to delay release.


      1.     If people are at risk, do not wait to communicate—and to act on—risk in-
      formation.  If a hazard Is putting people at Immediate risk, the agency should follow its
      mandate to protect public health without hesitation.


      2.     If the agency la Investigating a potential risk, that people aren't aware of,
      the agency sfcooM acrtom^y consider' nuking* kimim what tt Is doing and why.
      When an agency announces findings from an Investigation people have not been aware

"Improving Ditlofiie with Communities,* written by Ctroo Chess. BilUe Jo Hiaet. ud Peter Sudmu of (he Eavirouneaul Commumcmon
Research Program u Cook CoUefe, Rutgers University, 1987.
                                       25
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 of. the agency is forced to defend its delay tn announcing the investigation, and to
justify the possibility that people were exposed to a risk longer than necessary. The
 public, in its anger over not being told, is more likely to overestimate the risk and far
 less likely to trust any recommendations that the agency makes concerning the risk
 itself.
 3.     If It teems likely that the media or someone else may release the Informa-
 tion before yon are ready, release it yourself. When information is leaked, agencies
 lose the ability to shape the Issues and are Instead engaged in playing "catch up" at the
 expense of their credibility and the accurate portrayal of information.


 4.     If it is likely that the media will "Oil in" with information concerning an
 ongoing story while they are waiting for yon to speak, speak first.  When you wait
 to communicate about an issue that is already news, the press win shape the issue
 without you.  You may spend more time defending your views or your credibility.


 B.     If yon really don't trust your data, talk to the public about your procedures
 but don't release the data. Obviously, hold onto data for which your preliminary
 levlew shows sdous quality cuiiUul ui methodological flaws. ° However, be up-front and
 tell citizens what has happened and when they will be able to gel some results,


 6.     If the preliminary results do show a problem—and yon are fairly confident
 of the results—release them and explain the tentatlveness of the data. If you are
 fairly confident that the data show a problem, then holding onto data for any length of
 time for any reason is likely to be considered unconscionable. You will leave the agency
vulnerable to charges of cover-up later on and risk creating a great deal of anger.


 7.     Before deciding to wait to communicate—especially if the news is bad—
 consider the effect on the credibility of the agency representative dealing with
 the public. Because credibility can be a scarce commodity, difficult to replace, you
 might make it a major variable tn your decision about timing the release of information.
 hi particular, take into account the effect of your decision on those staff who are dealing
 with the community.


 8.     Release Information while the risk management options ate tentative,
 rather than waiting to develop solutions. If they are not consulted during the deci-
 sion-making process, people are likely to resent  decisions that affect their lives.  Con-
alder, instead, giving people risk management options, not decisions, when you release
the data. Then work with them to develop risk management decisions.  (See Chapter IV.)


ft.     If you feel the Information will not make tense unless released with other
relevant Information—and yon don't have all the information ret—wait to release
  TVhen you're designing On Investigation or a regulatory strategy, the communication
                            uaitd«mto^
                          ^*— -* -- . f* ,— ,  fr, I ^V*MMH«AA«44M»^^r M^^W * Y^MM^^T^MMtt«*VMaM* ff
                          Durac* ucpucy v^r1 Tf liffTffffiffri ifcvucrac^r ucyat uiiciii us
                                                               '
  Health.
         Dufcfoe with r^i»»««itu. • wiauo by Cvoo Oteti. Bill* Jo Haoce, Md Ptter SMdnu of Ac Eavjoaiataul Commume*.™
  Raevcfa Prognin it Cook Cottcfe. Rtt|en University. 19(7.
                                        26
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        •We get a great deal of criticism because people don't know what we're doing.... There's
        always going to be delay: there's always going to be problems. But at least we can tell
        them what we're doing." Gary Sondermeycr, Acting Bureau Chief. Bureau of Solid
        Waste & Resource Recovery Planning, NJDEP.
      it all at once. But explain to the public why you are waiting, and get the Informa-
      tion as toon as you can. If piecemeal release of information would seriously disrupt
      the agency's program or the public's understanding, then, consider delay. But take a
      hard look at whether g"pia**at
-------
•      By releasing Information early, we man cause undue alarm.

       You may cause greater alarm, compounded by resentment and hostility, if you
hold onto information. When people are not given information, they may think that the
truth Is too awful to be told, or they may consider the agency uncaring. Instead, con-
sider releasing information In context and with caveats, if necessary.


»      We run the risk of legal liability tfwe release Information early.

       The number of cases in which ttabflity is a primary concern—rather than a
convenient rationale l» questionable. "Can we do this?" wffl probably eUdt a different
response from a lawyer than "We want to do this, so can you help us deal with any legal
concerns^ If, in fact, there might be a liability problem, vulnerability to legal action
should be weighed against the ten reasons given below for considering early release of
Information.
 , J ; TEN REASONS TO RELEASE INFORMATION EARLY

        Decisions about when to release information depend, in large part on the
 situation. However, agencies should seriously examine the implications of holding
 : onto information. / The "*•* time you contemplate whether to make Information
 public, consider some of the reasons to release information early:         •
  ;il^. People are entitled to information that affects their Itves. V •

   2. -  Eartyrdease of information aets the pace for re

   3. .,.  If you wait the story may leak anyway, Wnett it doeav you are-apt to lose
   4.   You can better'control theaccuracyof ttifonnation If you are the first to
        present it.
                                              r

   5.   There is more likely to be time for meaningful public involvement in decision-
        making if the information is released promptly.

   6.   Prompt release of information about one situation may prevent similar situ-
        ations elsewhere.        '    •-,/, .:;:o%;f;y,:-> :.;:.':^, ;:....•:..-:* -.\ :'•-.}. {'••- '- •.-••'

   7.   Less work Is required to release information early than to respond to Jnquir-
   V 5 * tea. attacks, etc. that might result from delayed release.:

   6. :•  You are more apt to earn public trust if you release Information promptly.

   8,   If you wait, people may feel angry and resentful about hot learning of the in-
        tj,m ji iiLJ •	L •mAvllAW                    '" ''*'!•' ".;.:"•*•". .-.:.'.:; "..-:.•..•-• ••.'.'"•!: .-.:-.•./. .  • :.:-  -"  , '"
     *   lV"i liHITlffri CCUUCX»                 - • " • . •" :*• •'.'-' • •"-•"•"*,•;" :•'-.• ••'{•-• :•':':• .•*.'":•:••:"'.":". -•"•":::•-•. '••  •••••: .'•" -• ••"

   10*  People arc more likely to overestimate the tisk if you ho^ orto Infonziatlon.
              with Comownhiw." wrinca by Cvoe Ow**. Billie Jo H»oee, ud feut Stadmu of die Eavmnmnul
 Reward) Program at Cook College. Rutgen Uaivenity. 1987.
                                         28
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       "Value Judgments are part of the risk assessment process, but IT you are part of defining
       those Judgments and those decisions then the outcome of it is something you can trust."
       Ix>ls Glbbs, Executive Director. Citizens Clearinghouse for Hazardous Wastes
      consider giving people more control.  Community monitoring, oversight, and on-going
      feedback can be measures that help people exert some control over risks and thus feel
      more comfortable with them.

      •      Acknowledge that there are other aspects of decision-making besides risk,
      and be prepared to listen and address people's concerns.  People will often argue
      about risk when they're as concerned about Issues such as property values, because
      risk is considered a more legitimate issue by agencies. As said previously, it is usually
      helpful to recognize, acknowledge, and address these other concerns.

      •      Help people to help their neighbors decide what is acceptable to them.
      Sometimes people can better accept problems when they can talk them over with
      others. Encourage rather than discourage dialogue.


      8.     Take even greater care presenting technical information than presenting
      other Infonuatiua. Many of the keys for presenting technical Information are the same
      as those for presenting fftfry ^^""at j^n but are oftffn overlooked.
      •     Know jour audience and gear your presentation to its level. Think through:
      (a) what the audience already knows; (b) what the audience wants to know: and (c) what
      you want the audience to know. When explaining technical Information, it can help to
      Imagine that you are talking to an intelligent but uninformed friend and speak at that
      level.

