&EPA
Santa Clara Valley
Integrated Environmental
Management Project
Stage Two Report
Keith Hinman
Palma Risler
Jennifer Ruffolo
Eileen Softer
Andrew Steckel
Regulatory Integration Division
Office of Policy Analysis
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
Committees of the Santa Clara Valley
Integrated Environmental Management Project
Sec
'987
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Santa Clara Valley
Integrated Environmental
Management Project
Stage Two Report
Keith Hinman
Palma Risler
Jennifer Ruffolo
Eileen Softer
Andrew Steckel
Regulatory Integration Division
Office of Policy Analysis
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
Committees of the Santa Clara Valley
Integrated Environmental Management Project
September 1987
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ACKNOWLEDGEMENTS
While this project benefitted greatly from the assistance
of people too numerous to name, we would like to thank some
who were especially helpful. For supporting technical reports,
we are indebted to Lauraine Chestnut, Ron Dickson, Don Eisenberg,
Peter Flessel, Jim Long, Rod Lorang, Adam Oliveri, Bart
Ostro, and Jill Shapiro. For their managerial guidance, we
are grateful to Dan Beardsley, Art Koines, Sam Napolitano,
Clint Whitney, and John Wise. And for her editorial, admin-
istrative, and production assistance, we thank Eileen Dodini.
Finally, this project would not have been possible without
the efforts of the many participants in the IEMP committee
structure who gave generously of their time and talents
during Stage II.
Sharon Albert
Delia Alvarez
Mike Belliveau
Jacqueline Bogard
Cliff Bowen
E.H. Braatelein, Jr.
Lynn Briody
Bob Brownstein
David Chesterman
Ann Coombs
Will Danker
Les De Baun
Rod Diridon
Amy Dunn
James Easton
Jon Elliot
Lee Esquibel
Milton Feldstein
Patrick Ferraro
Thomas Ferrito
Peter Flessel
Leode Franklin
Roxanne Fynboh
Dan Heiser
Mike Holm
Glenn Hildebrand
Steve Hill
Roberta Hughan
Nancy lanni
Roger James
Peter Jones
Mike Kent
Rick Kitson
City of Gilroy
Santa Clara County Health Department
Citizens for a Better Environment
Clean Water Task Force
Department of Health Services
Water Pollution Control Plants
City of Sunnyvale
Supervisor Wilson's Office
Santa Clara Valley Water District
League of Women Voters
Chevron
Bay Area League of Industrial Assn.
Santa Clara County/BAAQMD
Citizens for a Better Environment
State Water Resources Control Board
Santa Clara County Executive's Office
Santa Clara County Health Department
Bay Area Air Quality Management District
Santa Clara Valley Water District
Town of Los Gatos
Department of Health Services
Santa Clara County Executive's Office
Cal-OSHA
Palo Alto Fire Department
Supervisor Diridon1s Office
County of Santa Clara
Bay Area Air Quality Management District
City of Gilroy
City of San Jose
Regional Water Quality Control Board
San Jose Fire Department
Citizens for a Better Environment
Supervisor Diridon's Office
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Kenneth Kizer
Ruth Koehler
Dan Kriege
Patrick Kwok
Eugene Leong
Tom Lewcock
Bill Loscutoff
Gary Lynch
Sara Malaun
Kenneth Manaster
Ken McKay
Dianne McKenna
Marian Melendy
Ed Miller
David Morel 1
Mike Neale
June Oberdorfer
John O'Halloran
Elisabeth Pate-Cornell
Steve Pederson
Lewis Robinson
William Sanborn
Charles Shulock
Alice Sicular
Ted Smith
Tim Smith
Peter Snyder
Shanna Swan
Lynn Terry
Greg Van Wassenhove
Kitty Weiss
Lenore Wilcox
Charles Wilhelm
Dan Wilkowski
Kirk Willard
Susanne Wilson
Scott Yoo
Mike Young
California Department of Health Services
League of Women Voters
Santa Clara Valley Water District
City of San Jose
Association of Bay Area Governments
City of Sunnyvale
California Air Resources Board
San Jose Office of Environmental Mgmt.
League of Women Voters
Santa Clara University
Central Labor Council of Santa Clara
Santa Clara County/BAAQMD
Councilwoman lanni's Office
Bay Area Air Quality Management District
Santa Clara County Executive's Office
Halogenated Solvents Industry Association
San Jose State University
Santa Clara Valley Water District
Stanford University
Semiconductor Industry Association
Bay Area Air Quality Management District
Santa Clara Chamber of Commerce
Office of Secy of Environmental Affairs
Supervisor McKenna's Office
Silicon Valley Toxics Coalition
Bay Area Air Quality Management District
Regional Water Quality Control Board
Department of Health Services
Air Resources Board
County Agriculture Commission
League of Women Voters
City of Sunnyvale
City of San Jose
Santa Clara County Manufacturing Group
Lockheed Missiles and Space Company
Santa Clara County, BAAQMD
San Jose Water Company
City of Campbell Fire Department
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TABLE OF CONTENTS
CHAPTER 1 : INTRODUCTION 1-1
CHAPTER 2: AIR ISSUES 2-1
Health Risks from Criteria Pollutants 2-8
Monitoring for Toxic Organic Particulates..2-23
Controlling Air Toxics Sources 2-31
Other Subcommittee Action 2-55
CHAPTER 3: WATER ISSUES 3-1
Effectiveness of Hazardous Materials
Ordinances 3-10
Protection of Private Wells 3-22
Aquifer Management: Santa Clara Valley
Water District Study 3-37
Aquifer Management: EPA Study 3-44
Reduction of Trihalomethanes in
Drinking Water 3-82
Additional Issues of Concern 3-93
CHAPTER 4 : INSTITUTIONAL ISSUES 4-1
Introduction 4-1
Summary of Institutional Analysis 4-5
Institutional Action Plan 4-21
CHAPTER 5: CONCLUSIONS 5-1
BIBLIOGRAPHY 5-6
APPENDIX A: ACRONYM LIST A-l
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SANTA CLARA VALLEY
INTEGRATED ENVIRONMENTAL
MANAGEMENT PROJECT
STAGE TWO REPORT
Executive Summary
SEPTEMBER 1987
Regulatory Integration Division
Office of Policy Analysis
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
Committees of the
Santa Clara Valley
Integrated Environmental Management Project
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This report presents the results of the second phase of
the Santa Clara Valley Integrated Environmental Management
Project (IEMP), an innovative project designed to address
environmental and public health problems posed by toxic
chemicals in California's Santa Clara Valley. The IEMP,
sponsored by the U.S. Environmental Protection Agency, is an
effort to improve public health protection and environmental
management by applying the best scientific knowledge and
management skills available to the problems found in the
Santa Clara Valley. The project's goals are:
o to evaluate and compare the health risks - of cancer
and other chronic, toxic effects - from toxic pollutants
in the environment;
o to use this evaluation to set informed priorities for
further analysis and possible control;
o to work closely with government agencies and the
community to manage environmental public health
problems effectively.
THE CONCEPT OF INTEGRATED ENVIRONMENTAL MANAGEMENT
Traditionally, EPA has developed regulations aimed at
controlling the health and environmental effects of a single
industry or a single pollutant in air or in water. In contrast,
the integrated environmental management approach compares
a wide range of pollution problems in air, surface water and
groundwater, and places those that appear to pose the greatest
health risk at the top of the environmental agenda.
The integrated approach is founded on the concepts of
risk assessment and risk management in which estimates of
risk provide a common measure for comparing and then setting
priorities among pollution problems. Once high-priority
issues are identified, limited management resources can be
directed at evaluating control strategies for these problems
first, and the most desirable management option selected and
implemented.
Integrated environmental management is intended to be a
practical tool for controlling pollution that threatens
public health. By focusing on one community, in this case
the Santa Clara Valley, the approach can assist communities
in developing environmental management strategies tailored
to their unique problems and characteristics.
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11
THE STUDY AREA
Currently, the southern part of Santa Clara Valley is
sparsely populated, with an agriculturally based economy- The
northern part of the Valley, in contrast, is well populated
and has a heavy concentration of electronics and other high-tech
industries. In recent years, the discovery of groundwater
contamination caused by leaks and spills from underground
tanks and other waste storage areas has generated widespread
public concern. Other sources of toxics in the local environ-
ment are common to urban areas and include automobiles, dry
cleaners, and disinfection of drinking water supplies.
PUBLIC PARTICIPATION
In conducting the Santa Clara Valley IEMP, the EPA has put
a great deal of emphasis on public participation and cooperation
with other agencies. This emphasis is consistent with EPA's
desire to have the IEMP serve as a practical vehicle for managing
environmental problems, to be responsive to the concerns of
Santa Clara Valley residents, and to promote communication and
education on environmental health issues. At the project's
outset, EPA established two advisory committees to guide the
project: an Intergovernmental Coordinating Committee (ICC),
consisting of local elected officials and board members of
regulatory agencies? and a Public Advisory Committee (PAC),
including staff of regulatory agencies, industry and public
interest groups, and members of the academic community.
METHODOLOGY
The IEMP was conducted in two stages: Stage I, correspond-
ing to risk assessment; and Stage II, corresponding to risk
management. Risk assessment is a means of evaluating the
potential health impact of exposure to chemicals in the
environment. It allows decision-makers to compare the potential
effects of different pollutants (such as trichloroethylene
and benzene), exposure pathways (such as air and drinking
water) and sources (such as underground tanks and automobiles),
using a common denominator of human health risk. By providing
estimates of the comparative impacts of different toxic
chemicals and sources, risk assessment can be used to identify
the most serious problems. The Santa Clara Valley IEMP
comparative assessment of health risks from environmental
toxics was completed in the Spring of 1986.*
* This analysis is described in the report entitled, Santa Clara
Valley Integrated Rnwi r-onmonf-ai Management Project; Revjsed
Stage I RepoVt, (Keith Hinman, Do^S^rt^fl^d Ell«en Soffer,
Office of Policy Analysis, USEPA, May *"•
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Ill
Risk management is the process of controlling the health
risks identified through risk assessment. Risk management
considers not only the level of risk posed by a particular
pollutant or source but also the feasibility and cost of con-
trol, public preferences, and institutional capabilities.
Since there are many components involved in effective risk
management, risk management research can take a variety of
forms. For example, Stage II work included further data-
gathering and risk assessment, cost-effectiveness analysis,
program evaluation, program design and institutional analysis.
STAGE I: RISK ASSESSMENT
Some of the key findings from the Stage I analysis are
the following:
o Estimated cancer health risks from the sources,
pollutants and pathways studied appear to be low
relative to overall "background" levels of disease.
o A small minority of the population appears to be exposed
to toxic chemicals from the sources and routes of
exposure studied, at levels high enough to pose a
risk of effects other than cancer. The incidence
(i.e., number of cases) of non-cancer effects could not
be calculated.
o Among the exposure pathways studied, exposure and
estimated cancer risk appear to be greatest via air.
Sources of airborne toxics were estimated to be pre-
dominately area sources, such as motor vehicles and
home heating.
o The greatest drinking water risks from the toxic
chemicals studied were estimated to be from treated
surface water, posed by by-products of disinfection
(such as chloroform).
o Groundwater, the focus of greatest local concern, was
estimated to account for only a small proportion of the
total risk estimated. Groundwater contamination was
found to pose a comparatively low estimated health risk
because of a protective hydrogeology; and because of
regulatory efforts to prevent contamination, to
clean up existing plumes, and to protect people from
exposure to contaminated drinking water at the well
head.
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IV
o On the other hand, groundwater contamination was
judged to pose a potentially high risk to small
numbers of more highly exposed people, and a substantial
threat to valuable groundwater resources.
o Relatively high localized risks to small numbers of
people may exist for those drinking groundwater from
unregulated private wells, people living near traffic
intersections, individuals near hospitals, and
people regularly consuming contaminated fish or
shellfish from the south Bay.
STAGE II: RISK MANAGEMENT
Several changes were made to the IEMP committee structure
during the transition to Stage II, reflecting the project's
shift in emphasis from the essentially technical task of risk
assessment to the policy-making focus of risk management. One
important change was a decision to change the local role from
one of advising EPA to one of active leadership in directing
the project and implementing recommendations. The Integovern-
mental Coordinating Committee (ICC) was designated as the
decision-making body of the IEMP, with EPA's role changing to
one of advice and support of the ICC. In addition, three
working subcommittees - on Air Toxics, Drinking Water and
Institutional Issues - were formed to provide review and guidance
on technical analysis, and to draft recommendations for change
for the ICC's approval.
EPA worked closely with local IEMP participants to select
risk management issues deserving priority attention in the
project's second stage. Based on the results of the Stage
I risk assessment, as well as the potential for control, public
preferences, other regulatory activities, and the contribution
that the IEMP could make, seven issues were selected for analysis
in Stage II. The results of the Stage II analyses then formed
the basis of extensive discussions by the local participants,
eventually resulting in a series of recommendations for change
to Federal, State, and local toxics policies. Highlights of
the analyses and recommended actions are summarized below.
Air Issues
Monitoring for Toxic Organic Particulates
In conducting the Stage I analysis the IEMP was limited by
a lack of data on organic particulates in Santa Clara Valley.
By scaling values from other urban areas to local conditions,
the IEMP estimated that organic particulates could account for
roughly one-third of the estimated airborne cancer risk.
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However, this estimate was highly uncertain, and IEMP in
Stage II undertook further air monitoring to determine better
the ambient levels of organic particulates and their associated
risks.
The pollutant levels detected in this analysis are
within the range predicted in Stage I, and generally confirm
the Stage I estimates of exposure. The estimated risk from
these pollutants therefore continues to be of concern to the
Santa Clara Valley. The Santa Clara Valley IEMP recommends
that PAHs continue to be a focus of source inventory work at
the BAAQMD, and of higher-priority control research at the
ARB.
Health Risks from Criteria Pollutants
Criteria pollutants (conventional air pollutants) were
not included in the Stage I risk assessment, which focused on
"toxic" chemicals suspected of causing cancer, birth defects
or other health impacts at low levels of exposure. The criteria
pollutant study quantifies health and welfare effects in Santa
Clara County for exposure to ozone, total suspended particulates,
carbon monoxide, and lead to add perspective to the risk estimated
for air toxics in Stage I.
Levels of ozone and CO found in Santa Clara County are
above Federal ambient standards. Ambient levels of lead are
below State and Federal standards. Santa Clara Valley meets
the Federal standard for total suspended particulates, and is
expected to be close to the new Federal standard for fine
particles.
The IEMP finds that significant air quality improvement has
been made over the last fifteen years of pollution control by
Federal, State, and local agencies. Nevertheless, current
levels of exposure to these pollutants appear to entail signifi-
cant health risk, including premature mortality from both lead
and particulate matter, and a host of lesser effects from all
four pollutants. Reductions in current levels if these pollutants
are projected to reduce these health hazards substantially.
Based on these findings, the IEMP committees recommend
continued vigorous control efforts for all of these pollutants,
and increased attention to controlling particulates. IEMP
participants also stress that the risks estimated for criteria
pollutants should not be grounds for reduced efforts to understand
and control toxic air contaminants. Instead, they recommend
that co-control (simultaneous consideration of air toxics and
criteria pollutants) be institutionalized at the ARB and Air
District.
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vi
Controlling Air Toxics Sources
The "Air Toxics Controllability Study" examines controls
for a subset of the relatively high risk air contaminants
identified in Stage I. To help set priorities for local risk
management efforts, this project estimates the cost effectiveness
of controlling various sources of air toxics. The assessment
of health risks from Stage I was used to select nine air
pollution source categories for in-depth examination. For
each of these, three types of control strategies are considered:
hardware controls, chemical substitution, and land-use planning.
Based on the analysis, the participants recommend further
and particular attention by State and regional air regulatory
agencies to the most cost-effective controls: wood stove controls,
wet scrubbers on hospital sterilizers, and refrigerated free-
board chillers on methylene chloride degreasers. In addition,
the IEMP recommends that air toxics risks be considered in
land-use planning and decision-making, using the tools developed
in this study. Land-use decisions are one mechanism for
controlling air toxics that are under the direct control of
local authorities. The IEMP also recommends that the regional
air regulatory agency place a special emphasis on evaluating
and possibly controlling pollutants, processes and industries
that are unusually concentrated in Santa Clara Valley, and
thus not likely to be as high a priority to State and Federal
agencies.
Water Issues
Effectiveness of Hazardous Materials Storage Ordinances (HMSO)
The Stage I analysis indicated that preventive programs,
such as the HMSOs, could play a significant role in reducing
potential future groundwater contamination. As a result, the
IEMP in Stage II evaluated the effectiveness of these relatively
new programs, which form the cornerstone of local efforts to
prevent the release of hazardous substances. The study documents
the nature of the ordinances and their implementation, and
identifies possible organizational and regulatory changes
that could yield benefits in protecting health and resources,
and could be implemented by local authorities.
Based on the results, participants suggest a series of
specific improvements including improved documentation of
activities, better data management, monitoring to detect both
tank leaks and nearby contamination, and better follow-up
(i.e., investigation and cleanup) at sites with identified
contamination. To address the latter recommendations, the
Santa Clara Valley Water District (SCVWD), under an agreement
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Vll
with the RWOCB, has recently undertaken a program to oversee
follow-up at potential fuel contamination sites.
The HMSO study and recommendations have relevance beyond
Santa Clara Valley itself. Because Santa Clara Valley's local
hazardous materials ordinance was one of the first in the
nation, local experience with hazardous materials storage
regulation should provide valuable information to still-
developing State and Federal programs.
Protection of Private Wells
The private well analysis targets a sub-population
identified in Stage I as potentially at high risk due to
groundwater contamination and is a natural follow-up activity
to the County's current private well monitoring program. The
study provides local government with analysis of options for
protecting users of privates wells—wells that are under
local jurisdiction and that are essentially unregulated in the
Santa Clara Valley. The options analyzed range from education
and voluntary monitoring to required monitoring, well standards,
and well closure.
As a result of the analysis, IEMP participants recommend
that the Santa Clara County Health Department implement a
private well program that includes outreach to private well
owners at risk, counseling of users of contaminated wells as
to their options, construction and performance standards for
new wells, and well testing and disclosure at property transfer.
The County is currently drafting a private well ordinance
incorporating many of these recommendations.
Aquifer Management
Despite the relatively low estimates of health risks
from groundwater, the Stage I analysis identified the potential
resource impacts of contamination and clean-up as an important
environmental management issue. The aquifer management project,
undertaken jointly by EPA and the SCVWD, develops strategies for
managing groundwater and drinking water resources in a world
complicated by significant existing and potential sources of
contamination. Contamination, prevention, clean-up, and overall
management issues are addressed.
Analysis confirms the high value of local groundwater, and
the potential impact of contamination and cleanup activities
on this natural resource. Contamination sites in the Recharge
Zone present policy-makers with a particularly difficult choice
between undertaking aggressive cleanup, with its significant
impact on groundwater resources, and allowing widespread
residual contamination to remain in the ground.
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viii
Some of the most important recommendations that evolved
from the analysis include proposals to: (1) institute groundwater
protection zones to restrict activities that threaten important
but vulnerable areas of the groundwater basin; (2) consider Valley-
wide groundwater resource impacts and potential health effects
in developing policy for the cleanup of existing groundwater
contamination sites; (3) develop innovative, less resource-
intensive cleanup techniques; and (4) evaluate the feasibility
of requiring compensation for unmitigated damages to groundwater
resources. Many of the aquifer management recommendations are
relevant to State and Federal, as well as local, groundwater
programs.
Reduction of Trihalomethanes in Drinking Water
The lEMP's Stage I risk assessment estimated that trihalo-
methanes (THMs), such as chloroform, represented the largest
health risk of any class of pollutants. In considering risk
management work in Stage II, the IEMP concluded that the logical
follow-up to the Stage I finding was being conducted by the
SCVWD through its investigation of alternatives for reducing
THMs in treated drinking water.
In Stage II, the IEMP tracked the work of the San Francisco
Water Department (SFWD) and the SCVWD on THM reduction through
its Drinking Water Subcommittee. An engineering analysis by
the SCVWD indicates that ozonation may be the most cost-effective
treatment method for reducing THM concentrations significantly.
The IEMP recommends that both the SFWD and the SCVWD continue
efforts to reduce THMs in drinking water. The IEMP participants
also recommend that EPA promulgate filtration requirements and
revised THM standards and complete its review of chloroform
toxicity in a timely manner.
Institutional Issues
Over the years, there has been a widespread perception
that effective risk and resource management in the Santa Clara
Valley has been hindered due to institutional and political
problems, such as gaps and overlaps in activities and uncertainty
over roles and responsibilities. The Stage II analysis finds
that the institutional status quo has worked fairly well to
date, but that the current ad hoc method of agency coordination
is inefficient and may not be well suited to rapidly increasing
local environmental management responsibilities. Problems with
the current informal system of coordination include (1) the
lack of a formalized, well defined process for decision-making
on environmental matters; (2) the lack of any responsible
agency to perform some activities, such as coordination, program
evaluation, long-term planning and public education; and (3)
the lack of a unified voice for speaking to regional, State and
Federal agencies.
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IX
To address these problems, the IEMP participants recommend
forming a new Toxics Policy Council to provide a central forum
for county-wide decision-making on environmental issues. The
Council would promote consistent policy, evaluate programs,
target high-priority issues, and promote public education
within the Santa Clara Valley. It would also respond to new
State legislation and function as the voice of Santa Clara
Valley to outside agencies. The Council would coordinate a
range of issue-specific task forces (many already in existence),
would be supported by a modest staff, and would be chartered by
a vote of the people through a ballot initiative.
CONCLUSIONS
The IEMP is intended to be both a pilot effort for develop-
ing better methods of environmental risk management and a
practical vehicle for decision-making on environmental issues.
The IFMP attempts to provide sound analysis to support priority-
setting and decision-making; to provide an effective forum for
risk communication, discussion and consensus-building on issues;
and to lay the groundwork for implementation of risk management
decisions and continued integrated environmental management.
The project's success in achieving these ends is discussed
below.
Analysis to Support Decision-making
The IEMP has successfully synthesized and analyzed a great
deal of data about a wide range of problems in ways that assist
in comparing problems, identifying risk management priorities,
and clarifying trade-offs involved in risk management decision-
making. Stage I of IEMP helped to clarify the nature and
magnitude of risks from groundwater and drinking water contamina-
tion, highlighted the risks from trihalomethanes and the vulnera-
bility of private wells, and provided evidence of the importance
of exposure to airborne toxics. Stage II analyses identify
areas where local hazardous materials programs could be improved;
develop groundwater Management strategies to protect both human
health and grou^dwater resources; assess health risks from
conventional, or "criteria" air pollutants; identify cost-
effective control strategies for air and drinking water contam-
ination; and assist in the design of a new environmental
management structure.
From the national perspective, the Santa Clara Valley IEMP
has served to develop further the methods of risk assessment
and risk management in some key respects, and has produced
results and insights useful to national programs. An important
contribution has been the identification of research priorities
as a result of scientific and data limitations encountered
in this project.
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Public Participation and Education
The IEMP has had significant success in communicating
risk and in fostering public participation and agency coordina-
tion. Discussions of environmental issues by Santa Clara
Valley leaders now employ a common language of health risk,
and display an unusual level of sophistication. However,
despite the lEMP's success in promoting risk comunication and
dialogue, much remains to be done. The IEMP has identified
public education as a priority risk management activity for
the future.
Impact on Regulatory Action
Because many agencies and groups work together closely
on environmental issues, it is difficult to distinguish the
effect of one non-regulatory body, the IEMP, on regulatory action.
Nevertheless, it is clear that the IEMP has already had some
influence on management activities. It has, for example,
focused management attention on drinking water disinfection
issues, private well risks, and basin-wide management of ground-
water, as well as on the importance of ethylene oxide, organic
particulates, and metals in the air. In addition, this
report contains a number of thoughtful recommendations on
actions needed to improve management of environmental problems
in air and water, and to improve the process of overall
management and coordination in the future. A final judgement
on the lEMP's practical impact must be deferred several
years, when it will be possible to see how the specific
recommendations and overall direction of the IEMP have been
carried forward.
**************i
For its part, EPA has found the project to be a valuable
experience that has provided practical results useful to its
programs, helped to refine its technical ability to perform
risk assessment/risk management analysis, and provided valuable
knowledge about working with local leaders on sensitive environ-
mental issues. EPA hopes that IEMP participants have found
the project to be an equally valuable experience from their
perspective. EPA would like to thank the many persons who
have contributed their time, knowledge and enthusiasm to this
project, and to express its admiration for the quality and
commitment of local participation in the IEMP.
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CHAPTER ONE:
INTRODUCTION
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TABLE OF CONTENTS
BACKGROUND 1
The Concept of Integrated Environmental Management 2
The Santa Clara Valley IEMP 2
A Pilot Project: Learning by Doing 4
Two Stages: Risk Assessment and Risk Management 5
STAGE 1 6
Public Involvement 6
Analysis and Findings 7
STAGE II 9
Work plan 9
Public Involvement 13
Activities 14
Organization of the Report 19
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CHAPTER ONE:
INTRODUCTION
BACKGROUND
In the 1980's, effective management of toxic risk has
risen to the top of the environmental agenda. An increasingly
concerned public is demanding safe drinking water, cleaner
air, and control over toxic materials. In response, federal,
state, and local governments have been seeking new ways to
control toxic environmental risks.
In its pursuit of new approaches to environmental policy,
the U.S. Environmental Protection Agency (EPA) began a
special project in 1984 in Santa Clara County, California—an
area better known as "Silicon Valley." This effort, termed
the "Integrated Environmental Management Project," or IEMP,
is an attempt to improve public health protection and
environmental management by applying the disciplines of
risk assessment and risk management to the problems found in
the Santa Clara Valley-
EPA designed the project to identify and define risks to
public health posed by toxic enviromental pollutants; to
compare these risks to one another in order to set research
and management priorities; and to develop approaches to manage
such risks more effectively. A key aspect of the IEMP is that
it involves the close cooperation and active participation of
regional and local governments, industry, environmental groups,
universities and members of the public. The Santa Clara Valley
IEMP is part of a national effort including earlier studies
in Philadelphia and Baltimore, and a recently begun project
in Denver.
The Santa Clara Valley IEMP has been conducted in two
parts: Stage I was completed in Spring of 1986. The Stage I
risk assessment was a screening exercise designed to set
research and management priorities among toxic environmental
problems. This first phase of the project was completed in
the Spring of 1986, and is described in the report entitled,
Santa Clara Valley Integrated Environmental Management Project;
Revised Stage I Report (Keith Hirunan, Don Schwartz, and Eileen
Soffer, Office of Policy Analysis, USEPA, May 30, 1986).
Stage II of the IEMP, the risk management phase of the project,
involved the further assessment of some risks as well as the
analysis of strategies to manage those risks identified as
priorities in Stage I. This report presents the results and
recommendations of Stage II of the Santa Clara Valley IEMP-
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1-2
The Concept of Integrated Environmental Management
Traditionally, EPA has developed regulations aimed at
controlling the health and environmental effects of a single
industry or a single pollutant in air or in water. While
substantial environmental improvement has been achieved with
this approach, some drawbacks have also become apparent.
Perhaps the most significant drawback has been the lack of
attention to whether environmental programs, taken as a
whole, reduce health risks in the most efficient way.
In contrast, the integrated environmental management
approach emphasizes the comparison of a variety of problems
and the placement of those that appear to pose the greatest
risk at the top of the agenda. The integrated approach is
founded on the concepts of risk assessment and risk management
in which estimates of risk provide at least one common
measure for comparing and then prioritizing pollution problems.
Integrated environmental management is intended to be a
practical tool for controlling pollution that threatens
public health. By focusing on one community, in this case
the Santa Clara Valley, the approach can assist communities
in developing environmental management strategies tailored
to their unique problems and characteristics.
THE SANTA CLARA VALLEY IBMP
The Santa Clara Valley IEMP is one of EPA's early efforts
to gain field experience with this alternative approach. EPA
chose to conduct an IEMP in the Santa Clara Valley in part
because the industrial base and environmental concerns were
substantially different from those of other areas under
study (Philadelphia and Baltimore). In the last three to
four decades, the area's population has grown rapidly to its
current level of about 1.4 million. In addition, the local
economy has shifted increasingly from agriculture to industry.
In the 1970's, the area experienced a rapid growth in electronics
and other high-tech, computer-related industry, becoming a
world leader in this field.
Currently, the northern Santa Clara Valley is well populated
and has an industrial economic base. The southern part of the
Valley, by contrast, remains more sparsely populated, with an
economy based on agriculture. The southern Santa Clara Valley,
however, is expected to experience significant population and
industrial growth in the coming decades. The IEMP study area,
which roughly corresponds to the Santa Clara Valley, is shown
in Figure 1.
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Fig. 1-1 Santa Clara Valley
IEMP Study Area
SANMATEO
COUNTY
SANTA CLARA
COUNTY
SANTA CRUZ
COUNTY
SAN BENITO
COUNTY
MONTEREY >
COUNTY
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1-4
Some of the Santa Clara Valley's environmental concerns
are at least partly a result of its unique industrial base.
In recent years, the discovery of groundwater contamination
caused by leaks and spills from underground tanks and other
waste storage areas has generated widespread public concern;
many of these leaks occurred on the grounds of electronics
firms. Other sources of toxics in the local environment are
common to most urban areas, and include automobiles, dry cleaners,
and disinfection of drinking water supplies. The southern
Santa Clara Valley has high nitrate levels in its groundwater
thought to be primarily from past agricultural activity.
The decision to conduct an IEMP in the Santa Clara Valley
followed extensive discussions by EPA with state and local
officials, industry representatives, and public interest groups.
EPA was especially impressed by the local response to ground-
water problems associated with underground storage tanks. In
1982-83, a coalition of local elected and regulatory officials,
industry representatives, and environmental leaders responded
effectively to the discovery of groundwater contamination in
the Santa Clara Valley. Working together, these local leaders
drafted a new model Hazardous Materials Storage Ordinance
(HMSO) to regulate the storage and handling of industrial
chemicals; most of the cities and the county then enacted these
ordinances within their respective jurisdictions. The IEMP
could thus build upon an unusually active coalition of local
interests committed to effective management of environmental
risks.
A Pilot Project; Learning by Doing
As a pilot project, the Santa Clara Valley IEMP is
intended to be both a practical vehicle for evaluating and
controlling environmental problems in Santa Clara Valley and
a learning experience for EPA and other environmental and public
health agencies. The project's primary emphasis has been to
provide tools and information to local leaders and regulatory
authorities so that the community has the best available basis
for making informed decisions on environmental control stategies.
At the same time, it is hoped that application of the risk
assessment/risk management approach in Santa Clara Valley will
provide insights and methods useful to environmental managers
in other localities, states, and at EPA.