      *     Prepare ss thoroughly as you can. Practice your presentations. Role-playing
         also help.
      •     Consider which Information is most important to convey. This often In-
      cludes: (a) the facts your agency wants people to know about a situation: {b) the back-
      ground Information they need  in order to understand the facts: and (c) the additional
      facts they need to know so they won't get misimpresslons. Identify three or four main
      Ideas you want to convey and make sure the details support those points, rather than
      obscuring them by sheer volume.  Finally, make sure to address people's concerns
      rather than just gtvmg the facts.

      •     Be sore to give people sufficient background. Don't assume that condensing
      information is the same as making it clearer.

      •     Use ss down*to-earth language as possible.  Watch jargon and acronyms.

      •     Beware of the tendency to oversimplify and give only data that support
      your point.  People know when you  are using ammunition for your argument as op-
      posed to presenting information.

      •     Choose supporting graphics that Illustrate your message clearly and simply.
      Be cautious about using the sane graphics used for t^ffrifrni audiences. Hastily or ill-
                                  ? than mine* . Evert weO*^jeectej ffl apji h's win not go
      over well If they do not deal with people's concerns.
       Dialogue with Communjtie*." written by Cra Chew. Bflbe Jo HMCC, ud Pcttr Sudmta at the EovnonmeouJ Cooununjc*uoo
Research Propun it Cook College, Rutfen University, 19(7.
                                          40
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 •      Be •ware of body language and other signals your audience gives you that
 they're lost. Slow down, back up. or ask questions.

 •      Rave background material available at meetings.

 •      Always have question-aad-aniwer periods after presentations.

 *      Critique your presentation afterward, so yon eta learn from the things you
 did sight as. veil a* those yon did wrong.
YES, BUT....
•      We still don't have a clear ways to explain very complex Information. If
we did, it's likely the public would understand better.

       It is true that further research is needed about how to explain eiiviiumnental
health risks.  EPA and DEP's Division of Science and Research are both funding proj-
ects in this area. However, regardless of our sophistication in explaining risk, people's
perception of the risk will be influenced by far more than scientific data. If you con-
tinue to stress explaining data and fail to attend to these other variables, you will
probably create problems.


      It is extremely difficult to help people put envfronmentof health rfsfcs fn
                 can't cotnptcre* then rtsLs to other rtsfcs in people's lives.
       Comparisons can be used, but those employed by agencies are frequently not
helpful. Comparing voluntary to involuntary risks and other comparisons that ignore
the outrage factors are apt to make people angry.  The section on comparing risks in
this chapter gives examples of some useful comparisons. Further research is being
done to develop and test others.


•      lit Is difficult to see why on agency should admit uncertainty when people
will use such admissions against us.

       This chapter suggests that people are already alert to uncertainty.  Failing to
disclose uncertainty is likely to undermine trust in the agency. As suggested, agency
representatives should not merely admit uncertainty and then drop the subject. The
uncertainty should be put in context in several ways, as suggested in this chapter.
 "Improving Dialogue with Communititi," written by Ctroo Chut, Billie Jo Hance. and Peter Sandman of the Environmental CommuaK4i..-t>
 Research Program it Cook College, Rutgers University. 1987.
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            VI. TEN MYTHS OF RISK COMMUNICATION

            As with most myths, myths concerning risk communication have an element of
     truth.  But they should not be swallowed whole. The following beliefs often interfere
     with effective risk communication and deserve closer scrutiny.
     2.     We don't have enough time and resources to do risk communication. Risk
     communication does take time and staff. But If yon dent devote efforts to interacting
     with the public, you may be forced to mop up comrannlcatlora disasters- which typi-
     cally takes more resoun
     Suggestion: Tr_i. t!;e staff you have. Including clerical staff who answer the tele-
     phone, to communicate more effectively. Flan projects to Include time to Involve the
     public.
     2.     Communicating with the public about a risk ts more likely to unduly
     alarm people than keeping quiet. Risk communication can be risky. But not giving
     people a chance to express their concerns is likely to increase rather than decrease
     Suggestion: Consider releasing information earlier rather than later.
     3.     If we could only explain risks clearly enough, people would accept them.
     True, explaining risk Is Important. But data are not the only factors which influence
     people's perception of risk.

     Suggestion? Pay as much attention to your process for dealing with people as you do
     to explaining the data.
     4.     We shouldn't go to the public until u>e have solutions to environmental
     health problems. Problems can seem easier to deal with when coupled with solutions.
     But falling to involve people in decisions that affect their lives may result in tremendous
     Suggestion: Release risk management options, not decisions, and involve communities
     In discussions of risk management strategies in which they have a stake.


     5.     These issues ore too tough /or the public to understand. Environmental
     health issues can be complex.  But as demonstrated by citizen groups throughout the
     country. laypeople can grasp a great deal of the substance.

     Suggestion: Do not assume that the public's disagreement with your policies indicates
                             science.
       Dutocne with Commonhiei." wmca by Ctroe Chest. Billie Jo Hucc. ud Pfler SimfanM Of the EnvirMunenuI CammunicJiioa
Research Progrwn it Cook Ccltefe, Rmfen University. 1987.
-------
 6.     Technical decisions should be lejt In the hands qf technical people. Tech-
 nical staiTgenerally are better versed in the scientific aspects of environmental health.
 But many of the problems government deals with raise policy and values issues that go
 beyond the technical realm.

 Suggestion: Develop mechanisms to listen to communities' concerns about policy and
 values issues. Inside the agency. Involve staff with diverse backgrounds In developing
 policy.


 7.     Risk communication is not my job. True, you were probably hired because of
 other credentials. But as public servants, agency staff have a responsibility to deal with
 people.

 Suggestion: Learn to Integrate communication Into your job and help others to do the
 same.
a.     tf we glue. Che public on inch, they'll take a mile. If the Interaction with the
community more closely approximates a battleground than a discussion, this may be
true.  But if you listen to people when they are asking for inches, they are less likely to
demand miles.

Suggestion; Avoid the battleground.  Involve people early and often.
9.     If tue listen to the public, we will devote scarce resources to Issues that
arc not a. great threat to public health. In any public policy arena we can find such
inconsistencies. But dosing out the public Is likely to cause distrust and farther skew
the policy debate.  ~

Suggestion: Be sensitive to public concerns. Otherwise you will unwittingly create
controversy and contribute-to raising the profile of Issues of lesser significance.
10.    Activist groups ore responsible/or stirring up unwarranted concerns.
True, activists help to focus people's anger.  But activists do not create the concerns:
they merely arouse and channel those that already exist.

Suggestion;  Deal with the groups and their concerns rather than merely fighting
them.
 "Improving Dialogue whh Commuaiuei." written by Caroa Cheu. Bribe Jo HIDES, aad faa Sandman of the Eaviraimeata] Communication
 Research Program at Cook College, Rutgers University. 1987.
                                           43
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                   DRArT

WORKSHOP ON RISK COMMUNICATION
                              i

 U.S. EPA Risk Communication Project

                   SOURCE: Drawing by Richten Z '938

                   The New Yorker Magazine, Inc.
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44
-------
                      1HE STATE UNIVERSITY OF NEW JERSEY
          ;    ;   i Environmental Communication Research Program::
   "-;..•-         ;;  A program of the Agricultural Expertment.Stqttori <
    Cook. College * 122 Ryders Lane • NewBnjnswick* New Jersey 08903 •201/932-8795
    TEN WAYS TO LOSE TRUSi; ANJD:
                           . .. ;  /;-:.:J:^i;''.;:^;fif^^
       Take a good look at most risk cbrnmu&raUpn"^                     proba-
bly find a major breakdown in trust between government representatives and the public
:they are supposed to serve.  The neatt time someone comes to you with a sob;story
•about communicating with the public.you might want to hand them this tongue-in-
cheek list. Or better yet. hand it out before the dainage is done.
 J.  Don't involve people In decisions that directly affect their lives.  Then act de-
    fensive when your policies are.challeiig^'i^"t^i^|!^^W^;^:
                                -• •.' -••..;-•• .-;-; ,:.:•.•;•.•'•; ;. :'•:•:•''••''<•: •'•'• 'V^^:^:^:^:^^''^^!:^-:^-:-1.';'^'

 2. r Hold onto information until people are screaming for: Jit;: while they are wait-
    ing, don't tell them when they will get it;•; Just say;:!^iraethings;taketlnie.'' or "It's
    going through qu<
3.:;i Ignore peoples'feelings.  Better yet, say they are irrelevant and irrational. It
    .helps to add that you can't understand why they are overreacting to such a small:
    • -  *  , ,   	   .  »       ...         ....•»••••-.» ,••• • • -.•.-.-..-- -..,-, -....,- -	*& -  	  , .-,,.,-..-,-
    risk.
4. u: Don't/ollouj up.  Place returning phone calls from citizens at the bottom of your:
    "to do" list Delay sending out the information you promised people at the public
    :meeOng...