In conducting the IEMP, EPA has had two primary emphases:
o Good technical and policy analysis to support environ-
mental management. The IEMP approach involved the
application of the best available scientific knowledge
and management tools (e.g., risk assessment, cost-
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effectiveness analysis, other policy analysis tools)
to the environmental issues in the Santa Clara Valley
in an effort to develop practical solutions to site-
specific problems. EPA hoped to use the IEMP approach
to foster management decisions that were more directly
linked to desired environmental results than traditional
methods. In addition to pursuing improved management
of local problems with this approach, EPA wished to
assess the usefulness of these tools, identify problems
with improvements to the approach, and develop a model
that could be applied elsewhere.
o Effective public involvement. The IEMP constitutes an
historic partnership between EPA and the local community.
From the outset, EPA has been committed to conducting
the project through an open process that involves the
active participation of concerned community leaders
in a dialogue with Federal, state and local regulatory
agencies. EPA desired to conduct the project in a
way that addressed the concerns of the local community,
improved their understanding of local environmental
issues, and ultimately provided that community with
the capacity for more effective management of environ-
mental problems. Community involvement has been as
much a part of the IEMP "experiment" as has comparing
problems on the basis of estimated health risk. As
with the technical methodology, EPA has been interested
in identifying problems and possible improvements to
the community participation "model" developed in this
project.
Two Stages; Risk Assessment and Risk Management
The Santa Clara Valley IEMP has been conducted in two stages
o Stage I, corresponding to risk assessment. Risk
assessment is a discipline that allows estimation of
potential human health risks from exposure to toxic
pollutants. In the IEMP, risk assessment was used as
a means of comparing the health threat posed by a
wide range of toxic chemicals and pollutant sources in
the air and water.
o Stage II, focusing on risk management. Risk manage-
ment is the policy-making process by which priorities
are set, and research and control strategies analyzed,
selected and implemented. Establishing priorities
for risk management relies on risk assessment, but
also incorporates considerations of cost, technical
feasibility, fairness and public preferences.
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In reality, assessment and management activities overlap,
and cannot be neatly separated. For example, the choice of
what problems to assess and what resources to devote to that
assessment is a management decision. Nevertheless, the risk
assessment/risk management distinction provided a useful
conceptual framework that guided this project.
The following section very briefly summarizes the activities
and findings of Stage I of the Santa Clara Valley IEMP. The
interested reader is referred to the Revised Stage One Report
for a complete report on the activities and findings of
Stage I of the IEMP.
STAGE I OF THE SANTA CLARA VALLEY IEMP
In late 1983, EPA began informal meetings with local
community leaders and regulatory agency personnel in an effort
to get Stage I of the IEMP underway. These initial contacts
eventually led to the formation of a formal structure of com-
mittees to advise and guide EPA on the project. At the same
time, EPA staff drafted a workplan to guide research on the
environmental exposures and health risks from a range of toxic
chemicals in air and water. After refinement as a result of
public and technical comment, this workplan became the basis
of the analytic work done in Stage I.
Public Involvement in Stage I
EPA developed a structure of advisory committees to guide
the conduct of Stage I of the IEMP and invited a set of
organizations to nominate representatives to these groups.
The resulting broad-based committee membership reflects the
wide range of individuals and organizations that are concerned
about and active in environmental issues in Santa Clara
Valley. Committee membership also reflects the community's
desire to solve environmental problems through a constructive
and open process involving elected officials, regulators, and
representatives of industry, environmental and other community
groups. This consensus model for local decision-making was in
part an outgrowth of the Valley's successful experience in
drafting the local Hazardous Materials Storage Ordinance
(HMSO) through a cooperative process.
Two committees were established to advise EPA during
Stage I: the Intergovernmental Coordinating Committee (ICC),
consisting of local elected officials and board members of
regulatory agencies; and a Public Advisory Committee (PAC),
composed of staff of regulatory agencies, industry and public
interest group representatives, and members of academia. The
ICC was intended to represent policy-level decision-makers,
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while the PAC was designed to provide a forum for both technical
review and public input. Both committees met approximately
monthly for over two years, and several subcommittees were
formed to address specific issues (e.g., risk communication).
The committees fulfilled their functions, providing a forum for
valuable and thoughtful dialogue on sensitive environmental
and public health issues throughout the Stage I process.
Stage I Analysis and Findings
The analysis conducted in Stage I compared the potential
health risks from a wide range of toxic pollutants and pollution
sources in air and water. The health risks examined were
chronic effects, such as cancer and birth defects, that can
result from long-term exposure to relatively small concentra-
tions of toxic chemicals. Health risks were calculated by
combining estimates of exposure to toxics with estimates of
chemical potency or toxicity (see Revised Stage I Report for
fuller discussion). Many sources (autos, electronics plants,
dry cleaners, underground tanks, to name a few), pollutants
(e.g., chromium, arsenic, benzo(a)pyrene, benzene, 1,1,1-
trichloroethane) and exposure pathways (e.g., air, surface
water, groundwater) were studied.
The IEMP Stage I analysis was ambitious and path-breaking
in its breadth. However, it was limited by available data and
science, and was not a comprehensive measure of health risks
from all toxic exposures encountered in daily life. Because of
the significant underlying scientific uncertainties and
limitations, estimated health risks in the Stage I analysis are
most appropriately used for comparisons among problems, rather
than actual predictions of effects.
Some of the key findings from the Stage I analysis are
the following:
o Estimated cancer health risks from the sources,
pollutants and pathways studied appear to be low
relative to overall "background" levels of disease.
o A minority of the population appears to be exposed to
toxic chemicals at exposure levels high enough to pose
a risk of effects other than cancer; the incidence
(i.e., number of cases) of non-cancer effects could not
be calculated.
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o Among the exposure pathways studied, exposure and
estimated cancer risk appear to be greatest via air.
Sources of airborne toxics were estimated to be pre-
dominately area sources, such as motor vehicles and
home heating.
o The greatest drinking water risks from the toxic
chemicals studied were estimated to be from treated
surface water, posed by by-products of disinfection
(such as chloroform).
o Groundwater, the focus of greatest local concern, was
estimated to account for only a small proportion of the
total risk estimated. Groundwater contamination was
found to pose a comparatively low estimated health risk
because of a protective hydrogeology; and because of
regulatory efforts to prevent contamination, to
clean up existing plumes, and to protect people from
exposure to contaminated drinking water at the well
head.
o On the other hand, groundwater contamination was
judged to pose a potentially high risk to small
numbers of more highly exposed people, and a substantial
threat to valuable groundwater resources.
o Relatively high localized risks to small numbers of
people may exist for those drinking groundwater from
unregulated private wells, people living near traffic
intersections, individuals near hospitals, and
people regularly consuming contaminated fish or
shellfish from the south Bay.
The conclusions summarized above are only a cursory
restatement of some of the most important findings of the
Stage I analysis. The reader wishing to understand the analytic
methods, health risk estimates, caveats and limitations, and
conclusions of the Stage I analysis should refer to the
Revised Stage I Report.
The remainder of this chapter and this report describes
the activities, findings and recommendations of Stage II of
the Santa Clara Valley IEMP.
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STAGE II OF THE SANTA CLARA VALLEY IEMP
The Stage I risk assessment was not an end in itself, but
a screening study intended to provide the basis for selecting
the highest-priority problems for risk management attention
in Stage II of the IEMP.
The process of selecting such issues for analysis in
in Stage II began with the issuance of the draft Stage I
Report in October of 1985. The issuance of this report
engaged the scientific and regulatory communities, elected
officials, and members of the public and press in an animated
discussion of the report's findings and implications. While
this dialogue led to the creation of the Stage II workplan,
consideration of the appropriate interpretation and policy
implications of the Stage I analysis continues today.
Recognizing that such dialogue was not only appropriate, but
also would be ongoing, EPA and the local community forged
ahead with the development of a Stage II workplan.
Stage II Workplan
In developing a Stage II workplan that constructively
addressed the community's risk management priorities, it
quickly became apparent that selecting risk management priori-
ties would not be a straightforward process of selecting the
pollutants or sources ranked highest in estimated risk in
Stage I. Rather, the selection of management priorities
involved a number of factors in addition to calculated risk.
For example, environmental and toxic pollutant problems
can be defined in a number of ways: (1) by pollutant source
type (e.g., motor vehicles), (2) by population at risk of
effects (e.g., people drinking from private wells), (3) by
regulatory or other program area, or (4) by cross-cutting
issues (e.g., institutional problems in environmental manage-
ment). In developing options to be addressed in Stage II,
the IEMP adhered to no single way of defining problems, but
instead defined problems in a variety of ways that seemed to
lead themselves to risk management analysis and decision-making.
Actions to address identified problems can vary from data
collection and further risk assessment to cost-effectiveness
analysis and program design, depending on the type of problem
and the level of existing information and regulation. Moreover,
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allocation of resources to particular management issues should
clearly take into account the ongoing activities of other
agencies and the ultimate probability of success.
To assist in the process of balancing all these considera-
tions, EPA, with the input of local participants, developed
the following criteria:
A. Risk; The premise of the IEMP approach is that health
risks are identified and compared so that limited resources can
be spent mitigating the greatest risks first. Therefore, a first
consideration in setting Stage II priorities was identifying
which pollutants and sources pose the largest risk. Other
things being equal, the pollutants and sources identified in
Stage I as posing the largest risks would be top priority
in Stage II.
B. Potential for Control; In addition to considering the
size or extent of the risk in setting Stage II priorities, it
was necessary to consider the potential for managing the
identified risk. For example, what is the feasibility of
control of a given source or pollutant? What is the potential
for more cost-effective control of risk? Which problems are
amenable to local control?
C. Public Preferences; Although the thrust of risk
assessment/risk management is to address those problems that
pose the greatest risk and are amenable to control rather
than to set priorities in response to public outcry, public
preferences are relevant. Issues of public concern are
likely to receive the resources and attention necessary to
support the implementation of analytic findings. In addition,
an important objective of the IEMP is to institutionalize the
valuable aspects of the IEMP process and approach so when the
project concludes, local leaders are able to continue using
risk assessment/risk management in environmental decision-
making. Therefore, in setting Stage II priorities for the
IEMP, the EPA worked closely with local leaders and both tried
to be sensitive to public concerns.
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D. Complementing other Activities; The IEMP attempts to
contribute to better decision-making on environmental issues
within a larger context of regulatory agencies and other
groups already active in this area. In identifying Stage II
priorities, the IEMP attempted to select projects that added
the most to this set of activities. Thus the IEMP tried
to complement or facilitate ongoing efforts, rather than
duplicate them. Projects were proposed only when appropriate
follow-up activities on a high priority issue were not already
being undertaken.
E. Contribution; In general, the IEMP attempted to
identify where it could make the greatest contribution to
effective environmental management. In considering further
risk assessment and research projects, for example, preference
was given to projects that would advance effective risk
management over those that would merely generate interesting
information.
F. Project Resources and Timetable; The setting of
priorities for the Stage II analysis also took into account
the reality of IEMP staff and contractor resources, and the
time available for completion of Stage II activities.
The PAC and the ICC held a number of discussions on
Stage II priorities in spring and summer of 1986 and
eventually approved a workplan reflecting that input in late
summer of 1986. The analysis conducted under this workplan
is summarized in this report. Details of the work are contained
in separately available technical appendices. Very briefly,
the major elements of the Stage II workplan are the following.
Air
The elements of the workplan addressing air issues emphasize
further data-gathering and health assessment and preliminary
analysis of control options.
o Monitoring for airborne organic particulates. Reliable
data on sources and ambient levels of organic particu-
lates were lacking in Stage I, although organic
particulates were tentatively judged to be relatively
important sources of airborne toxics health risk. This
activity complemented other air toxics monitoring being
conducted by the Bay Area Air Quality Management District
(BAAQMD) and the California Air Resurces Board (ARE).
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o Assessment of health risks from airborne lead and
other criteria pollutants.The Stage I analysis was
limited to toxic pollutants. This study is intended
to provide a broader perspective on the health risks
posed by airborne contaminants in Santa Clara Valley
by assessing the health risk from criteria pollutants.
o Assessment of cost-effectiveness of controlling
selected sources of air toxics. Stage I identified
airborne toxics as the largest contributers to toxic
health risk in the Santa Clara Valley. This study
provides a local perspective on control priorities,
to support direct local actions and local input
to the BAAQMD and the ARE.
Water
The drinking water and groundwater elements of the workplan
did not address data gaps, since a number of agencies were already
collecting data on drinking water quality, groundwater contamination,
and hazardous materials storage. Instead, the water projects
targeted management issues facing local decision-makers.
o Evaluation of the effectiveness of local Hazardous
Materials Storage Ordinances (HMSOs). The Stage I
analysis indicated that preventive programs, such as
the HMSOs, could play a significant role in reducing
potential future health risks. As a result, EPA
and local leaders were interested in evaluating the
effectiveness of these relatively new programs, which
form the cornerstone of local preventive efforts. The
purpose of the study is to document the nature of the
ordinances and their implementation, and to identify
possible organizational or regulatory changes that
could yield benefits in protecting health and resources,
and could be implemented by local authorities.
o Assessment of control strategies to protect people
drinking from private wells. This effort targets a
sub-population identified in Stage I as potentially
high-risk and is a natural follow-up activity to the
county's current private well monitoring program.
The study provides local government with options for
protecting users of private wells—-wells that are
under local jurisdiction and that are essentially
unregulated in the Santa Clara Valley.
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o Development of aquifer management strategies. Despite
the relatively low estimates of health risks from ground-
water, the Stage I analysis identified the potential
resource impacts of contamination and cleanup as an
important environmental management issue. This
project, undertaken jointly by EPA and the Santa Clara
Valley Water District (SCVWD), develops strategies
for managing groundwater and drinking water resources
in a world complicated by significant current and
potential sources of contamination. Contamination,
prevention, cleanup and overall management issues
are addressed in these studies, and recommendations
developed for implementation by local and regional
agencies.
Institutions to Manage Environmental Risks
One important cross-cutting issue was included in the
Stage II workplan:
o Analysis of institutional problems and alternatives
in environmental management. This study addresses
the concern that local risk and resource management
is hindered by institutional and political problems
such as gaps and overlaps in authority, uncertainty
over responsibilities, and similiar concerns. The
study develops information and a framework to
support local decision-making on desirable
institutional management measures.
Local Participation in Stage II
Following discussions between EPA and local IEMP participants
several key changes were made to the IEMP committee structure
for Stage II. These changes reflected a shift in the project's
emphasis from the essentially technical task of risk assessment
to the policy-making focus of risk management.
The roost important change was a shift from a local role
of advising EPA to one of active leadership in environmental
management. This changed local role was deemed appropriate
because the elected representatives of Santa Clara Valley, as
well as the agencies responsible for environmental management,
are represented on the ICC. Decision-making that reflects
the wishes of the community and that stands a good chance of
being implemented must therefore come from this group of
policy-makers, not EPA.
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To effect this change in leadership, the ICC was desig-
nated as the local decision-making body of the IEMP, and
although EPA maintained primary responsibility for conducting
the tasks outlined in the workplan, its role changed to one
of providing advice and support to the ICC. The PAC remained
an advisory body to EPA, but also became an advisory group to
the ICC. The ICC added several new, non-voting members to
improve its effectiveness as a risk management body: the
Chair of the PAC, a representative of environmental groups, a
representative of industry, the Executive Officer of the
State Water Resources Control Board, the Director of the
California Dept. of Health Services, and the Special Con-
sultant to the Secretary of Environmental Affairs. The
latter three members were added to improve communication with
the state agencies most central to toxics and environmental
management.
It is important to recognize that even though the ICC
accepted the responsibility of making policy decisions in the
IEMP process, it has no direct authority to implement its
decisions. However, because the membership of the ICC is
drawn directly from potential implementing agencies (including
the county and cities), and because of the attention given
to consensus-building in the course of the IEMP, it is hoped
that the ICC will be effective in seeing its recommendations
implemented.