5.  If you moke a mistake, deny it. Never admit you were wrong.

6.  Jfj/ou don't know the answers, fake iL JNeversay "I don'tJoiow,"
          •  •        •:   _                   ^  .   tvv  -   - 4'-
7,"" Don't speak plain English. When explaining technical information, use profes-,
    sional jargon.  Or simplify so completely that you leave outimportant information.
    Better yet» throw up your hands and say. "You people could not possibly under-
    stand this stuff."   :    i.                .        'a£T\  '
6.  Present yourself Hfce a bureaucrat. , Wear a three-piece suit to a town meeting at
    the local grange, and sit up on stage with seven of your colleagues who are dressed
    similarly.                                  ;

9*  Delay talking to other agencies involved— or other people involved within your.; -
    agency— so the message the public gets can be as confusing as possible. -

10. {f one of your scientists has trouble relating to people, hates to do it, and
    has begged not to, send him or her out anyway.-It's good experience;
From C.
OO
1SJ",
                Hancer..B'.j;, and.- Sandman,
                 Short-Guide For
             «f. Science: .and. Reseaucciiv
Rl*k COJ»naaicat±oar*
                                     87)
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                     Selected Bibliography
                        Covello, Vincent T., "The Perception of Technological
                      Risks: A Literature Review," Technological Forecasting and
                      Social Change. 1983. pp. 285-287.


                        Covello, Vincent T., Detlof von Winterfeldt, and Paul
                      Slovic, "Communicating Scientific Information about Health
                      and Environmental Risks: Problems and Opportunities from a
                      Social and Behavioral Perspective," in V. Covello, A.
                      Moghissi, and V.R.R. Uppuluri, Uncertainties in Risk
                      Assessment and Risk Management  (New York: Plenum
                      Press, 1986), in press.


                        Fischhoff. Baruch, "Protocols for Environmental Reporting:
                      What to A*k the Experts," The journalist (Foundation far
                      American Communications), Winter 1985, pp. 11-15.


                        Klaidman, Stephen, "Health Risk Reporting," Institute for
                      Health Policy Analysis, Georgetown University Medical
                      Center, Washington, DC, 1985.


                        Mazur. Allan, "Media Coverage and Public Opinion on
                      Scientific Controversies, /ournol of Communication. 1981.
                      pp. 106-115.


                        Mazur, Allan, "Bias in Risk-Benefit Analysis." Technology
                      in Society, 1985. pp. 25-30.


                        Nelkin. Dorothy, Science in the Streets (New York:
                      Twentieth Century Fund, 1984).
                        President* Commission on the Accident et Tnrw Mile
                      bland, Report of the Public's Right to Information Task Force
                      (Washington; DC: U.S. Government Printing Office.  1979J.


                        Ruckelshaus, William, "Risk in a Free Society," Risk
                      Analysis, September 1984, pp. 157-163.


                        Sandman, Peter M.. "Getting to Maybe: Some
                      Communications Aspects of Hazardous Waste Facility
                      Siting." Seton Hall Legislative Journal, Spring 1986.
       1 Eoviroaiaeaul Risk: Some Noui OB Eavinameatil Risk Coaunuwcukw," by Ptut M. Stndnao for UK TSCA Auiiuncr
Office, Office of Toxic Subnucet, VS. Eavatmaeaul Praecuoc AfCKy. November 1986.
                                           116
-------
                        Sandman, Peter M., David B. Sachsman. Michael
                      Greenberg, Mayme Jurkat, Audrey R. Gotsch, and Michael
                      Gochfeld. "Environmental Risk Reporting in New jersey
                      Newspapers." Environmental Risk Reporting Project,
                      Department of Journalism and Mass Media, Rutgers
                      University, January 1986.


                        Sharlin, Harold I., "EDB. A Case Study in the
                      Communication of Health Risk." Office of Policy Analysis,
                      U.S. Environmental Protection Agency, January 1985.


                        Slovic. Paul, "Informing and Educating the Public About
                      Risk." Decision Research Report 85-5. November 1984.


                        Slovic, Paul, Banich Fischhoff, and Sarah Lichtenstein,
                      "Facts and Fears: Understanding Perceived Risk." in R.C.
                      Schwing and W. Al Albers. eds., Societal Risk Assessment:
                      How Safe Is Safe Enough? (New York: Plenum, 1980), pp.
                      181-216.
                        Weinstein, Neil D., and Peter M. Sandman,
                      "Recommendations for a Radon Risk Communicatioa
                      Program," Office of Science an
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118
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                         PUBLIC MEETING

         TYPICAL QUESTIONS & SAMPLE RESPONSES


                             Prepared by

     CDR Ahrin Chun, USPHS, Senior Enrironment*! Health Policy Advisor
                   Arnold R. Den, Senior Science Advisor
                   Office of the Regional Administrator
               U.S. Environmental Protection Agency, Region 9
      Following is a list of questions which, are often asked by the public,
along with some typical responses. The list is taken from EPA, Region 9's
Risk & Decision Making and Risk Communication & Public Involvement
Courses. It serves to illustrate the use of EPA's Seven Cardinal Rules of Risk
Communication and the careful preparation that is required.

      The authors welcome your comments and any suggestions for
additional questions. Based on your responses, the list may be expanded or
revised. All comments may be directed to the authors at (415) 744*1019 or
744-101&
      A CAUTION TO THE READER - The sample responses are offered
      only as ideas, from which you must develop your own responses.
      The responses are not intended to be memorized and used
      verbatim A response may be used only if it addresses the
      specific needs of your audience, and it is comfortable for both you
      and your agency. Your responses must be open, honest, frank,
      and meet ike needs of your public or audience. It may not be
      obvious, but developing your responses usually requires policy
      input from management as well as technical input from other
      credible sources.  This preparation is essential to your performance;
      if you fail to prepare, you can t expect to gain the important trust
      and respect of our public constituents, and you wont be effective.
  Cardinal Rule §2 from EPA'i Seven Cardinal Rules of Rick Communication (Sec page 1)
                              119
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                               EPA's

    Seven Cardinal  Rules of Risk  Communication
        1. Accept and involve the public as a legitimate partner.
            (CRl)
        2. Plan carefully and evaluate your performance. (CRZ)
        3. Listen to the public's feelings. (CR3)

           (Examples of "active listening* are offered in some of the
           responses to the questions which follow. These specific
           examples are underlined for easy reading.)

        4. Be honest, open, and frank. (CR4)
        5. Coordinate and collaborate with other credible sources.
           (CR5)
        6. Meet the needs of the media. (CR6)


        7. Speak dearly and with compassion. (CRT)
'Public Meeting: Typed Questions «ad Sunple Recpoues," By Alvin Chun ud AraoU R. Den. Office of the Refloat! Admmuuai.i
Office of At Senior Science Advisor, EPA Refioa 9, revised luuuy 1992.
                                120
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      1.    Q.    Why can't I ask my question now?

           Underlying Public  Need:  The Agency agenda isn't working and the
           public would like their concerns and questions addressed first.

      •  Reminder Note; Underlined sentences arif examples of "active listening "

           A.    Sounds like there are a lot of questions that need to be answered
                 now> Maybe we should do that first and save the rest of the
                 agenda for later? Is that OK? (Prindples: Listen,, feedback, and
                 accept the public as a legitimate partner in deciding on the
                 agenda.) (CR1,3)

           A.    J[ know yy»  all have  a lot of questions that you want answered.
                 Would it be alright if we proceed with the 20-30 minute
                 presentation, where I suspect that many of your questions will be
                 answered, and then leave the next period of time for the rest of
                 your questions? (Pnnciplesi Tictpn, faofH-^rfc with a
                 recommendation and accept the public as a legitimate partner in
                 deciding on the agenda.) (CR1,3)

           A.    Poor Response: Please let me finish my talk! (Not listening to
                 the audience's need for answers to their questions, and giving
                 the impression that we don't care and that we know better than
                 they do. Thus, we are not treating them as legitimate partners.)

           A.    Poor Response: Please (mfffr hand raised at audience) all
                 questions will be taken after our presentation! We need to
                 follow the agenda. Let us give our presentation  and then we'll
                 take questions.

      2.    Q.    Why won't you answer my question? (This is usually a follow-
                 up question to Question #1 when the Agency insists that
                 questions will be answered only after the presentation.)

           Underlying Public  Need:  The public would like to vent feelings and
           have us listen and  be responsive so that they can find out  if we are on
           their side and taking adequate action.  Also, they may not  want a
           "slick" presentation but are more  interested in direct answers  to their
           personal questions.

           A.    I apologize if we have not answered your questions. I have
                 written your questions here (on flip chart), and I have saved this
                 part of the agenda to answer them. I think that many of your
                 questions will be answered in the 20-30 minute presentation that
                 we have prepared, and it may save everyone some time.  Our
•Pnbbe Meeting: Typical Question! «ad Sample Reipoiuei,* By AJvin Chun and Arnold R. Deo. Office of the Refknul Administrator
Office of the Seoior Science Advisor. EPA Region 9. revised  Unuiry 1992.
                                       121
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        presentation will cover some important questions which may be
        on your mind such as, "Is my family safe?  What are we
        planning on doing about it? What's been going on?" If that
        sounds like it will work for you, could we proceed?  And if it
        isn't working, then we'll  have to think of something else.
        (Principles: listen, feedback with helpful suggestions and
        involve the public in deciding how to proceed.) (CR 1,3)

  A.    You've asked a very good question and maybe we haven't been
        listening ton well- How many of you have questions and would
        like them answered? I see there area lot of questions. Let me
        make 1 suggestions for how you might want to proceed, and you
        can tell me if either one sounds good.  (Principles: Listen,
        feedback with helpful suggestions and involve the public in
        deciding how to proceed.) (CR1,3)

        One suggestion is to answer your questions first until they are
        all answered, and then if you are still interested and have the
        time, we could give our 20 minute presentation.  Also, we have
        a fact sheet which, summarizes much of the presentation if you
        can't stay for the whole meeting.

        The other suggestion is to let us give a 20-minute presentation
        so that everyone will have some common  understanding of the
        situation, and be able to ask some questions which they may not
        have otherwise. We have a 20 minute presentation, and it may
        answer many of your questions.  After the  presentation, we can
        spend the rest of the evening answering all your questions.
        Since there are a lot of questions, and many of you can't stay pass
        11 P.M., when die meeting was suppose to end, we will try to
        accommodate your questions first and stay until all  your
        questions have been addressed.

        Now tef s have a show of hands to decide how we should
        proceed. How many would like to hear the presentation first?
        How many would like to get at the questions first?

  A.    Poor Response  Sir, if you would just let me finish, HI get to
        your question at the end, and we'll answer all questions then.
        (Not listening to the public Agency is more concerned about
        sticking to the agenda and  maintaining control of the meeting.
        In its attempt to maintain control, the Agency will likely lose
        control. An important point to consider: If your meeting goal is
        to give your presentation at any expense, then this would have
        been a-good response, llowevts, tins is usually not our intended
        goal. Otxr goal normally is to try to meet the needs of the

"PttWie M
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            community in trying to solve the environmental problem.
            Given that as our goal, if a community is insisting to be heard
            we should recognize their need and try to meet it, or present
            them with alternatives that meet both their needs and the
            Agency's, and let them choose.)

3.    Q-    What have you done about it? Why are you taking so long?

      Underlying Public Need:  The public would like to know  if we ere
      being responsive in correcting the problem, and. if we care,

      A.    Sir, you'd like to know what we're doing, and you're angry that
            it's taken so long. We share your concerned about taking care of
            this as quickly as possible. Unfortunately, there are no simple
            solutions for cleaning up hazardous waste sites. Each site must
            be carefully characterized before a clean up plan can be made to
            enable us to do a good job. This takes longer than we would all
            like but it is needed to ensure that it is done right in order to
            safeguard public health. We are proceeding as fast as we can, and
            here's what we are doing:	— (Principles:  listen, feedback,
            share concern, and answer.) (CR3,4,7)

      A.    Poor Response:  Ah, Ah, Ah	Don't you know we're doing our
            best!  (Didn't have an answer, wasn't prepared to answer a basic
            question, and became defensive.  This increases the public
            outrage which delays discussion on options and solutions.)

      A.    Poor Response:  I have 5 other sites that Fm working on and I'm
            working hard on all of them.  (The public is not interested in
            other sites or excuses. They want to know what we are doing
            about their site to protect them.)

4.    Q.    Why haven't you dosed the plant? How many more cancers do
            you want?

      Underlying Public Need:  The public is  worried about cancer  (or some
      other health issue) end needs to know how  we're  planning on
      addressing the  problem end  if we care about them.   To the public,
      dosing the  plant is e  logical solution.

      A.    We share your concerns about health. Let us assure you mat the
            plant isn't posing an immediate health hazard where dosing the
            plant would be needed. However, a long term and constant
            exposure to DNC could present a health hazard, and that is why
            we are i'"tiM'*c*ng nanw immediate Actions which  will ensure
            your safety.' Here's what we are proposing, and we believe this

  "Public Meeting: Typical Quenions ud Su?le Retpouei.' By AlwB Chun u4 Arnold R. Den. Office of the Regional Admimsifii J
  Office of the Senior Science Advisor. EPA Region 9, revued Juuar> 1992.
                                     123
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            will correct the problem, protect your health, and not create a
            hardship for the people who are currently employed at the plant.
            (Principles: Give a direct answer that addresses our concern for
            protecting people's health and welfare, and state our actions.)
            (CR3,4,7)

      A.    Poor Response:  Let me finish my presentation!

      A.    Poor Response:  We've been working with the plant, and we
            don't think that if s necessary!

5.    Q.    Is it safe? Are my kids safe?

      Underlying Public Need:  The public needs to know if there is any
      immediate danger to their family and that  we care about that.  They
      want "micro" risk answers to the "Am 1 safe?" questions, not "macro"
      risk answers which the Agency has been concerned with in their
      decision mating, tev "The hazard presents a 10*5 rfej. ^ ^
      community."