The second important change made to the committee structure
for Stage II was the creation of working subcommittees to pro-
vide technical review and policy guidance in specific areas.
After some discussion, three subcommittees were formed along
media or programmatic lines: an Air Subcommittee, a Drinking
Water Subcommittee, and an Institutional Subcommittee. The
subcommittees were charged with assisting in the developing
of analysis, exchanging information, and reviewing EPA products;
developing draft recommendations in their areas for considera-
tion by the PAC and ICC; and building consensus on their
recommended actions.
The members of the PAC and ICC during Stage II of the
IEMP are shown in Tables 1-1 and 1-2 (subcommittee members
are listed in each chapter).
Stage II Activities
EPA's major activity during most of Stage II has been
producing analytic reports on each of the projects identified
in the Stage II Workplan and working with the local community,
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Table 1-1
INTERGOVERNMENTAL COORDINATING COMMITTEES MEMBERS
Name
Representation
Nancy lanni, Chair
Thomas Ferrito, Vice Chair
Sharon Albert
Lynn Briody
Rod Diridon
Patrick Ferraro
Homer Hyde *
Dianne McKenna
(alt: Alice Sicular)
Peter Snyder
Susanne Wilson
Mike Belliveau
(ex officio)
Gary Burke
(ex officio)
James Easton
(ex officio)
Kenneth Kizer
(ex officio)
Kenneth Manaster
(ex officio)
Councilmember, City of San Jose
Councilmember, Town of Los Gatos
Councilmember, City of Gilroy
Councilmember, City of Sunnyvale
Supervisor, County of Santa Clara;
Board member, Bay Area Air Quality
Management District
Board of Directors,
Santa Clara Valley Water District
RWQCB
Supervisor, County of Santa Clara;
Board Member, Association of Bay
Area Governments
Board of Directors,
Regional Water Quality Control Board
Supervisor, County of Santa Clara
Board Member, Bay Area Air Quality
Management District
Research Director
Citizens for a Better Environment
Executive Director, Santa Clara
County Manufacturing Group
Executive Director, California
State Water Resources Control Board
Director, California
Department of Health Services
Professor of Law,
Santa Clara University
" Member of ICC during Stage One
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1-16
Chuck Shulock
(ex officio)
Table 1-1 (continued)
Assistant to the Secretary for
Policy Development, Office of the
Secretary of Environmental Affairs
Table 1-2
PUBLIC ADVISORY COMMITTEE MEMBERS
Name
Representation
Kenneth Manaster, Chair
Eugene Leong, Vice Chair
George Adrian *
Delia Alvarez
(Alt: Lee Esquibel)
Cliff Bast *
Mike Belliveau
Jacqueline Bogard
Cliff Bowen
E.H. Braatelien, Jr.
(Alt: Pat Kwok)
Peter Cervantes-Gautschi *
Ann Coombs
Greg Cummings *
Professor of Law,
Santa Clara University
Deputy Executive Director,
Association of Bay Area Governments
Santa Clara County Water Retailers
Director of Public Health,
County of Santa Clara
Hewlett-Packard, Industrial Environmental
Coordinating Council
Research Director,
Citizens for a Better Environment
Santa Clara County Manufacturering Group
District Engineer, California
Department of Health Services
Public Water Supply Branch
Director of Water Pollution Control,
San Jose Department of Water
Pollution Control
Central Labor Council
League of Women Voters
San Jose Chamber of Commerce
Member of PAC during Stage One
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Table 1-2 (continued)
Will Danker
Les DeBaun
Jim Dufour *
Don Fast *
Milton Feldstein
(Alt: Ed Miller)
Roxanne Fynboh
Bernice Giansiracusa *
Roger James
Peter Jones
Dan Kriege
(Alt: David Chesterman)
Ken McKay
June Oberdorfer
Elisabeth Pate-Cornell
Steve Pederson
David Roe *
William Sanborn
Ted Smith
Chevron, USA
Environmental Consultant, Bay Area
League of Industrial Associations
Semi-conductor Industry Association
Industrial Environmental Coordinating
Council
Air Pollution Control Officer,
Bay Area Air Quality Management
District
Senior Industrial Hygienist, Cal-OSHA
Santa Clara County Health Department
Executive Director, California
Regional Water Quality Control Board
Program Manager, San Jose Fire
Department Hazardous Materials Program
Manager, Santa Clara Valley Water
District, Operations and Maintenance
Central Labor Council of Santa Clara
Professor of Geology,
San Jose State University
Professor of Industrial Engineering,
Stanford University
Director, Environmental and OSHA Affairs,
Semiconductor Industry Association
Environmental Defense Fund
Technical Representative, Santa
Clara Chamber of Conference
Executive Director, Silicon Valley
Toxics Coalition
Member of PAC curing Stage One
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Table 1-2 (continued)
Shanna Swan
Greg Van Wassenhove
Jerome Wesolowski *
Chief, Department of Health Services,
Health Assessment and Surveillance
Unit, Epidemiological Studies and
Suveillance Section
Agriculture Commissioner,
County of Santa Clara
California Department of Health Services
Kirk Willard
Scott Yoo
Chief, Lockheed Missiles and Space
Company Environmental Compliance Program
Water Quality Manager, San Jose
Water Company
w Member of PAC during Stage One
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1-19
primarily through subcommittees, to ensure that the analyses are
accurate and relevant. Work began on some of these analyses
prior to final workplan approval, and complete reports were
produced for all projects by July, 1987. During this time, all
of the subcommittees met frequently (once or twice monthly) to
review draft products and provide suggestions for improvements.
As each analytic report was completed, EPA prepared a staff
summary for each project, summarizing analytic work conducted,
results, and conclusions or recommendations. These summaries
were intended to assist the subcommittees in their consideration
and discussion of the implications of the studies and in the
development of recommendations or action plans. Each subcommit-
tee held a number of meetings to develop action plans, with EPA
staff, contractors and reports, as well as expert members of
the subcommittees, serving as resources.
Each subcommittee also developed a list of recommended
issues worthy of risk management attention, but beyond the
scope of EPA or subcommittee efforts in Stage II.
Members of the subcommittees displayed a strong commitment
to addressing environmental problems by devoting significant
time and effort to this project over a period of many months.
Each committee developed a distinctive operating style, and
each was effective in its own way. The subcommittees have
provided a public forum in which to discuss complex environ-
mental problems and sensitive issues of public health, and a
process by which to build understanding and consensus within
the community- In addition, the committees have provided a
vehicle for fostering cooperation among the regulatory agencies
and local leaders who need to work together to manage
environmental risk effectively. Finally, each subcommittee
was able to forge consensus on a set of recommendations, while
maintaining respect for the diverse interests represented.
Organization Of This Report
The remainder of this report summarizes the analysis
conducted on each project identified in the Stage II workplan,
the results of that analysis, and subcommittee recommendatons
for action in each area. Each project is discussed separately,
and projects are grouped into chapters by subcommittee.
Chapter Two discusses the projects under the purview
of the Air Subcommittee, including:
o Organic Particulates Monitoring;
o Risks from Criteria Pollutants; and
o Air Toxics Controllability.
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Chapter Three describes projects under the Drinking Water
Subcommittee, including:
o Hazardous Material Storage Ordinance Effectiveness;
o Control Options for Private Wells;
o Aquifer Management Project
(including SCVWD and EPA studies of groundwater and
drinking water management); and
o Summary of Trihalomethane Control Activities.
Chapter Four discusses the analysis conducted for and
recommendations developed by the Institutional Analysis
Subcommittee.
Chapter Five presents overall conclusions.
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CHAPTER TWO
AIR ISSUES
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TABLE OF CONTENTS
INTRODUCTION
Air Toxics Subcommittee 1
Stage II Air Toxics Workplan 5
Outline of Chapter 7
HEALTH RISKS FROM CRITERIA POLLUTANTS
Summary of Analysis 8
Objective of Study 8
Background and Scope of Work 8
Methodology 8
Uncertainties in the Methodology 10
Results 10
Action Plan 20
MONITORING FOR TOXIC ORGANIC PARTICULATES
Summary of Analysis 23
Objective of Study 23
Background and Scope of Work 23
Methodology 23
Results 24
Conclusions 29
Action Plan 30
CONTROLLING AIR TOXICS SOURCES
Summary of Analysis 31
Objective of Study 31
Background and Scope of Work 31
Methodology 32
Results 39
Conclusions 48
Action Plan 52
OTHER SUBCOMMITTEE ACTION
Action Plan Issues Based on Multiple Studies 55
Issues not Addressed by the IEMP 58
BIBLIOGRAPHY 60
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CHAPTER TWO:
AIR ISSUES
INTRODUCTION
In May 1986, the Santa Clara Valley Integrated Environ-
mental Management Project (IEMP) completed its Revised Stage
I Report, a comparative assessment of the health risks posed
by 41 toxic pollutants in air, surface water, and groundwater.
This analysis indicated that exposure to the airborne toxic
chemicals examined appeared to account for the greatest cancer
risk among the exposure pathways considered: over two additional
cancer cases per year out of roughly four cases per year.
The Stage I analysis found that the sources of these toxic
air emissions were chiefly a variety of small, dispersed area
sources, notably motor vehicles and (more tentatively) home
heating. Highly-exposed individuals living near certain
sources were estimated to be subject to higher than average
risks. Such sources included traffic intersections with high
levels of benzene, hospitals using ethylene oxide as a sterilant,
and, to a lesser degree, various users of chlorinated solvents.
Finally, the Stage I analysis identified a number of key data
gaps that interfered with the accurate assessment of ambient
exposure and risk levels for many toxic pollutants of concern.
Because of the importance of exposure to airborne
toxics, IEMP participants agreed that the risk management
priorities of Stage II should include significant attention
to air issues. Therefore, during the transition to Stage II,
the IEMP created a subcommittee dedicated to air issues, and
developed a workplan of priority air projects to be performed
in Stage II.
Air Toxics Subcommittee
The Air Toxics Subcommittee was formed late in the summer
of 1986. Subcommittee membership was chosen with several
objectives in mind: technical expertise; representation of
relevant regulatory agencies at both staff and policy-making
level; and representation of an array of interests and groups
active in air toxics issues. Members included elected offi-
cials and representatives of local and regional agencies, the
university community, and environmental, industry, and citizens'
groups. The breadth of interests represented was intended to
allow the subcommittee to perform a representational and
consensus-building role, in addition to providing technical
expertise.
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2-2
Members of the Subcommittee and their affiliations are
listed in Figure 1, along with some of the other active sub-
committee participants who were not formally members.
Air Toxics Subcommittee Objectives
In September 1986, the Air Toxics Subcommittee adopted
the following Statement of Objectives:
Subcommittee Objective: Identify and evaluate alternative
methods for reducing or eliminating the release of airborne
toxics in Santa Clara Valley.
Elements of the Objective;
* 1) Continue to identify and assess health risks from
airborne toxic pollutants posing risks to human
health and the environment.
* 2) Investigate alternative control strategies for
reducing exposure and emissions of air toxics
identified in Stage I, including:
a. Investigate data needs and availability,
b. Review and incorporate activities of other
agencies in formulating alternative control
strategies,
c. Develop alternative risk management
recommendations.
* 3) Assess current activities in Santa Clara Valley to
prepare and control episodic releases.
4) Develop alternative control strategies for possible
episodic releases.
* Asterisk denotes those tasks to be addressed by the IEMP
funded Air Toxics Analysis.
Subcommittee Activities
During the course of Stage II, the subcommittee performed
two major functions: (1) provided technical and policy input
to EPA on the research projects; and (2) interpreted the
analytic results and developed policy recommendations to
address air toxics problems.
In the first role, members' expertise and policy direction
aided in formulating, designing, and reviewing the analytic
projects. In the second role, the subcommittee meetings
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2-3
Figure 2-1
AIR TOXICS SUBCOMMITTEE MEMBERS
Name
Rod Diridon (Chair)
Eugene Leong (Vice Chair)
Will Danker
Les DeBaun
Amy Dunn
Lee Esquibel
Peter Flessel
Roxanne Fynboh
Nancy lanni
(ex officio)
Bill Loscutoff
(Alt: Lynn Terry)
Kenneth Manaster
(ex officio)
Dianne McKenna
(Alt: Alice Sicular)
Ed Miller
David More11
(Alt: Jon Elliot)
Kitty Weiss
Representation
Board of Directors, Bay Area
Air Quality Management District;
Supervisor, County of Santa Clara
Deputy Executive Director,
Association of Bay Area Governments
Chevron, USA
Environmental Consultant,
Bay Area League of Industrial
Associations
Associate Research Director,
Citizens for a Better Environment
Deputy Director, Environmental
Health Services, Toxic Control Unit,
Santa Clara County Health Department
Environmental Biochemist,
Department of Health Service
Senior Industrial Hygienist,
Cal-OSHA
Councilmember, City of San Jose;
ICC Chair
Chief, Toxics Pollutants Branch,
California Air Resources Board
Professor of Law, Santa Clara
University; PAC Chair
Supervisor, County of Santa Clara
Environmental Toxics Specialist, Bay
Area Air Quality Management District
Special Assistant, Santa Clara
County Executive
Hazardous Waste Study Group,
League of Women Voters
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2-4
Figure 2-1, Continued
AIR TOXICS SUBCOMMITTEE PARTICIPANTS
Name Representation
Charles Wilhelm Director, Office of Environmental
Management, City of San Jose
Dan Wilkowsky Environmental Affairs Manager,
National Semiconductor, representing
Santa Clara County Manufacturing Group
Mike Young Fire Marshall, City of Campbell
Fire Department
EPA and members of the Air Toxics Subcommittee wish to
acknowledge that numerous non-members added valuable input to
the subcomittee by their participation. Some of these include:
Jacqueline Bogard, Clean Water Task Force; Ann Coombs, League
of Women Voters; Dan Heiser, Palo Alto Fire Department; Steve
Hill, Bay Area Air Quality Management District; Michael Holm,
Supervisor Diridon's Office; Rick Kitson, Supervisor Diridon's
Office; Ruth Koehler, League of Women Voters; Gary Lynch, City
of San Jose; Mike Neale, Halogenated Solvents Industry Associa-
tion; Bart Ostro, Environmental Protection Agency; Lew Robinson,
Bay Area Air Quality Management District; Ted Smith, Silicon
Valley Toxics Coalition; and Tim Smith, Bay Area Air Quality
Management District.
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2-5
provided a forun for consensus-building among parties with a
wide range of perspectives, constituencies and backgrounds.
The meetings provided an opportunity for dialogue between
experts and lay people, and between regulatory agencies and
concerned elements of the community.
The development of recommendations through consensus-
building culminated in the air toxics action plan, which
consists of a series of recommendations for air toxics policy
that are based on the findings of the analytic research and
on the expertise of subcommittee members. Recommendations
are, for the most part, directed at the two regulatory agencies
primarily responsible for air quality in Santa Clara Valley:
the Bay Area Air Quality Management District (BAAQMD), the
regional agency that regulates stationary sources in the Bay
Area; and the California Air Resources Board (ARB), which
directly regulates motor vehicles, identifies toxic air
contaminants (TAC), develops control measures in conjunction
with local air districts to control identified TACs, and
conducts air pollution related research. In addition, there
are a number of recommendations directed at the California
Department of Health Services (DOHS), the EPA, and city and
county bodies.
Stage II Air Toxics Workplan
The Stage II workplan was approved in September of 1986,
and included three projects under the purview of the air
subcommittee. These projects targeted priority issues that
complemented the ongoing activities of air planning and
regulatory agencies. The Stage II air projects are summarized
below under the general headings of (1) further evaluation of
health risks, (2) further data collection and (3) analysis of
controls.