      A.    Your concern for safety is our concern also.  Any cancer causing
            agent is potentially dangerous (The non-threshold concept).
            DNC is such a substance. Based on our knowledge of the
            amount of DNC that people are being exposed to, we feel it is
            safe for all residents east of Electrobotics because DNC isn't in the
            air or drinking water.  For residents to the west of BecUubutics,
            DNC is only present in the air, bat in such sired! quantities that
            exposure will only be  a health concern if it is not reduced in the
            next several years. We are proposing to reduce and minimize
            the exposures to DNC by permanently capping the source of the
            DNC to eliminate its presence in the air, and cleaning up the
            contaminated soil to minimize any contamination of the water.
            This will make It safe (CR 3,4)

            For a more typical case when the contamination cannot be
            totally removed from the ground water, a response could be:

      A.    Your concern for safety is our concent also.  Any cancer-causing
            agent is potentially dangerous (The non-threshold concept).
            DNC is such a substance. Based on our knowledge of the
            amount of DNC which people are being exposed to, we feel it is
            safe for all residents east of Electrobotics because it isn't in the air
            or drinking water.  For residents to the west of Electrobotics,
            DNC is only present in the air, but. in such **"»n iTnantitifj that
            exposure wffl only be a healm concent fg ft:fa not reduced in the
            next several years. We are proposing immediate actions to

•Public Mecliof: Typical Qoenoai aod Sample Reqnom.* By AJvin Qiua wd Arnold R. Deo, Office of the Regional Adnioiitiwar
Office at AK Settlor Science Advisor. EPA Region 9. revised January 1991
-------
            reduce and minimize the exposures to DNC by permanently
            capping the source of the DNC to eliminate its presence in the
            air, and cleaning up the contaminated soil to a safe level. (In this
            case there will be a finite but small concentration of DNC
            remaining in the drinking water, but it will be at a level which is
            between 10"* to 10"^ risk which we, as Agency personnel, have
            established in the regulatory processes for various air, and water
            standards as being "safe." This still may not be acceptable to
            some people, and understandably so, especially if they hadn't
            been involved in the decision making process. Similarly, it may
            not be acceptable to you as an Agency person because the risk is
            not zero, and a residual risk remains.)  (CR 3,4)

      A.    Your concern for safety is our concern also. We believe it is safe
            for you and your kids to drink the water and breath the air.
            There is no DNC in the drinking water, but we feel there will be
            in the future if a leak from  the company's holding pond is not
            controlled. There is some DNC contamination in the air and
            this will become a dangerous situation if it is not controlled and
            people are exposed to it over their entire life. (CR 3,4)

      A.    Poor Response: The life time risk of getting cancer based on the
            current level of DNC in the air is 10"4. Based on that estimate,
            we feel Hut we should  reduce the risk to a level of 1(T6.  (What's
            probably not needed here is more jargon.)

6.     Q.    Are?Uieirtxtyssftlevelsfor*cAixiiiugen? (Class A, B, or C
            carcinogens)

      A.    Your question on carcinogens is an excellent one. EPA has
            identified some chemicals as (A) known, (B) probable or (C)
            possible human carcinogens based primarily on human data (A),
            and on animal studies (B and Q. If we believe it to be a
            carcinogen, we assume that all levels of exposure will have
            some level of cancer risk.  The smaller the exposure, the smaller
            the risk. We generally  describe these risks in terms of
            probability. If in asking your question, you want to know if there
            are levels of exposure mat are free from risk, the answer is no.
            If, on the other hand, you are asking whether certain levels of
            chemical exposure are too small to be of a health concern, men
            the answer is yes. Our goal is to reduce the level of exposure to a
            safe level where it will  be safe to drink the water and breath the
            air.  (Remember that a  safe level does not necessarily mean zero
            risk. T* r*piJA ntftaTr faf twampl^ thitt 10"* Or 10"^ Ttfk fe f Jlife
            level. There are many reasons why zero risk may not be feasible,

  "Public Mwuog: Typical Qaettuaa in
-------
            but one must also remember that 10~* or 10~5 are upperbound or
            maximum risks. This means mat the actual probability may be
            much lower and may even be zero because of all the health
            protective assumptions that are used.)  (CR 3, 4)

7.    Q.    Would you drink our water? What about breathing our air?

      Underlying Public  Need:  Again, the public would like  to know how
      this affects their family and if we are. sincere about our  concern for
      them.

      A.    Yes, I would drink the water because it is not contaminated, and
            I am here breathing the air because it is such a low risk mat it
            isn't a health problem.  I understand that some of you may feel
            that any concentration of PNC in the air is unsafe. If you feel
            that way,  ! would recommend that you consult with your doctor
            or do what you feel will make you more comfortable.  However,
            we feel there is no immediate hazard, and we can dean, up the
            situation so mat mere will be no long term health concern. (If
            there was an immediate health hazard, in emergency response
            action would be ordered, and bottled water could be offered or
            recommended if the drinking water  was contaminated.)
             too are concerned* *"^ that is
            why thedeazMip .plan that we are proposing addresses the
            concern for safety. The plan will dean up the contamination to

 'Public Meeting: Typical QIMMMM lad Staple Reipoexa." By Aiwa Onto ud AnoU R. On, Office at the Re(k>otl Admiainraior
 Office 
-------
             a safe level. However, it sounds like you might be more
             comfortable with a greater-than-safe level which we are
             proposing. I can't make any promises, but I would be interested
             in any ideas or concerns which you may have. But at this time, I
             am confident that our proposal will make it safe for you and
             provide the level of health protection which you are expecting.
             (011,3,4,7)

       A.    It's unfortunate that there is so much sickness.  I am concerned
             and sad to hear that Our goal is to make it as safe as possible
             with your input.  I believe we can develop a solution to control
             the risk.  (CR3,4,7)

       A.    Poor Response: It's acceptable because the risk is 10^. Based on
             that risk level, we don't see how those illnesses  and cancers can
             be attributed to DNC

       A.    Poor Response We don't know what caused the cancers.
             However, you should know that 1 out of 4 of you win get cancer
             in your lifetime because of everyday activities and exposures.
             For example, it's more likely that you'll get cancer from eating
             peanut butter or charcoal broiled steaks than it would be from
             exposure to DNC. (Whether this is true or not is irrelevant
             when people are upset.  The people want to be involved.
             They are not asking for an explanation. In mis case, an
             explanation belittles the public and their concerns over the site.)

9.     Q.    What does 1X10 •* mean? What brisk?

       Underlying Public Need:  The public needs  to know if we're trying to
       "snow them" with jargon or if we're looking after their best interest.
       Discussing first how  the situation affects  them personally, i&.,  "Is it
       safe?" will reach people directly and get at  their needs.  Then, the public
       may want to have specific technical discussions about  risk calculations.
       Often, if the agency has done a good job addressing the  'Is it safe?"
       question with honesty and compassion, the agency  will have
       established some level of trust  and credibility where the public will be
       willing to focus on the 10~6 terminology.  Surprisingly, if the agency
       has done its job well in  establishing trust and credibility with the
       public, the public's need to know about 10~6 will not be needed!  Often
       times agencies  tend to focus on the I  issues  too soon with the public
       without adequately addressing  the real public concerns.  This  then
       creates a diversion to argue about  1&* and misleads the agency to
       think that  if only they could heoe explained 10* better, it would have
       not created an argument with  the public.  The  argument was probably

"Public Meeting: Typical QuesiioaJ lad Simple Re*poose*." By Alvia Quia tad AraoU R. Dea. Office of UK Region*! Adnunmm.x
Office of tbe Senior Science Advisor. EPA Region 9. revued Jiauiry
                                 127
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      over the agency not listening, and as • result some underlying public
      needs were probably not met.

            Assuming that this question is being asked at a technical
            meeting, some answers could be:

      A.    Risk is the probability or chance of getting cancer. IxIO^is
            another way of saying one-in-a-miliion chance of getting cancer
            (above the normal background ran due to aH

*PubUc Meeting: Typical Question* wd Sample Refpoue*.* By Alvin Chun and Arnold ft. Den. Office of the Refiooal Admnunraim
Office of the Senior Science Advisor, EPA Reajoo 9. (erited January 1992.
                                       128
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               other causes, about 250,000 cancer cases in a population of one
               million people.

               You should also realize, however, that there is a great deal of
               uncertainty that accompanies our risk estimates. Science has not
               yet progressed far enough to explain exactly how cancer is
               caused. Nor can we ever be absolutely sure of the levels of a
               chemical that are present in the environment  But in order to be
               protective of public health, our risk assessments are designed to
               account for the various uncertainties.  la fact, where our
               information is incomplete, we use assumptions that tend to
               overestimate the risk in order to further insure that we are being
               health protective. As a result, when we estimate that mere is a
               one-in-a-million risk, the actual risk has very little chance of
               exceeding one-in-a-million.  In  actuality, one-in-a-million most
               likely overestimates the actual risk, and, in fact, may be zero.

               Assuming that this question is being asked at a non-technical
               public meeting, some answers could be:
         A.    IX 10~  is an expression which scientists often use to express one
               chance in a million.  This in risk terms means one chance in a
               million of getting cancer from being constantly exposed to a
               certain level of a chemical over one's lifetime of 70 years. If that
               still isn't a good enough explanation, let me explain it another
               way and hopefully, this will be more helpful: DNC is a
               dangerous chemical because we have reasons to believe mat it
               may cause cancer. Currently, there is no danger to you if you
               drink the water because it isn't contaminated. The air is
               contaminated with DNC, but in such small levels that it is safe
               in the short-term provided we further reduce the contamination
               to a lower level where it will be also safe in the long-term. I'm
               sorry  if this sounded confusing because on the one hand we're
               saying it's sale m the short term, but on the other hand we're
               proposing to dean it up which will make it safe in the long term.
               If this is still confusing, let me use an analogy which may make
               this a little dearer. Some of you may say that my example is
               ridiculous because it will never happen, and you're right, but for
               a lack of a better example, allow me to try mis one just to see if it
               gives  you at least a better feel for what we have been talking
               about:

               Imagine mat there's a pallet of cement weighing 900 Ibs
               suspended over your house. The pallet is being held by a cable
               which is rated at 1000 Ibs. You are safe because the cable hasnt
               snapped and it isn't likely to. You may feel safe for a long time

'Public Meeting: Typical Qoexiooi ud Simple Rttpoom.' By Alvin Qnu tad AnoU R. Deo. Office of the Region*) Admiaimu.*
(Mice of die Senior Science Advisor. EPA Region 9. reviled Juuary 1992.
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Evaluating Risk Communication Programs
      Budget:                  Low
      This tool helps agencies assess their perception of the potential impact that important
actors can have on a decision or course of action.  Agency staff identify stakeholders and
numerically rate each of them in three categories:  issue position, power, and salience.
These ratings allow a calculation to determine whether ihc stakeholder might oppose,
support, or be neutral toward a decision. This tool guides the agency's internal assessment
of rclevantstakcholdcrsand involves no formal dan collection. It is a means for organizing
and comparing perceptions of stakeholders to anticipate reactions  to a decision or issue.
However, ihc ratings arc based solely on the perceptions of agency staff and arc only as
valuable as those perceptions.

  2A-2.  Audience Analysis Matrices
      Purpose:                 To identify relevant audiences and organize agency
                                perceptions of their reactions, involvement, or posi-
                                tion in a communication effort
      Lead Time:               Low
      Staff Time:               Brief
      Budget:                   Low
                                                                  i
        Ma trices are developed which identify relevant audiences and cross-reference the
audience with another important variable— such as issue position, anticipated reactions,
or issue importance.  These matrices allow a  graphic representation of groups in a
communication effort while also encouraging greater awareness of the specific audiences
and their qualities. These ma trices arc based only on the perceptions of agency staff—they
involve no data collection. The instrument may be  limited by the degree of knowledge,
intuition, and sensitivity present within the agency.

2B. JVcIiminarv Audience Feedback
         These techniques involve collecting information about an audience in advance
of communicating to help anticipate the audicnccs's needs and interests.


2B-1. Audience Infer/nation Needs Assessment
      Purpose:                 To gather questions from relevant audiences in ad-
                                vance of public meetings so a response can be orga-
                                nized and presented.
      Lead Time:                Moderate to  high—requires a number of weeks to
                                mail out inquiry, receive responses, and organize the
                                information. Lead time may be decreased if telephone
                                contacts arc used  instead of mailed inquiry.
      Staff Time:               Moderate
      Budget:                  Low to moderate

        Questions from an audience arc gathered in advance of a public meeting so agency
stiff can develop a meaningful response. The agency response may involve both written
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                                        Evaluating Risk Communication Programs
and verbal answers to the questions. This approach, which helpsagencies meet community
needs, establishes a precedent of listening to the audience and responding to its concerns.
However, it may require loo m uch lead time for a crisis situation, and the answers generated
in advance may still meet with disagreement and dissatisfaction from the audience.

25-2. Analysis of News Clippings
      Purpose:                 To identify audiences and their concerns. To develop
                                some historical knowledge of a community to help in
                                planning future phases of a communication effort.
       Lead Time:               Variable, depending on how far back in time the
                                analysis goes.
      Staff Time:               Variable, depending on the extensiveness of the re-
                                view.
      Budget:                  Low


        Background information about on-going issues is obtained by locating appropriate
newspapers and clipping articles relevant to the issue in question. The clippings can be
analyzed for a variety of factors, including perceptions of prior agency behavior, public
concerns, principal actors, key events, and community mood. While a useful source of
input and background information, news clippings may reflect media biases, journalistic
sensationalizing, and the inaccuracies of the rush of daily reporting.


2B-3. Public Opinion Polling
       Purpose:                 To assess audience opinion or reaction; to find out
                                what people see as important problems, what issues
                                and events they are aware of, and how they evaluate
                                social and political institutions.
      Lead Time:               Moderate,dependingonhowformalapoSlisrequired.
      Staff Time:               Moderate
      Budget:                  Moderate to high—may involve contracting with a
                                polling firm to obtain useful results. A low estimate
                                for a very brief formal poll with a relatively small
                                sample is about $2000. Informal telephone  surveys
                                may require fewer resources.

        Polling can give agencies a sense of public attitudes and perceptions so the agency
can better target its communications. Carefully constructed polls can  help  prevent
surprises and provide a baseline for ihc later evaluation of the communication effort
Agencies may hire firms to design and conduct polls on specific issues. These polls benefit
from careful development of the polling questionnaire and random sampling to increase
the reliability of ihc data. They may also be quite expensive. Informal telephone surveys
involve briefer questionnaires  and smaller samples.  Informal surveys may be  more
practical and less expensive, but also less reliable.  Polls and surveys tend to consist of
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Evaluating Risk Communication Programs
closed-ended questions that limit the richness of the data and can fait to convey the
complexity of public perception.

2B-4. Public Opinion Polling/Pollstart
      Purpose:                  To organize and analyze polling data on personal
                                computers available within agencies.
      Lead Time:               Moderate to high, depending on extensiveness of the
                                poll,  expertise in polling  design available, and
                                knowledge of personal computers.
      Staff Time:               Moderate—depends on previous expertise and skills.
      Budget:                   Moderate.  Pollstan software costs $98.00; Public
                                OpinionPolling.abook that guides useof the software,
                                costs  S 19.95.

        Pollstart is a piece of computer software which allows agency staff to tabulate and
analyze polling data on a typical office personal  computer. The manual for Pollstan
provides step-by-step guidance on how to encode the data within computer files and how
to generate "frequency reports" and "cross-tabulations." Public Opinion Polling provides
useful, background on polling and a useful outline of the steps in planning and developing
a poll., The book was written as a companion volume for the software. While this system
provides an excellent review of polling issues, it docs not make the reader a survey design
expert, and  less experienced  readers may still have difficulty designing appropriate
surveys. The software is also not capable of doing more complex data analysis.