Further evaluation of health risks.
Scientific uncertainty and data gaps limit the accuracy
of all risk assessments, including the Stage I analysis.
While improved risk assessment of air toxics would certainly
be desirable, the pace of experimentation and data-gathering
is such that a revised analysis of such risks in Stage II
would add little to the information generated in Stage I.
The Stage I analysis was also intentionally limited by
restrictions in the scope of problems and pathways to be
examined. For example, Stage I did not include study of the
health risks from indoor air exposure, episodic or accidental
releases, or criteria pollutants. These exposure pathways
and sources were not excluded because they were believed to
be unimportant, but because of limitations in project resourcesr
traditional EPA authority, data, or expertise.
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At the request of the ICC and PAC, a qualitative evalua-
tion of occupational health risks was conducted. (Froines,
John R., Ph.D., et al, Occupational Exposures in Santa Clara
County, UCLA School of Public Health, July 1986.)
In Stage II, the IEMP decided to broaden the scope of
health risks examined by studying the health effects of four
criteria pollutants. The Criteria Pollutant Study was con-
ducted to provide a basis for comparing the relative importance
of the two types of air pollutants. The study estimated the
health effects of current levels of ozone, particulates,
lead, and carbon monoxide, and the possible health benefits
of reductions from current levels.
Further data collection
The Stage I assessment was limited by a lack of reliable
data on air toxics. Emission estimates for toxic organic
gases were developed for the Stage I analysis, but the only
ambient monitoring data available were a limited amount collected
under the IEMP. For toxic metals, limited monitoring data
existed, but no emissions data were available. For organic
particulates, neither emissions nor ambient monitoring data
were available.
Efforts are now under way to fill many of these data
gaps. The ARE and BAAQMD are collecting ambient monitoring
data on 18 pollutants at 2 stations in Santa Clara Valley.
Partially as a result of the IEMP, EPA region IX is funding
the BAAQMD's development of an emissions inventory on toxic
metals, and estimates of organic gas emissions are being
improved.
The IEMP decided in Stage II to fund the collection of
an additional important set of data not being collected under
any of the above programs: ambient monitoring data on organic
particulates. The PAH Monitoring Study funded analysis for
eight polycyclic aromatic hydrocarbons (PAHs). This effort
was designed to provide local exposure data to allow verifi-
cation of the rough Stage I estimates, based on scaling data
from other cities. Verification of the Stage I estimates is
important because organic particulates were estimated to
account for a relatively high proportion (about 1/3) of the
total airborne risk.
Analysis of controls
While the Stage I analysis identified a number of research
priorities that would aid in risk management, the ultimate
objective of all the data collection and risk assessment is
to assist in making decisions on effective ways to control
the most important air pollutants. In California, the Air
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Resources Board has the lead in developing model regulations
for toxic air contaminants and directly regulates motor
vehicles. The BAAQMD controls point sources and performs
risk assessment of major new sources.
The IEMP decided in Stage II to conduct an Air Toxics
Controllability Study to examine the cost-effectiveness of
controlling a set of high-risk toxic air contaminants iden-
tified in Stage I. The goal of this project was to provide a
basis for input to the regional and state agencies on Santa
Clara Valley's priorities for control, and to identify areas
where local authorities could directly implement local
controls.
Outline of Chapter
The remainder of this chapter summarizes the analysis
conducted in each of the three project areas described above.
Each summary concludes with a set of related recommendations
developed by the IEMP participants on desirable regulatory and
policy activity. Several recommendations are associated with
more than one study, and these are discussed next. Finally,
the chapter presents discussion and recommendations on issues
that were outside the scope of the Stage II workplan, but
which the committee members believed deserve priority attention
and follow-up work.
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HEALTH RISKS FROM CRITERIA POLLUTANTS
SUMMARY OF ANALYSIS
Objective of Study
The objective of this research was to better inform risk
management activities by analyzing the risks from conventional
(i.e., criteria) air pollutants. This project provides
perspective on the health risks from toxic air pollutants
estimated in Stage I of the IEMP.
Background and Scope of Work
Stage I of the IEMP focused on estimating cancer risk
from toxic chemicals in both ambient air and drinking water.
This initial emphasis on toxics was chosen because less
research had been conducted on the scope of the toxics problem.
However.- criteria air pollutant emissions are large compared
to air toxics emissions, and were a logical target for expand-
ing the Stage I risk assessment.
This study examined selected health and welfare effects
for four conventional air pollutants: particulate matter
(PM), ozone, lead, and carbon monoxide (CO). The health
effects studied include mortality, emergency room visits,
restricted activity days, and asthma attacks. Health effects
for sulfur oxides and nitrogen oxides were not examined
because Santa Clara County is currently in compliance with
all applicable State and Federal regulations, and adverse
health effects are expected to be small. While the County is
currently in compliance with the lead standard, health effects
were investigated because there is evidence that health effects
occur below the current standards.
Welfare effects (i.e. non-health effects) were estimated
for visibility and damages to materials such as paint, fabric,
and rubber. Forest and agricultural damages were omitted due
to the limited quantitative information available and because
a recent study found these effects to be relatively small in
California. The entire analysis is documented in the Santa
Clara Criteria Air Pollutant Benefit Analysis, released May 1987.
Methodology
To estimate health effects from criteria pollutants,
information was used from published national health studies
on the amount of damage (health effect) that is likely to be
seen at current levels of air pollution, and the decrease in
health impacts that would result from reduced levels of air
pollution.
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2-9
The estimated reduction in health effects are the result
of three factors: the changes in health risk resulting from
changes in air quality; the estimated changes in air quality;
and the sizes of the populations at risk. A brief description
of each of these factors follows.
Changes in health risks were estimated using "damage
functions", which relate the ambient levels of pollution to
expected health effects. This relationship was based upon
statistical studies of how exposure to air pollution affects
humans. Damage functions allow estimation not only of the
type of expected health effects at current levels of pollution,
but also of the magnitude or quantity of the health effects.
Unlike the Stage I analysis which used toxicology information
that was based mainly upon extrapolation of animal experiments
in the laboratory or on occupational exposures, the damage
functions employed in this study were based on epidemiological
associations observed in human studies.
Three alternative threshold assumptions were included in
the analysis to estimate damages for each of the pollutants:
(1) the damages of current levels compared to the federal
primary ambient air quality standard, (2) the damages of
current levels as compared to California standards, and (3)
the damages of current levels as compared to the minimum
levels at which damages have been detected in studies selected
for use. The first two alternatives presume that there is no
measurable damage below the selected standard (i.e. the stand-
ard is the threshold.) The third alternative was considered
because of current scientific controversy regarding the
existence of effects below current standards and should be
regarded as an upper bound estimate of health damages. Thus,
the three alternative assumptions as to the threshold for
health effects provide three sensitivity cases as to the
magnitude of health effects at current ambient levels.
The three alternative threshold levels described above
were also used as the three hypothetical estimates of the
second factor, changes in air quality. They provide estimates
of the health benefits of reducing ambient pollutant concen-
trations by varying amounts, assuming the different thresholds
are applicable.
The third factor was the population at risk which varied
by health effect studied. For example, the entire population
may be at risk for eye irritation from ozone, but only asthma-
tics are at risk of increased asthma attacks.
The three factors—damage functions, changes in air
quality, and population at risk—were all used to estimate
total health effects.
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Uncertainties in the methodology
There are a number of general caveats to the methodology.
First, the categories of damages presented in this report were
not all-inclusive, because quantitative evidence was not
available for every suspected effect of exposure to these
pollutants. These omissions suggest that the results of the
analysis are likely to understate, rather than overstate, the
estimated damages of current pollution levels.
The second caveat is that a good deal of uncertainty
exists in estimating health and welfare effects. For example,
the methodology is based upon statistical associations between
air pollutants and the effects, which in most cases do not
establish cause and effect. We often do not know how pollu-
tants cause the problems. In addition, there is uncertainty
as to the extent and measurement of the relationship between
air pollution and the health and welfare effects.
The benefits of attaining carbon monoxide standards were
not estimated because of the limited information available.
The estimates presented are for the number of people at
potential risk of health effects during the peak carbon
monoxide season in 1985 due to elevated carboxyhemoglobin
levels (of which ambient CO is only one source.)
Finally, these numbers were based upon a single year's
data, while pollutant levels vary from year to year because
of changes in meteorological conditions and economic activity.
The base year for CO and particulates was 1985. The baseline
for ozone was 1984. For lead emissions, which are being re-
duced as a result of Federal lead-in-gasoline restrictions,
we obtained 1986 data. These baseline years were somewhat
higher for PM and ozone than have occurred in other recent
years. For lead and CO, limited data on San Jose blood
levels were available from the 1976 National Health and
Nutrition Examination Survey (NHANES). These levels were
scaled to 1985 and 1986, respectively, by taking account of
changes in ambient lead and CO levels. Blood data, rather
than ambient air data, were used for these two pollutants
because blood levels are considered better indices of exposure.
Results
Tables 2-1, 2-2, and 2-3 summarize the results of the
report for a 'best1 estimate case for the entire county.
Table 2-4 provides information on San Jose exposure levels
for three pollutants, as compared to levels elsewhere in the
Bay Area and the U.S. The technical report provides additional
information (not summarized here) on estimation of upper
bounds, lower bounds and best estimate; adjustment of the PM
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Table 2-1
ESTIMATES OF COUNTY-WIDE HEALTH EFFECTS FROM PM AND OZONE
(Reduction in Cases/year)
Pollutant and
Health Effect
PARTICULATE MATTER^
Federal
Standards a
Upper Lower
Bound Bound
(Best)
(Estimate)
California
Standards a
Upper Lower
Bound Bound
(Best)
(Estimate)
- Deaths Oc
- Emergency Room Visits
- Restricted activity days Oc
OZONE
- asthma attacks
- eye irritation
respiratory
restricted
activity days
100 - 700
(400)
NA NA
(25,000)
12,000 - 15,000
(13,000)
0-57
(37)
198 - 4154
(2,176)
269,000 - 584,000
(367,000)
500 - 3,600
(1,900)
NA NA
(99,000)
63,000 - 86,000
(74,000)
a These numbers assume that the standard is the threshold,
i.e. below the relevant standard there are no measurable
effects.
b These numbers use the adjusted monitoring data for TSP.
The BAAQMD believes that air pollution from temporary
local construction skews the actual monitoring data.
c Ambient Santa Clara County PM levels are currently below
federal standards. Therefore, bringing levels to federal
standards does not reduce health effects.
Source: Energy and Resource Consultants, Santa Clara Criteria
Air Pollutant Benefit Analysis, Office of Policy Analysis, US
EPA, May 1987.
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Table 2-2
HEALTH EFFECTS ATTRIBUTABLE TO 1985 GASOLINE LEAD5
Children Children
Men Women Age 6-17 Age < 6
ANNUAL CASES:
Blood/FEP
Fetal
Reproductive
Renal
Neurological
Anemia
Hypertension*3
Heart Attacks0
Deaths^
165
NA
16
0.7
571
NA
2,380
8.8
8.8
17
2
NA
0
20
NA
NA
NA
NA
34
NA
NA
0.16
136
NA
NA
NA
NA
974
NA
NA
95
260
4
NA
NA
NA
a Estimated health effects are from lead in gasoline, the
major source of airborne lead. The health effects calculation
for lead assumes that the threshold is well below the Federal
standard.
b Based on 119,000 men aged 40-59.
c Predicted number of fatal and nonfatal myocardial
infarctions related to increases in blood pressure, males
ages 40-59.
d Predicted number of deaths from all causes related to
increases in blood pressure, males ages 40-59.
Source: Energy and Resource Consultants, Santa Clara Criteria
Air Pollutant Benefit Analysis, Office of Policy Analysis, US
EPA, May, 1987.
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Table 2-3
ESTIMATES OF WELFARE BENEFITS OF POLLUTANT REDUCTION*
(Thousands of dollars annually)
Federal California
Standards Standards
VISIBILITY (PM):
Value of improved SO S 20,900
visibility
MATERIALS DAMAGES;
Value of replacement and
avoidance costs for materials
- particulate matter SO $ 66,700
- ozone $ 28 S 63
* Does not include value of health risks reduced.
Source: Energy and Resource Consultants, Santa Clara Criteria
Air Pollutant Benefit Analysis, Office of Policy Analysis, US
EPA, May 1987.
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Table 2-4
1984 CRITERIA POLLUTANT LEVELS FOR
SELECTED CITIES
1984 Ozone
(highest
hour-ppm)
1984 TSP
(annual geometric
iriean-ug/m-^)
1984 CO
(highest 8-hour
average-ppm)
Selected Bay Area Cities
San Josea
Los Gatosb
Fremont
Livermorec
Richmond
Pittsburg
Vallejod
Napa
Santa Rosa
San Rafael
San Francisco6
Redwood City
.16
.17
.15
.15
.09
.16
.14
.11
.09
.11
.10
.11
79
—
50
56
56
57
41
50
37
56
60
44
12
—
5
4
5
5
10
7
5
6
8
6
Selected U.S. Cities
Los Angeles .29
New York City .17
Washington, D.C. .14
Chicago .15
Denver .12
105 (Lynwood)
64
64
85
142
19(Lynwood)
15
14
11
20
a Highest annual average TSP and 8-hour CO in the Bay Area.
b Greatest number of ozone exceedences in Bay Area.
c Greatest number of ozone exceedences in Bay Area outside
Santa Clara County.
d Highest 8-hour CO in Bay Area outside Santa Clara County.
e Highest annual average TSP in Bay Area outside Santa Clara County.
Sources: California Air Resources Board, "Summary of 1984 Air
Quality Data," Sacramento, California.
U.S. Environmental Protection Agency, "National Air
Quality and Emissions Trends Report 1984," Research
Triangle Park, North Carolina.
(From: Energy and Resource Consultants, Santa Clara
Criteria Air Pollutant Benefit Analysis, Office of
Policy Analysis, US EPA, May 1987.)
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2-15
levels to account for temporary local construction activity
that is believed to bias the monitoring results; and sensitivity
cases using low pollution levels to account for possibile
health effects below the standards.
Health and Welfare Effects
The major result of this study is that significant health
and welfare benefits can be expected by reducing air pollution
to Federal and especially to State ambient standards. When
the PM levels are adjusted to account for temporary influences,
the County just meets the current Federal PM standard. If
the California PM standard was met, Santa Clara County could
expect a reduction of 0 to 51 deaths (with 37 as best estimate),
200 to 4200 emergency room visits, and 270,000 to 580,000 re-
stricted activity days (RAD = days spent in bed, days missed
from work, and days when activities are restricted to a minor
degree.)
The estimated health benefits of meeting the Federal ozone
standard are about 1/5 of the benefits of meeting the California
standard if the California standard is assumed to be the true
health effects threshold. If the Federal standard were reached,
there is an expected annual reduction of 100 to 700 asthma
attacks, 25,000 cases of eye irritation, and 12,000 to 15,000
respiratory restricted days. If the California standards were
reached there is an expected annual reduction of 63,000 to
86,000 respiratory restricted days, 500 to 3,600 asthma attacks,
and 99,000 cases of eye irritation.
Health effects from lead from gasoline were estimated for
four subpopulations (men, women, children age 6-17, and children
less than 6) and several different health effects. These esti-
mates are presented on Table 2. The estimates suggest that in
1985, adult males incurred an additional 165 blood effects
(disruption of red blood cell production), 16 reproductive
effects (malformed sperm), 571 neurological effects (effects on
the peripheral nervous system), 2,380 cases of hypertension, 8.8
fatal and non-fatal heart attacks, and 8.8 deaths from all lead
related causes. Children under age 6 are estimated to have
incurred an additional 974 blood effects, 95 renal effects
(impaired kidney function), 260 neurological effects, and 4 cases
of anemia. The expected health effects are relatively low
for women and children age 6-17.