2B-5. Qualitative Questionnaires
      Purpose:                 To collect information from people whom agencies
                                have  involved in a communication effort
       Lead Time:              Low  to high,  depending on the complexity of the
                                questionnaire and the lime needed to develop it. May
                                also require at least two weeks to receive responses to
                                mailed questionnaires.
      Staff Time:               Low to moderate—depends complexity of feedback
                                to be tallied.
      Budget:                   Low  to moderate

        Questionnaires are developed, usually in-house, to assess audience positions on
issues or responses  to agency process. Because they may involve a small sample, the
feedback may not be statistically accurate or gencraliiablc. These questionnaires can still
provide early input about specific directions an agency might take, or reasonably rapid
assessment of audience reactions. Questionnaire development, distribution, and tallying
can take considerable effort

3. Message Pretesting
        Agencies can  obtain useful feedback on written materials by having them
reviewed (pretested) in advance of production and distribution. This input can significantly
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                                        Evaluating Risk Communication Programs
improve materials so they are more easily  understood and communicate the intended
message more effectively.  Message pretesting may involve surveys and questionnaires,
discussion groups, and/or reviews of the language used in a document. Agencies can assess
whether ihc document is too complicated for the intended audience, the amount of jargon,
and other aspects of the writing style. We found the work of the National Cancer Institute
(198-4,1989) to be of great value in exploring and assessing these techniques.

3A.  Brief Approaches
        These techniques give feedback in a short amount of time.

3/4-7 „ Rightwritcr
      Purpose:                  To  review documents written on computer word-
                                processing programs  for errors in grammar, style,
                                usage, and punctuation.
      Lead Time:               Low
      Staff Time:                Low
      B udget:                   Rightwritcr software currently costs $95.00.

      Rightwritcr reviews documents on computer and creates a "mark-up" copy, includ-
ing feedback on grammar, style, usage, and punctuation in the text, as well as a summary
of the analysts.  This summary includes a readability  quotient, a strength  index, a
descriptive index, a jargon index, and a sentence structure analysis. The summary also
includes a list of words which readers might find difficult to understand. The program is
easy to use and quite rapid.  While it can provide a useful feedback mechanism for written
materials, Rightwritcr docs not "understand" the content of the text and can give no
feedback about tone or appropriateness. In addition, some Rightwritcr feedback may be
confusing, difficult to understand, or irrelevant.

3A-2. SMOG Readability Grading Formula
      Purpose:                  To  evaluate the level of reading comprehension a
                                person must have to be able to understand a piece of
                                written material.
      Lead Time:               Low
      Sta(T Time:                Low
      Budget:                   Low

        This approach involves reviewing a sample of  text from a written piece and
performing some simple  mathematical calculations to obtain a SMOG grade, which
represents the reading grade level a person must have reached in order to understand the
text.  The higher the grade level, the more sophistication is necessary to understand the
material. Assessment of readability, along with a knowledge of the target audience's level
of sophistication, can allow agency staff to produce materials that will be more accessible
to their audiences. Readability quotients are useful as a "first cut" in reviewing drafts of
materials for the public, but they give no feedback on style, format, tone, or content. In
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Evaluating Risk Communication Programs
addition, frequent use of long terms that may be necessary in scientific reports may inflate
the SMOG grade.

3A-3. Signaled Stopping Technique
      Purpose:                  To examine how readers process information as they
                                read written materials and through (his procedure to
                                get feedback on those materials.
      Lead Time:               Low
      Staff Time:               Low
      Budget:                   Low

        In this approach, respondents read through a document and put slash marks where
they stop. They are then provided with a coding scheme to notate why they stopped at each
slash. These reasons for stopping provide feedback to the writer. Respondents may stop
due to being confused, needing to re-read, having a question, wanting to think about the
idea, or agreeing or disagreeing with the writer. This technique can help writers recognize
confusing or controversial statements within a piece of text and consider revisions, but its
value may be diminished if the reader  is unmotivatcd or uninterested.

3B. More Extensive Feedback Methods
      These methods give richer feedback but also take more time to administer.

3B-1. Self-administered Pretest Questionnaires
      Purpose:                  To get feedback on pretest materials.
      Lead Time:               Moderate—allow at least two weeks if questionnaire
                                is  mailed.
      Staff Time:               Moderate
      Budget:                   Low to moderate

        Questionnaires about written material arc developed to elicit both quantitative
and qualitative feedback from readers representative  of the intended audience.  The
questionnaire may include questions about format, comprehension, reaction, interest in the
materials, and any other relevant opinions. Questionnaires may include open-ended or
closed-ended questions, depending on the items being pretested and type of feedback
desired. The approach may be limited by low response rates to mailed questionnaires and
the amount of follow-up time needed to insure a meaningful response.

3B-2. Central Location Intercept Interviews
      Purpose:                  To get feedback on pretest materials or to examine an
                                audience's attitudes and opinions.
      Lead Time:               Moderate
      Staff Time:               Moderate to high
      Budget:                   Low to moderate
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                                        Evaluating Risk Communication Programs
        Interviewers arc stationed at a place frequented by a target audience. They recruit
participants who review materials and then respond to a series of multiple-choice or closed-
ended questions.  The structured interviews provide feedback that can be summarized
quantitatively. Careful planning when using this approach can increase the reliability and
gencralizability of the data, but central location interviews typically reflects non- random
sample weighicJ;., ;u. ^ jf those who are able to get to the particular site. In addition, the
necessity of using closed- ended questions may deprive the agency of richer feedback from
a more extended discussion.

3B-3. Theater Testing
      Purpose:                 To get feedback on visually presented pretest mate-
                                rials.
      Lead Time:               Moderate
      Staff Time:               Moderate
      Budget:                  Moderate to high

        Films, pubiic-scrvice announcements, slide shows, or other audio-visual mate-
rials are observed by a group of respondents in a theater or auditorium.  After watching the
film, participants  fill out a pretest questionnaire to provide the agency with feedback.
While very useful to improve visually presented messages, this approach may require a
great deal of time and logistical arrangements, in addition to design of the message itself
and the questionnaire.

3B-4. Focus Croups
      Purpose:                 To get feedback on and generate  ideas about pretest
                                items. To get a "feel" for the attitudes and beliefs of
                                a target audience.
      Lead Time:               Moderate to high
      Staff Time:               Moderate
      Budget:                  Moderate to high

        A focus group is a discussion session run by a trained moderator. It may include
six to twelve participants, who discuss pretest materials or issues of importance to a
communication effort.  Areas covered in a  focus group discussion are outlined in the
moderator's guide, which is developed before the session. Focus  group discussions
generally yield qualitative feedback as summarized in a report by the moderator. These
reports can give an in-dcpth sense of participants' language, their reactions to the materials,
and suggestions for improvement.  Formal  focus groups require careful planning and
moderation and may therefore be too resource-intensive for the average agency. 'Target
audience meetings," involving brief informal discussions with a neutral moderator, a group
typical of the target audience, an agenda planned in advance, and some procedure for note-
taking, am be useful and less expensive.
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Evaluating Risk Communication Programs
 4.  Assessment of Communicator Style
        Although agency staff may traditionally focus on "facts" as opposed to relation-
ships, conflict in styles can lead to tremendous frustration as well as impasses in a given
communication. Armed with the facts alone, practitioners may be doomed to skirmish with
audiences whose very style of perceiving the world and communicating about it differs
from theirs. Tools in this category can help communicators examine what they bring to the
communication process. Mostof these tools are self-assessment surveys that arc completed
and then scored, providing a profile of the respondent's style, type, and/or motivational
pattern. This profile provides a model for understanding communication situations, which
in turn  can help practitioners gain flexibility within their own style, recognize their
strengths and limitations, identify the communication styles of people in their audiences,
and recognize and deal with communication impasses resulting from a clash in styles.

4-1. Myers-Briggs Type Indicator
      Purpose;                  To provide feedback on the communication styles of
                                agency staff.
      Lead Time:               Moderate to lengthy, due to time needed to secure
                                services of consultant
      Staff Time:               Low
      Budget:                   Moderate
    *
        The Myers-Briggs Type Indicator (MBIT) is a self-report inventory consisting of
126 questions. It provides feedback on respondents' communication styles in terms of four
scales: Extraversion-Introversion, Scnsing-Intuition, Thinking-Feeling, and Judging-
Perceiiving. The profiles generated in terms of these four scales  include feedback about
communication strengths and weaknesses. Communicators can become aware of their
own strengths and weaknesses while learning to recognize differing communication styles
in their audiences.  The MBTI model has been used in consultation with risk communi-
cators and has helped foster flexibility in communication style. However, the psychological
theory of type underlying the tool may not fully capture the diversity of personality styles,
and the feedback from this tool is of limited value without a consultation to set it in context.

4-2.  Strength Deployment Inventory
      Purpose:                  To identify the strengths of agency staff and suggest
                                ways these strengths can be used to communicate
                                more productively with others.
      Lead Time:               Moderate to lengthy, due to time needed to secure
                                services of contractor.
      Staff Time:               Low
      Budget:                   Moderate.  Each Inventory  form  costs $3.45; con-
                                sultation is additional.

        The Strength Deployment Inventory (SDI) consists of twenty questions, some of
which refer to situations where things are going well, and some of which refer to situations
where things are going wrong.  The SDI is self-scoring, and respondents identify whether
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                                        Evaluating Risk Communication Programs
they an: characterized by any of seven style patterns, each of which implies different
strengths, weaknesses, and motivations which may be reflected in interpersonal com-
munication. The inventory is easy to complete and provides quick feedback about an
individual's style. The SDI model is one way of understanding differences in personal
styles and their impact on communication. A consultation should accompany the tool for
maximum benefit.

4-3. Conflict Management Survey
      Purpose:                  To provide feedback about a respondent's approach
                                to conflict.
      Lead Time:               Moderate to lengthy, due  to time needed to secure
                                services of consultant
      Staff Time:               Low
      liudget:                   Moderate. Each survey form costs $5.60 and con-
                                sultation is additional.

        The Conflict Management Survey presents scenarios in each of the following
areas: personal views of conflict, interpersonal conflicts, the handling of conflict in task
groups, and conflict in relationships among groups. Respondents note how they would
respond to each conflict scenario, and after a self-scoring exercise, a style preference is
determined, which represents the respondent's preferred mode of managing conflict.
Through consultation, respondents become able to understand the implications of their
style preference and develop the flexibility to use other styles if situations dictate this.
Feedback from this tool may seem threatening if not accompanied by a good consultation.


4-4. Communication Style Survey
      Purpose:       • •         To provide feedback on the respondent's style of
                                interpersonal communication.
      Lead Time:               Moderate to lengthy—surveys need to be mailed to
                                Chicago for scoring, and  a consultation should be
                                arranged.
      Staff Time:               Low
      Budget:                   Moderate—standard fee of $140 per person which is
                                negotiable

        The Communication Style Survey consists of a self-assessment form and "other-
assessment" forms to be filled out by people who know the respondent well. The survey
involves choosing among a set of words the term that most aptly describes the respondent.
The data are processed to yield an assessment of communication style as somecombination
of Analyzing, Facilitating, Advocating, and Controlling. This Style Profile is accompa-
nied by feedback on the respondent's oral communication competency and adaptability.
Consultation is needed to  help respondents understand  the strengths and weaknesses of
each communication style and develop flexibility.
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Evaluating Risk Communication Programs
5. Outcome Assessment
     Agencies typically view evaluation as a means of finding oul whether what they did
worked or not As suggested earlier, carefully designed scientific evaluation research is
required to draw these kinds of conclusions. When agencies have little time and few
resources, however, they may still need to find out how audiences have reacted to phases
of the communication effort and to the effort as a whole. The outcome tools we recommend
provide strategics forgetting feedback on audicnccrcaclion and communicator performance.

5 A.  Audience Reaction
        Audiences are asked what their reaction is to a presentation.
SA-J. Meeting Reaction Form
      Purpose:                  To get feedback about participants' reactions to a
                                public meeting.
      Lead 1'ime:               Low to moderate, depending on whether the form
                                developed by the Environmental Communication
                                Research Program needs modification for specific
                                agency use.
      Staff Time:               Moderate—includes preparation of form, distribution,
                                and data analysis.
      Budget:                   Low

     The Environmental Communication Research Program has developed a form for
distribution at public meetings which examines whether information was understood,
whether presenters were perceived as honest, whether people felt their concerns and issues
were understood, whether people felt their input would be used in decision-making, etc.
Other relevant issues can also be addressed. The particular form described in this catalogue
was designed to get feedback from various constituencies involved in a public participation
program run by the Bureau of Water Quality Standards and Analysis (BWQS A) of the New
jersey  Department of Environmental Protection. While it provides a quick, easy, and
inexpensive way to get feedback about a public meeting, the form is not standardized or
scientifically validated and some feedback could be difficult to interpret.

5A-2. Verbal Meeting Feedback
      Purpose:                  To get direct feedback from participants at a meeting.
      Lead Time:               Low
      Staff Time:               Low
      Budget:                   Low

        Time for a structured feedback discussion is planned in a meeting agenda.  The
meeting chairperson actively solicits and  may even record this feedback on a chart for
everyone to sec. Participants should feel free to comment on any aspect of the meeting, and
conflicting statements are allowed.  The goal is to generate as many idea as possible rather
than going into detail on any one idea. This approach is highly dependent on the skill of
the chairperson in creating a comfortable environment for feedback  and inviting partici-
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pation. Less verbal members may not be heard, and it is difficult to know whether this kind
of feedback is in any way representative of ihe views of the group as a whole.

5B.  Performance of Presentation
      These techniques provide feedback more specific to how the communicator per-
forms than how the audience reacts.

5B-L Speech Evaluation Checklist
      Purpose:                 To get feedback on how a speech or presentation
                                went.
      Lead Time:               Low to moderate—depending on design of form.
      Staff Time:               Low
      Budget:                   Low

      The Speech Evaluation Checklist is a simple form to get feedback on a speech or
presentation.  It may include statements about the physical setting of the speech, the
speaker's appearance, rapport, comprchensibility. and other important areas. The forms
can be completed by one or a number of evaluators who observe the speech. Alternatively,
a speech can be audio* or video-taped for use for scoring by the presenter. The form is not
intended as a "report card," but as a chance to get some input on a speech that will improve
future presentations. This approach can provide immediate, relevant written feedback, but
the perceptions of other agency staff may differ markedly from the perceptions of the
audience.

5B-2. Observation and Debriefing
      Purpose:                 To get feedback on speeches and presentations.
      Lead Time:               Low to moderate—time needed to develop an ob-
                                server checklist
      Staff Time:               Low
      Budget:                   Low

      One or a number of observers attend a presentation and take organized notes, using
their perceptions of the event and some kind of observer checklist based on the goals of the
presentation. An informal verbal debriefing session may be held after the presentation to
review important strengths and weaknesses with regard to both the speaker's performance
and the audience's reactions. The presenter can also use an audiotaped or videotaped
version for self-assessment.  While this is a quick and easy way to provide feedback on a
speech, it should not substitute for finding out the audience's actual reactions, and it can
be uncomfortable for the observers or the presenter depending on their roles within the
agency.
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 REFERENCES
  Briggs, K.C. and Myers, I.B. 1976. Mvcr?-Briggs Type Indicator, Form G. Palo AHo,
  CA: Consulting Psychologists Press, Inc.

  Green, L.W., Kicuicr, M.W.. Deeds, S.G., and Partridge, K.B. 1980. Health Education
  Planning:  A Diagnostic Approach. Palo Alto, CA: Mayfield Publishing Company.

  Hance, B J., Chess, C., and Sandman, P.M, 1988. Improving Dialogue with Commu-
  nities:   A Risk Communication Manual for Government.  Trenton. NJ:  New Jersey
  Department of Environmental Protection, Division of Science and Research.

  National Cancer Institute.  1984.  Protesting in Health Communications:  Methods^.
  Examples, and Resources for Improving Health Messages and Materials. Washington,
  DC: National Institutes of Health, NIH Publication #84-1493.

  National Cancer Institute. 1989. Making Health Communication Programs Work: A
  Planning Guide, Bcihcsda, MD:National institutes of Health, NIH Publication #89-
  1493.

  Rossi,P.H. and Berk, R.A. 1988. A Guide to Evaluation Research Theory and Practice.
  Discussion Draft prepared for the Workshop.
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