The welfare benefits for particulate matter (i.e., dollar
value of visibility improvements and materials damages avoided)
are large compared with ozone. If the California PM standard
was reached, over $65 million in materials damages could be
avoided. However, the ozone damages avoided by meeting the
State ozone standard amount to less than $100,000.
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Quantitative estimates of the benefits of meeting Federal
or California standards for CO are not presented due to diffi-
culties in estimating the relationship between carboxyhemoglobin
(COHB) and ambient CO levels. Estimates were made of the
number of people at risk of adverse health effects due to COHB
levels measured in 1976. Measurement of people at risk differs
from other health measures because not all people at risk will
develop health effects. It was estimated that 5,000 to 8,600
adult nonsmokers with existing heart disease are at increased
risk of angina pain and 5,600 adult nonsmokers are at risk of
reduced exercise capacity and vigilance (i.e., the ability to
carry out complex tasks such as driving). 56,500 smokers are
at risk of reduced exercise capacity and 104,000 smokers are at
risk of reduced vigilance. The estimated health effects caused
by CO are not shown in Tables 1 or 2 to avoid confusing them
with the measures used to estimate health benefits for the
other pollutants. The CO analysis should be considered
preliminary and more uncertain than the estimates for PM and
ozone. No welfare damages were estimated for CO because there
is no evidence of damages.
Comparison of Federal to State Standards
Because California standards are stricter than Federal
standards, additional health benefits may occur by attaining
California standards. This is especially true for the State PM
standard where the county might expect both health and welfare
benefits. Of course, the State standards will be more difficult
to achieve.
Comparison to Results of the Stage I Air Toxics
Risk Assessment
There are two major differences between the risk assessment
performed in Stage I and this study: the relevant health effects,
and the analytic methodologies.
Comparing the magnitude of health impacts estimated in
Stage I to those estimated for this report entails contrasting
cancer incidence (not death) from toxics, to increased mortality
(probably related to hypertension, bronchitis, or emphysema),
emergency room visits, asthma attacks, etc. Some of these
effects are less serious than a cancer diagnosis. However,
certain effects, such as death from a respiratory problem or a
heart attack, can be considered more serious than a cancer
diagnosis, which is not always fatal.
There are some important differences between the methodol-
ogy used in Stage I and the methodology used here. First, the
Stage I methodology used upper bound estimates of health risk
(estimates more likely to overestimate than to underestimate
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2-17
actual health risk); whereas this methodology used observed
relationships, which are closer to best estimates. Second, the
information underlying the Stage I risk assessment was mainly
extrapolation from animal studies or occupational studies;
whereas this study used mainly epidemiological information.
Third, the estimates of exposure for Stage I are less certain
than the estimates of exposure for this study. After consider-
ing all these factors, the Stage I estimates for air toxics
should be considered more uncertain than the figures estimated
for conventional (criteria) pollutants.
The air toxics analysis in Stage I examined human exposure
for 11 organic compounds, 8 toxic metals, and organic particu-
lates, and estimated a 0.8 to 7.8 annual increase in cancer
incidence, with 2.2 as the midpoint. To put these numbers in
perspective, the health effects estimated for particulate mat-
ter and ozone (the numbers for which we have the most confidence)
suggest zero reduced mortalities if Federal standards are
reached because Santa Clara County is already in compliance
with Federal standards. However, if California standards are
considered the threshold of effects, the expected reduction in
mortality achieved by attaining the standards would be 0 to 57
deaths per year, with 37 as the best estimate. Eliminating
lead from gasoline would be expected to result in an additional
reduction of about 9 deaths per year. Comparing only these
most serious effects (increased cancer incidence and increased
mortality), it appears that the health effects from conventional
pollutants are at least as significant as those from air toxics
estimated in Stage I.
Comparison of less serious health effects yields a similiar
conclusion. Stage I estimated that 100,000 people were at risk
for blood effects (such as anemia and/or propensity for infec-
tion) from benzene. This study indicates that if California
standards were met, Santa Clara County could expect reduction
of the following health damages: 198 to 4,154 emergency room
visits, 269,000 to 584,000 restricted activity days, 500 to
3,600 asthma attacks, and 63,000 to 86,000 respiratory restricted
activity days.
In summary, although comparisons are imperfect, the health
damages estimated here from conventional air pollution appear
as significant as those estimated in Stage I. However, the
health effects from toxic air pollutants considered in Stage I
have been studied less and therefore quantification is less
reliable.
Results in Dollar Value
Dollar estimates of the value of preventing each of the
nonfatal health effects were developed to facilitate compari-
sons of the relative significance of the different effects.
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2-18
A modified cost-of-illness approach was used, which estimated
the value of work lost and the average medical expenditures
for some of the health effects. These estimates probably do
not reflect the full value of preventing illness because they
do not account for the discomfort and inconvenience exper-
ienced. The cost-of-illness figures for effects such as eye
irritation due to ozone should be viewed as more uncertain
than other figures. Except for mortality estimates, Table
2-5 expresses the dollar value saved by reducing pollutant
levels.
If Federal standards are met, an estimated $656,000 of
health damages could be avoided. All of this is attributed
to Ozone because Santa Clara County is already in compliance
with the Federal PM standard. Meeting the more stringent
California standards for ozone and particulates would result
in an estimated reduction in health damages valued at over
$100 million. Almost all of these estimated benefits are
attributed to reductions in PM.
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2-19
Table 2-5
ESTIMATED ECONOMIC VALUE OF WELFARE AND
MORBIDITY BENEFITS OF POLLUTION REDUCTION*
- thousands of dollars annually -
Federal State
Standards Standards
PARTICULATE MATTER:
Morbidity $ 0 $ 16,000
Welfare 0 88,000
Total 0 104,000
OZONE:
Morbidity 628 3,214
Welfare 28 63
Total 656 3,277
Total Ozone and PM $ 656 $ 107,277
* Does not include value of reduced risk of mortality.
Source: Energy and Resource Consultants, Santa Clara Criteria
Air Pollutant Benefit Analysis, Office of Policy Analysis, US
EPA, May 1987.
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ACTION PLAN
The IEMP acknowledged that significant air quality improve-
ment has been made over the last fifteen years of pollution
control by Federal, State, and local agencies, and noted that
all criteria pollutants except carbon monoxide and ozone are in
attainment in Santa Clara County. However, based on the IEMP
analysis and on the experience of the participants, the IEMP
found that the health risks associated with all four of the
pollutants studied are of concern, and made a series of nine
recommendations.
1) The BAAQMD, and ARE, in cooperation with EPA, ABAC
(Association of Bay Area Governments), and MTC (Metropolitan
Transportation Commission), should continue vigorous efforts
to achieve the federal amhient standards for carbon monoxide
and ozone. The study shows that significant health and
welfare benefits can be achieved by bringing ambient levels
of CO and ozone in compliance with the Clean Air Act.
2) The ARE and BAAQMD should increase the priority of
controlling particulate emissions. Exposure to particulates
at current levels results in some of the most significant
health effects of the four pollutants studied, and deserves
increased attention. In particular, ARE should place a high
priority on controlling fine particles by achieving the
upcoming Federal PM-10 standard (and the existing State
standard).
3) The ARE and BAAOMD should implement measures to achieve
California standards for criteria pollutants. Additional health
and welfare benefits are achievable by improving air quality
from federal to State ambient air quality standards. Federal
standards should not be considered the ultimate goal of the ARE
and BAAOMD efforts and, where feasible and cost effective, they
should implement measures to achieve State standards for ozone,
PM-10, and carbon monoxide.
4) The cities and County should reduce emissions of these
pollutants. Efforts might include:
a. Adopt an air quality element into city and county
general plans. Santa Clara county is adopting BAAQMD1s
model general plan element (BAAQMD Board Resolution
No. 1666, May 21, 1986) and individual cities can do
the same.
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2-21
b. Work with BAAQMD to develop, adopt, and implement
effective local street sweeping programs and other dust
abatement measures. (Street sweeping reduces PM levels
and is also expected to have water quality benefits.)
c. Work with BAAQMD to further regulate and enforce
construction related particulate control programs.
d. Control, through public education and possibly future
regulation, emissions from residential wood combustion.
(Discussed further on page 2-55.)
e. Encourage voluntary emission reductions through actions
such as carpooling, mass transit, reduced use of
aerosols and other consumer solvents, etc. (Discussed
further on page 2-56.)
5) The Bureau of Automotive Repair (BAR), ARE, and California
Legislature should accept and implement the recommendations
of the State Inspection and Maintenance (I/M) Review Committee,
The California I/M review committee published an evaluation
of the smog check program in April, 1987. This report was
prepared for the California Legislature and contains two sets
of recommendations aimed at improving the biannual inspection
and maintenance program: recommendations that can be imple-
mented without additional legislation, and recommendations
that can not.
In addition to these recommendations, the following
opportunities for improvement to the I/M program should be
pursued by the legislature: (1) the I/M program should require
annual inspections, (2) the program should be conducted by
centralized state inspection stations, (3) the limits on
costs to repair engine defects contributing to air pollution
should be raised, and (4) automobiles from the north-central
air basin (Monterey, Santa Cruz area) should be subject to
the I/M program if they commute to Santa Clara County.
6) The BAAQMD and ARB should explicitly quantify co-control
relationships in research and regulatory decisions. Control
strategies that reduce emissions of criteria pollutants may
affect emissions of air toxics. For instance, a BAAQMD
regulation discouraging use of paints with reactive VOCs
(volatile organic compounds) reduces ozone formation, but
increases emissions of toxic (but non-reactive) VOCs that
are used as substitutes. Another example is increased
emissions of formaldehyde (an air toxic) that may occur if
methanol fuel replaces petroleum in order to reduce criteria
pollution.
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Effects of criteria pollution controls on air toxics
emissions and of air toxics controls on criteria pollutant
emissions should be included when weighing costs and benefits
of control strategies. In addition, co-control should be
explicitly evaluated in the ARB's criteria regulation
development, Tanner process, and in the BAAOMD's rule making
process.
7) BAAQMD, in cooperation with ABAC and MTC, should continue
region-wide planning and pollution control. Santa Clara
County receives air contaminants emitted in other counties
and produces air pollution that is transported outside the
County. The study indicates that Santa Clara Valley's criteria
pollutant emissions are about the same per capita as those of
the Bay Area as a whole. However, for a variety of reasons
including airborne pollution transport, air quality for some
pollutants (e.g., ozone) is worse in Santa Clara County than
in that other areas of the Bay. BAAQMD should continue to
explicitly account for pollution transport in their research
and rule development. Bay area-wide adoption of the proposals
in this report is imperative. In particular, transit system
management (TSM) and mass transit improvements throughout the
region should be pursued.
8) Important data gaps are reflected in the following
recommendations, though remedial and regulating efforts should
not be delayed while this data is being gathered.
a. DOHS and EPA should develop additional information on
the health effects and dose response relationships of
carbon monoxide. DOHS and EPA are the most logical
sources of this research.
b BAAOMD and ARE should continue their work to determine
the sources and particle size distribution of particu-
late matter. This is partially addressed by BAAOMD's
inventory work planned and in progress, and will be
helpful to the AQMD and ARB in formulating the State
Implementation Plan (SIP) for the Federal PM-10
standard.
9) BAAQMD, ARB, and EPA should continue research and control
of toxics.Criteria pollutants have been studied for much
longer and in far greater detail than toxics, so the informa-
tion on their (criteria pollutants) hazards is more abundant
and reliable. The criteria pollutant study shows that conven-
tional air pollutants are still of concern, but it does not
suggest reducing efforts at understanding and controlling
toxic air contaminants. Efforts such as the BAAOMD's ongoing
air toxics inventory activity should be continued.
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MONITORING FOR TOXIC ORGANIC PARTICULATES
SUMMARY OF ANALYSIS
Objective of Study
The objective of this research was to provide information
on the levels of toxics in the ambient air in Santa Clara
Valley and estimates of health risks from these toxics. Specifi-
cally, this project was designed to improve the information
base by monitoring for polycyclic aromatic hydrocarbons (PAH)
and thereby improve the estimates of the relative health risks
posed by PAH compounds.
Background and Scope of Work
The IEMP Stage I report estimated that PAH compounds posed
a relatively high risk of cancer compared to other air contam-
inants studied. However, estimates of ambient air concentrations
for PAH compounds were relatively uncertain compared to other
air toxics estimates in the Stage I report because neither
local emissions information nor local monitoring information
were available. This combination of both relatively high and
uncertain estimated health risks led to the funding of a moni-
toring project for PAHs in Stage II.
The funding, sampling, and analysis were made possible
through the cooperation of three agencies. The Bay Area Air
Quality Management District (BAAOMD) provided consultation in
setting up the project and collected the air filters. The
California Public Health Foundation, in association with the
Air and Industrial Hygiene Laboratory of the California Depart-
ment of Health Services (DOHS), analyzed the samples. DOHS
staff also provided technical reports to EPA and briefed the
IEMP subcommittee. EPA's IEMP provided the funding, brought
the research to the IEMP committees, and revised the Stage I
risk estimates.
An interim report, titled Monitoring for Polycyclic Aromatic
Hydrocarbons, Mutagens and Standard Particulate Pollutants in
Santa Clara County Community Air, was released on June 30, 1987.
A final report will be prepared in September, 1987.
Methodology
The monitoring effort consisted of two sampling locations,
analysis of eight PAH compounds, and analysis of two years of
data. The two locations were both in San Jose; one at Moorpark
Avenue near Bascom Avenue, and one at Moffett Boulevard near
Stevens Creek Road. The Moorpark site is a permanent BAAQMD
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station where particulate sampling has taken place for many
years. The Moffett Boulevard sampling site is temporary and
was established for the duration of this project.
Many PAH compounds are known to be present in ambient air
particulates. Among these, eight compounds of particular interest
were selected for analysis. The two years of data were analyzed
somewhat differently from one another. For the period of July
1985 through June 1986, samples from the Moorpark station were
refrigerated until June 1986 and then analyzed in four month
composites. For the period July 1986 through June 1987, samples
were collected from both stations and analyzed every two months.
To date, data are available for the period of July 1985 through
February 1987. The report also provides results of the levels
of TSP, lead, sulfate and nitrate. In addition, the Ames
Mutagenicity test (a test that measures the mutagenic activity
of chemicals on sensitive bacterial tester strains) will be
conducted on these samples.
Results
Monitoring Results to Date
The monitoring results to date are reported on Table 2-6
and 2-7 and show both the levels of PAH and the seasonal
variation. The annual concentrations across specific PAHs
range by an order of magnitude. Dibenz(a,h)anthracene (DBA)
has the lowest level with a yearly average of 0.2 ng/m3, and
Benzo(g,h,i)perylene (BgP) has the highest level with a yearly
average of 2.1 ng/m3. The average monitored value for Benzo(a)-
pyrene (BaP: 0.7 ng/m3) agrees with the Stage I estimate of 0.6
ng/m3 (range of 0.03 to 1.9). These levels are roughly compar-
able to those found in neighboring Contra Costa County, providing
another check on their general accuracy.
No significant differences in levels were found between
the two monitoring locations. This may indicate that the ambient
levels do not vary greatly across the county and that the
measured levels are representative of the county as a whole.
Variation in ambient levels was found to be seasonal, with
the highest level in the winter months of November to February.
It is difficult to isolate the cause of the seasonal variation.
Possible explanations include: changes in weather patterns between
summer and winter months with lower ventilation in the winter
months causing higher PAH levels; variation in source loading
between winter and summer with a possible increase in wood
burning in winter months; and chemical transformation of PAHs
on the filter in summer months causing PAHs to be undersampled.
Of course, any combination of these explanations is possible.
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Table 2-6
PAH CONCENTRATIONS (ng/m3)*
IN AIR PARTICULATE MATTER EXTRACTS
Samples collected at Moorpark Avenue,
July 1985 - June 1986
7/85- 11/85-
PAH 10/85 2/86
Benzo(e)pyrene [BeP] 0.1 2.1
Benzo(b)f luoranthene [BbF] 0.1 1.3
Benzo(k)f luoranthene [BKF] 0.1 0.6
Benzo(a)pyrene [BaP] 0.2 1.7
Dibenz (a ,h)anthracene [DBA] 0.1 0.3
Benzo(g,h, i )perylene [BgP] 0.9 4.6
Indeno(c,d)pyrene [IDP] 0.3 2.1
Coronene[COR] 0.7 1.9
TOTAL 2.5 14.6
* Values listed as 0.1 are less than or equal
Source: Flessel, Peter; Wang, Yi; Kim, In-suk
Polycyclic Aromatic Hydrocarbons, Mutagens and
Pollutants in Santa Clara County Community Air
San Jose
3/86-
6/86 Average
0.3 0.8
0.1 0.5
0.1 0.3
0.1 0.7
0.1 0.2
0.9 2.1
0.4 0.9
0.4 1.0
2.4 6.5
to 0.1.
, Monitoring for
Standard Particulate
, California Departmen
of Health Services, June 30, 1987.
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2-26
Table 2-7
PAH CONCENTRATIONS (nq/m3)*
IN AIR PARTICULATE MATTER EXTRACTS
Samples collected at Moorpark Avenue, San Jose
Two month composites July, 1986 - February, 1987
PAH
BeP
BbF
BkF
BaP
DBA
BgP
IDP
COR
7/86-8/86
0.2
0.2
0.1
0.1
0.1
0.8
0.2
0.4
9/86-10/86
0.4
0.1
0.1
0.1
0.1
0.6
0.2
0.5
11/86-12/86
2.3
1.7
1.0
2.0
0.4
4.1
2.5
2.5
1/87-2/87
3.8
1.5
0.9
1.9
0.4
3.3
2.3
3.3
TOTAL
2.1
2.1
16.5
17.4
* Values listed as 0.1 are less than or equal to 0.1
Source: Flessel, Peter; Wang, Yi ; Kim, In-Suk, Monitoring for
Polycyclic Aromatic Hydrocarbons, Mutagens and Standard Particulate
Pollutants in Santa Clara County Community Air, California Department
of Health Services, June 30, 1987.
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Estimation of Health Risk
Estimating the health risks associated with the eight PAH
compounds poses some difficulties because of the lack of infor-
mation on the health effects of all of the compounds. Toxicolo-
gists believe that many PAH compounds pose cancer risk. However,
EPA's Cancer Assessment Group has assessed the health effects
for inhalation of only BaP. Therefore, in quantifying estimated
cancer risk, IEMP was limited to the use of potency information
for only BaP.
Two approaches were used to estimate health risk from PAHs.
First, the EPA potency score for BaP (3.3 x 10~3 ug/m3*"1)) was
multiplied by the average ambient level of BaP in the Santa
Clara Valley (0.7 ng/m3). By this method, individual cancer
risk from exposure to BaP is 2.3 x 10~6. Multiplying individual
risk by the estimated population of Santa Clara Valley (1.4
million) yields an annual incidence of about 0.05 cases per
year. This approach assumes that BaP, which is fairly well
characterized in terms of toxicity, is the only toxic constituent
of the monitored PAH group. However, some of the other PAHs
may also be carcinogenic. Therefore, the result of this approach
is considered a lower bound estimate of risk.
The second approach used to estimate health risk assumed
that the entire group of related compounds in the BaP group
might also have cancer potency equivalent to BaP. This approach
was also used in the Stage I analysis of health risk. While
this may overstate the potency of the other PAH compounds
monitored, it does not account for the possible carcinogenic
potency of other PAH compounds not sampled.
The substances sampled for this analysis correspond roughly
to the BaP group (some members of the BaP group were not sampled
because of analytic constraints). Applying the BaP potency
score to the average concentration of all the substances sampled
yields an estimated individual health risk of 2.1 x 10~5 and an
annual estimated incidence of 0.4 cases. These figures are com-
parable to the Stage I estimates of 3.5 x 10~5 individual risk
(range: 7 x 10~7 to 7 x 10~5); and an annual incidence of 0.7
cases (range: 0.01 to 1.3). These results are summarized in
Table 2-8.
In general, monitored levels of these eight compounds appear
to correspond well with the estimates of PAH from Stage I. While
estimates of health risk are uncertain due to the limited potency
information, monitoring results to date appear to confirm the
estimates of PAH exposure levels made in the Stage I analysis.
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Table 2-8
COMPARISON OF STAGE I ESTIMATES AND REVISED ESTIMATES
OF CANCER RISK FROM PAHS
Point estimate
(Range)3
Stage I
Revised Estimates
BAP GROUP
AMBIENT CONCENTRATION (ng/m3):
0.2 - 20.0
INDIVIDUAL LIFETIME RISK:
Weight of
8 PAHs1 yearly Evidence of
average 7/85 - carcinogenicity
6/86 monitoring to humans*3
6.5
BaP Group
3.5x10-5 2.1 x 10-5 B2 - E
(7xlO-7 - 7xlO-5)a
BaP Alone
ANNUAL INCIDENCE:
BaP Group
BaP Alone
0.7
(0.01 - 1.3)
2.3 x 10-6
0.4
0.05
B2
B2 - E
B2
a
b
Numbers in parentheses are the range of estimated risk.
The weight of evidence of carcinogenicity for the compounds
included in the analysis varies greatly, from very limited
to very substantial. According to EPA's categorization of
levels of evidence of carcinogenicity, A = proven human car-
inogen; Bl = probable human carcinogen (limited human
evidence); B2 = probable human carcinogen (insufficient
human evidence but sufficient animal evidence); C = possible
human carcinogen; D = not classifiable; E = no evidence.
Sources: Flessel, Peter; Wang, Yi; Kim, In-Suk, Monitoring for
Polycyclic Aromatic Hydrocarbons, Mutagens and Standard
Particulate Pollutants in Santa Clara Community Air, California
Department of Health Services, June 30, 1987
Hinman, Keith; Schwartz, Don; Soffer, Eileen, Santa Clara
Valley Integrated Envrionmental Management Project, Revised
Stage I Report, Office of Policy Analysis, US EPA, May 27, 1987.
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Conclusions
Improved Data on Ambient Levels and Health Risk
This monitoring project has significantly improved the
local data base on ambient PAH levels by confirming and refining
the Stage I modelled estimates. Risk assessment estimates are
improved, although they are still limited by uncertainty about
the potency of PAH compounds as a group.
Need for More Research on Source Identification
If the monitored levels of PAHs are judged to warrant
continued concern, an important remaining question is the
relative contribution of different sources of PAH compounds.
This research was not structured to provide information on
source identification. Good source data are a prerequisite to
consideration of detailed risk management options for
controlling PAHs.
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ACTION PLAN
The IEMP found, on the basis of the draft final report,
that the ambient levels of PAHs are within the range predicted
in Stage I and are similar to those measured in Contra Costa
County. The estimated risks presented by these concentrations
rank relatively high among risks predicted for other toxic air
and drinking water contaminants in Santa Clara County. These
risks were of concern to the IEMP participants, and inspired
the following recommendations:
1) BAAQMD and DOHS should continue monitoring for PAHs along
with other toxics. This program should continue to provide
data on PAH levels in Santa Clara County and the greater Bay
area. In addition, the IEMP supports periodic assessment of
the monitoring network to assure that the number and location
of monitoring stations provide a comprehensive assessment of
air quality in the region.
2) BAAQMD should complete the PAH source inventory work in
progress (stationary sources) and planned (area and mobile
sources). Relative contributions of two major sources of
PAHs—mobile sources and residential wood combustion (wood
stoves and fire places)—remain a significant uncertainty.
Reliable source identification is necessary before control
measures can be evaluated. Therefore, the IEMP committees
particularly encourage a thorough and timely completion of
the area and mobile source inventories, currently scheduled
for June, 1988.
3) ARE should increase attention to PAHs in the Tanner
Process.PAHs have been nominated,but not scheduled,for
review as a Toxic Air Contaminant (Tanner group IIB). Stage
I and the PAH monitoring effort suggest that PAHs present a
higher risk than some of the pollutants in group IIA (e.g.,
trichloroethylene, perchloroethylene). The IEMP encourages
ARE to schedule PAHs for review.
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CONTROLLING AIR TOXICS SOURCES
SUMMARY OF ANALYSIS
Objective of the Study
The air toxics controllability study was the portion of
Stage II devoted to risk management of air toxics. The major
analytic goal of the study was to examine costs and benefits of
controls for a range of sources of air toxics to help set
priorities for regulatory efforts.
Background and Scope of Work
Risk management of air toxics in Santa Clara Valley is
currently performed by three regulatory agencies. At the
national level, National Emissions Standards for Hazardous Air
Pollutants (NESHAPs) are being developed by EPA. Because this
is a relatively slow process, the California Air Resources
Board (ARE) has implemented a parallel state program (the
Tanner process) which is expected to be both quicker and stricter
than the Federal program. Regulations for benzene and chromium,
two of the highest contributors to airborne toxic risk both
locally and nationally, are far along in the Tanner process.
Many of the other toxics examined in Stage I (e.g., hexavalent
chromium and ethylene oxide) are also due for rule promulgation
over the next few years.
At the regional level, the Bay Area Air Quality Management
District (BAAOMD) affects air toxics emissions in two primary
ways. (The District's ten-point air toxics plan includes other
mechanisms as well.) First, the District is working with the
ARE to develop model rules for the Tanner process where one of
their most significant contributions is compiling inventories
of sources of organic gases and metals. (The metals inventory
is being funded by EPA Region IX in part as a result of Stage I
findings, which identified toxic metals as a relatively signifi-
cant contributor to overall air toxics risk.) Second, the Air
District affects air toxics emissions via their rule making
procedure known as Regulation 8. Regulation 8 focuses on
reducing ozone concentrations, and several air toxics are
controlled directly because they contribute to ozone formation.
Risk management of air toxics is currently being studied
and performed by the BAAOMD, the ARB, and the EPA air division
with budgets far exceeding that available to the IEMP. The
IEMP study is designed to complement the activities of these
regulatory agencies, and to offer perspective on how well their
programs address the priority air toxics issues in Santa Clara
Valley.
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In light of the Federal, State, and regional programs,
the goals of this study could be further defined as follows:
o Determine whether the lEMP's broad-brush examination
of current air toxics risk management activity can
suggest a reorganization of local air pollution
priorities.
o Provide recommendations to the State Tanner process (ARE
and BAAQMD) based on local priorities and perspectives.
Recommendations could include input on the cost and
effectiveness of air toxics emission controls being
considered under Tanner.
o Provide recommendations to regional and local agencies
(BAAQMD, Board of Supervisors, planning bodies, etc.)
on the need and approach for controlling sources
not included in the Tanner process, based on local
priorities and perspectives.
The next two sections outline the study methodology and
summarize the results. Following that, a brief conclusion section
details the policy decisions that are suggested on the basis of
the analytic results. The complete analysis is documented in
the Air Toxics Controllability Analysis, Volumes I & II, released
in May 1987.
Methodology
The study was composed of three distinct tasks:
o Source Selection, where a group of sources was chosen
for detailed examination,
o Controllability Study, in which the cost-effectiveness
of direct control of these sources was examined, and
o Land-Use Control Evaluation, in which land-use control
was discussed as a method of risk reduction complementary
to the direct controls examined in the controllability
study.
Source Selection
In this analysis, the Santa Clara County air toxics sources
were grouped into source categories and screened to select the
most promising for detailed analysis. Four criteria were used
in this initial screening:
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o Estimated health risk,
o Feasibility of control,
o Data availability,
o Impacts of current regulatory programs.
Estimated health risk; The magnitude of the risk to
human health was the most important criterion in selecting
sources for further examination. Almost all the health effects
considered were forms of cancer for which risk was measured in
terms of the probability an individual faces of contracting
cancer over a lifetime. (A one in a million chance of contract-
ing cancer is typically written as 1 x 10~6 or just 10~6.)
Stage I also evaluated non-cancer health effects. The only
chemical estimated in the ambient air above a non-cancer thres-
hold concentration was benzene and the only other that was
fairly close was 1,1,1-Trichloroethane (TCA). Both of these
were included in the analysis although no generally accepted
method of quantifying non-cancer risk exists and, as far as is
known, the risk from TCA exposure below the threshold is zero.)
Uncertainty in risk estimation is discussed later.
In screening sources for study under NESHAPs, EPA uses a
flexible guideline probability of 10~4 to the maximum exposed
individual (MEI). That is, if preliminary and conservative
calculations estimate that the MEI faces a risk of 100 chances
in a million (100 chances in a million equals one chance in ten
thousand) of contracting cancer because of the examined source,
then the source passes the screen and is subject to further
examination (and possible control) under NESHAPs. However,
this process precludes examination of area sources where a large
number of people are exposed to lower levels of risk. To
account for area source emissions, sources also meet the NESHAPs
screen if they are expected to cause one or more cancer inci-
dences per year over the entire exposed population.
In our study, sources were given further consideration if
the estimated risk to the MEI was greater than 10~6. If the
average risk was greater than 10~6, then the MEI risk, by defin-
ition, was also greater than 10~6. Therefore, our screen was
clearly more inclusive than NESHAPs for the MEI case. The two
screens are harder to compare for area sources of concern.
However, most area sources that are expected to cause more than
one cancer incidence per year probably present an MEI risk
greater than 10~6. Thus, our screen should be at least as
inclusive as NESHAPs for area as well as for point sources.
Feasibility of Control; Sources were not considered for
study if there were no known direct control methods available,
even if the emissions met the risk screen described above.
For example, the Kaiser cement plant is equipped with the most
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efficient particulate control device available, and therefore
was excluded from further analysis.
Data Availability: Sources and chemicals were excluded
from the study where there was insufficient information to
analyze them. Members of the Air Toxics Subcommittee were
interested in examining arsine and phosphine emissions from
semiconductor facilities. However, poor toxicological and
emissions data on these compounds limited the feasible analysis.
In addition, there may be sources and chemicals posing risks
that were not mentioned in the report because they had not yet
been identified.
Impacts of Current Regulation Programs; The status of
existing regulatory efforts was considered in selecting sources
for analysis. To avoid duplicative work, treatment of benzene
controls was largely a summary of applicable information from
the ARE's recently completed State-wide Benzene Control Plan.
Conversely, glycol ether emissions from semiconductor facilities
were examined in part because they are not being considered
under the Tanner process.
Based on these four criteria, nine source categories were chosen
for control analysis:
Point Sources
Chrome plating
Cooling towers
EtO sterilization
Semiconductor positive
photoresist operations
Area Sources
Solvent degreasing
Primary Pollutant of Concern
Hexavalent chromium
Hexavalent chromium
Ethylene oxide
Glycol ethers (cellosolve)
Dry cleaning
Light-duty mobile sources
Heavy-duty mobile sources
Residential wood combustion PAHs
Primary Pollutant of Concern
Perchloroethylene
Benzene
PAHs
Chlorinated solvents (i.e.,
trichloroethylene, perchloro-
ethylene, methylene chloride,
and 1,1,1-trichloroethane)
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Arsenic, benzene, hexavalent chromium, and PAHs from all
sources contribute over 75% of the airborne risk estimated in
Stage I. With the addition of the aforementioned cement plant
(wood combustion and the cement plant account for almost all of
the identified arsenic emissions), the nine sources above
produce over 80% of Santa Clara County's emissions of these
four air toxic contaminants. Table 2-9 presents source contri-
butions as estimated by Stage I and by additional work in
Stage II.
Controllability Study
Controllability studies performed under Tanner and NESHAPs
compare the cost-effectiveness of several controls for one
source. If all else is equal and two controls reduce risk by
the same amount, the less expensive control is superior.
The IEMP controllability study took a different perspec-
tive. Instead of examining several controls for one source, we
examined one control each (in general) for several sources.
The justication for this approach is that the IEMP analysis was
intended to set control priorities among sources rather than to
identify the most cost-effective control for a given source.
For example, we did not wish to set priorities among different
controls for hospital sterilizers, but between controlling
hospital sterilizers and controlling chrome platers.
Note that by choosing a polypropylene ball bath cover to
reduce decorative chrome plater emissions, we decided not to
consider demisting additives, wet scrubbers, chemical substitu-
tion, or other possible controls. The controls examined were
not necessarily the most cost-effective, nor the ones that can
achieve maximum risk reduction. However, they appeared to be
the most appropriate with regard to risks, control costs, and
risk/cost tradeoffs. This decision process relied heavily on
professional judgement to select controls that provide signifi-
cant risk reduction at reasonable costs.
Where possible, we calculated the cost of control and the
emissions, exposures, risks, and estimated cancer incidence
reduced by control implementation. (Had some sources exceeded
health effect risk thresholds for non-cancer effects, we would
also have examined reductions in relation to thresholds.)
Combining the estimates of cost and reduced incidence results
in a cost-effectiveness value of dollars per reduced case of
cancer. Comparing the cost-effectiveness of controlling the
various sources then allows estimation of how most cost-effect-
ively to reduce risk to the general population. A similar
analysis was performed on the costs of reducing risks to maximum
exposed individuals (MEIs) near certain sources.
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2-36
Table 2-9
Percent Contributions to High Risk Pollutants
Pollutant
Residential
Mobile Wood Cement Chrome
Sources Combustion Plant Plating
Total
Arsenic
44%a
54%b
98%
Benzene
80%a
80%
Hexavalent
Chromium
8.5%b
80%t>
89%
PAHs
13%a
87%a
100%
a Air Toxics Controllability Analysis, Table 1-2.
b Air Toxics Controllability Analysis, Table 3-1.
Source: Radian Corporation, Air Toxics Controllability
Analysis, Volume I, Office of Policy Analysis, US EPA,
Final Report, May 27, 1987.
-------
2-37
A brief description of the controls examined for each of
the nine sources follows.
Point sources
Chrome plating. Rule-making workshops are in progress
for State regulation (Tanner process) of chrome platers. A 99%
efficient scrubber will probably be required for the one large
chrome plater in the Valley while polypropylene ball bath
covers may be acceptable for the smaller ones. Analysis of
this source offers insights into the cost-effectiveness of
controls that are likely to be mandated.
Cooling Towers. Substitution of a hazardous chemical
with a less hazardous one can complement or replace traditional
hardware controls. Chemical subsitution for chromates used as
corrosion inhibitors and biocides was considered in the analysis.
EtO Sterilization. A wet scrubber (under acidic condi-
tions) was analyzed for this source. Wet scrubbers force
pollutant-laden air to mix with water where the pollutant
either enters solution directly, or reacts with a chemical
additive to the water. In either case, treatment and/or dis-
posal of the water often becomes a second pollution control
issue, and one which we did not consider.
Semiconductor Positive Photoresist Operations. Thermal
and catalytic incineration were considered for controlling
emissions of glycol ethers used in the positive photoresist
process of semiconductor production. Positive photoresist has
grown in prominence throughout the Valley partially in response
to the Air District's Regulation 8, rule 30. This rule restricts
emissions of xylene, an ozone precursor used in negative photo-
resist. (Negative and positive photoresist are somewhat sub-
stitutable.) Although there is evidence that glycol ethers are
toxic (the California Department of Health Services has issued
a hazard alert warning against workplace exposures), there are
no generally accepted measures of toxicity at concentration
levels typically found in the ambient environment. Better
toxicity quantification is expected in the near future which will
complement the information generated in this study on control
costs and emission reductions.
Area sources
Dry cleaning. Transfer dry cleaning is an outdated
technology where clothes are transferred from a washer to a
dryer. During this transfer, there is considerable evaporative
-------
2-38
loss of perchloroethyene, the standard cleaning agent. The
newer dry-to-dry technology washes and dries in one machine and
uses 20% as much perchloroethylene. The report analyzed the
risk reduction obtainable by encouraging the fleet turnover from
transfer machines to dry-to-dry machines and by switching to
dry-to-dry machines using chlorofluorocarbon-113 (CFC-113)
instead of perchloroethylene.
Light-duty mobile sources. Based on the results of ARB's
Benzene Control Plan, we discussed seven measures for reducing
benzene emissions from motor vehicles and three from petroleum
marketing. Of these, the largest reductions can be achieved
respectively through a more stringent evaporative hydrocarbon
standard, and a 1.0% benzene limit in gasoline. The hydrocarbon
limit is actually directed at reducing ozone, and lowering
benzene emissions is a side benefit. Reducing emissions of
toxics as a parallel benefit to reducing criteria pollutants
(or vice versa) is known as co-control.
VMT Reductions. The report also discussed reducing
mobile source benzene emissions by reducing total vehicle miles
traveled (VMT). The strategies considered were based on infor-
mation generated in Santa Clara County's Transportation 2000
(T2000) study- They included carpool/vanpool programs, reserved
bus/carpool lanes, and ramp metering programs as well as exten-
sions and additions of bus and rail systems.
Heavy-Duty Mobile Sources. Heavy-duty vehicles are a
significant source of both organic particulates and benzene.
Two controls were considered: (1) retrofitting gasoline trucks
with catalytic converters, and (2) including trucks in the
existing automobile inspection and maintenance (I/M) program.
Residential Wood Combustion (RWC). EPA recently proposed
regulations for new wood stoves limiting particulate emissions.
This regulation will not affect existing low efficiency/high
emission stoves, so we examined the cost-effectiveness of replac-
ing such stoves with the newer technology. However, an estimated
75% of the RWC particulate emissions come from fireplaces which
do not apply to this strategy. Discouraging or forbidding wood
burning during air stagnation periods was considered, in addition
to stove replacement, as a means of reducing emissions from
both stoves and fireplaces. The feasibility of implementing
such control strategies should consider the ability of stove-
owning households to pay for stove replacement, and the percen-
tage of stove- and fireplace-owning households who would abide
by the burning curtailments.
-------
2-39
Solvent Degreasing. During vapor degreasing, a blanket
of solvent vapors is maintained between the liquid solvent
surface and the refrigerated coils. These coils reduce the
vapor emissions by condensing the solvent, which then runs back
into the bath. We analyzed the cost-effectiveness of achieving
further emission reductions by placing a second refrigerated
chiller above the first.
Land-Use Control Evaluation
All the controls discussed so far are direct controls, and
can be divided into two categories: (1) hardware controls, such
as scrubbers, chillers, and other technological changes, and
(2) chemical substitution, such as replacing perchloroethylene
with chlorofluorocarbons in dry cleaners. A third method of
reducing risks is land-use controls.
In the last section of the study we examined the risk
reductions accrued if buffer zones were created between emission
sources and residential populations. The farther apart the two
are, the more the pollutant disperses before it reaches people
and the less risk those people face. Increasing this buffer
zone could be an alternative or an addition to traditional
end-of-pipe controls. To explore the utility of this control
strategy, we analyzed the relationship between excess individual
cancer risk and the distance between source and receptor.
For each of the eight sources considered (perchloroethylene,
trichloroethylene, and methylene chloride degreasing, ethylene
oxide sterilizing, dry cleaning, chrome plating, gasoline
stations, and bulk gasoline storage), we estimated the stack
parameters for a small, medium, and large-sized facility.
Using these parameters (emission rate, stack height and diameter,
and exit velocity and temperature) and County meteorological
data, we calculated the dispersion of the emissions and the
resulting ambient levels of pollution at various distances from
the sources. Ambient concentrations were then converted to
human exposure levels and, in turn, to risk. Both conversions
were performed using conservative assumptions.
Results
Average Risk Reduction From Direct Controls (hardware
controls and chemical substitution).
Where possible, we generated estimates of the control cost
needed to reduce one estimated cancer incidence among the
exposed population. These values are summarized in Table 2-10.
-------
Table 2-10
SUMMARY OF COST EFFECTIVENESS ANALYSIS FOR
Source
Dry Cleaning6
Solvent
Degreasing
Residential
Wood Combustion
Hospital
Sterilization
Semiconductor
Manufacturing
AVERAGE9 RISK REDUCTION^
Control Method
Converting perc
transfer to perc
dry- to-dry
Converting perc
transfer to CFC
113 dry- to-dry
Converting perc
dry- to-dry
CFC 113 dry-to-
dry
Refrigerated
freeboard
chillers
Fuel efficient
wood stovesf
Fireplace and wood
stove burning
curtailments
Wet
scrubbers
Thermal
incinerators
Catalytic
Pollutant
(Weight of
Evidence of
Carcinogenicity|c
Perchloroethylene
(B2)
Pe rch lorethy le ne
(B2)
Pe rchloroethy lene
(B2)
Perchloroethylene ( B2 )
Trichloroethylene( B2 )
Methylene chloride (B2)
[q]
[g]
Ethylene oxide (Bl)
Cellosolve (NA)
Cellosolve (NA)
Cancer
Incidence
Reduction
Over 30 years ^
0.0019
0.0028
0.00044
0.069
0.021
0.12
0.9
0.74
0.38
th]
[h]
Net Present
Value for
30 Years of
Service ($)'
56,000
130,000
87,000
2,400,000
290,000
470,000
420,000
NA
1,200,000
57,200,000
56,000,000
Cost
Effectiveness
(Million $/
reduced
Incidence)^
29
50
200
36
14
4.1
0.47
NA
3.1
th]
fh]
I
*».
O
incinerators
-------
Table 2-10 (Continued)
Summary of Cost Effectiveness Analysis for
Average3 Risk Reduction (Continued)13
Source
Control Method
Mobile Sources Oxygen sensor
durability*
Pollutant
(weight of
evidence of
carcinogenicity)c
Benzene and
organic
particulates
(A-E)
Modifer certified Benzene and
new vehicle organic
registration*5 particulates
(A-E)
Mass transit
improvements
Catalyst
retrofit for
heavy-duty gas-
oline vehicles
I/M for heavy-
duty gasoline
vehicles
Benzene and
organic
particulates
(A-E)
Benzene and
organic
particulates
(A-E)
Benzene and
organic
particulate
(A-E)
Cancer
Incidence
Reduction
Over 30 Yearsd
0.09
0.034
0.14 to
0.29
2.3
0.31
Net Present
Value for
30 Years of
Service ($)d
OJ
NA
170,000,000
6,600,000
Cost
Effectiveness
(Million $/
Reduced
Incidence)^
KJ
i
•U
76
22
-------
2-42
Table 2-10 (Continued)
SUMMARY OF COST EFFECTIVENESS ANALYSIS FOR
AVERAGE9 RISK REDUCTIONb
(footnotes)
a The term "average" refers to the overall risk calculated for
the entire county population.
b Because of significant uncertainties in the underlying data
and assumptions, these estimates of risk are only rough approx-
imations of actual risk. They are based on conservative
estimates of exposure and potency and are more likely to over-
estimate risks than to underestimate them.
c The weight of evidence of carcinogenicity for the compounds
included in the analysis varies greatly, from very limited to
very substantial. According to EPA's categorization of levels
of evidence of carcinogenicity, A = proven human carcinogen;
Bl = probable human carcinogen (limited human evidence); B2 =
probable human carcinogen (insufficient human evidence but
sufficient animal evidence); C = possible human carcinogen; D
= not classifiable; E = no evidence.
All incidences and costs were normalized to 30 years to
facilitate comparison. Cost-effectiveness = net present value
of 30 years of service / cancer incidence reduced in 30 years.
See Section 5.0 of the full report for a detailed explanation
of the methodology.
e The net present value for the dry cleaning control costs
are based on one machine.
The control method involves replacing existing stoves with newer,
less polluting stoves.
9 Wood stove emissions include benzene, organic particulates,
and toxic inorganics. Emissions of these pollutants are all
reduced simultaneously, so that the cost of removal and
incidence reduction includes all three pollutant categories.
See Section 5.0 for a detailed explanation of the methodology.
n Cellosolve is believed to cause birth defects but not believed
to be carcinogenic. Therefore, calculating the reduction in
cancer incidence is not appropriate.
i Adoped by ARE in 4/85.
J Cost of control was attributed by ARE to criteria pollutant
reduction.
k Adopted by ARE in 12/85.
-------
2-43
It appears that the most cost-effective strategy evaluated
for reducing average risk is replacing inefficient wood stoves
with efficient ones. Unlike other measures, controlling this
source may place the direct financial burden on individual house-
holds. The estimated cost-effectiveness of average risk reduction
for the controls examined range from $0.5 million per reduced
cancer case for wood stove replacements to $200 million per
case reduced for converting perchlorethylene dry-to-dry dry
cleaning machines to CFC-113 dry-to-dry. (Chlorofluorocarbons
are suspected of damaging the earth's ozone layer, a global
environmental problem with potentially significant health and
ecological impacts. While these effects were not examined in
this study, EPA recommends against any control strategy that
would increase CFC emissions.)
Based only on cost-effectiveness, the second most attractive
control appears to be wet scrubbers for hospital sterilizers
($3.1 million per reduced cancer case), although this does not
reflect risk reduction to the MEI, which may be more important
in this case. The third best cost-effectiveness is attributed
to refrigerated freeboard chillers for methylene chloride
degreasers, at $4.1 million per reduced incidence. The estimated
cost-effectiveness of other degreasing varies greatly by solvent
because a cost credit proportional to the cost of the particular
solvent was attributed to the solvent recovery when using free-
board chillers.
In interpreting the estimates in Table 2-10 it is important
to bear in mind that the mobile source cost-effectiveness
values reflect co-control. Oxygen sensor durability and modifier
certified new vehicle registration were attributed a zero cost
because they are being mandated by the ARE to reduce ozone
formation. Thus, the reduced health risk from reduced benzene
concentrations is a side benefit to a control aimed at a criteria
pollutant. Conversely, if catalyst retrofits and I/M for
heavy-duty gasoline vehicles were implemented, emissions of
other hydrocarbons would also be reduced. If these co-control
benefits were fully accounted for, they would improve the
cost-effectiveness of the control.
MEI Risk Reduction From Direct Controls.
For area sources such as automobiles and residential wood
combustion, the effectiveness of reducing risk to the average
exposed population is the appropriate issue. But for point
sources like hospital sterilizers, the real public health
threat may be to a small population near the source facing much
greater exposures. In fact, MEI risk is often the critical
concern that guides regulations.
-------
2-44
Unfortunately, average cost-effectiveness can not be used
in determining MEI cost-effectiveness. If the size of the
general population is large and the risk to them low, the
average cost-effectiveness of control will be poor regardless
of the risk to the maximum exposed individual. In addition, a
single meaningful cost-effectiveness value for the MEI is
impossible to calculate without an estimate of the size of the
affected population. Instead, Table 2-11 presents the total
annualized cost of control alongside the risk reduction to
the MEI. Together, these variables offer qualitative insight
into the relative merits of the various controls.
An interesting footnote to this table is that controls
for chrome platers similar to those analyzed in this study
are currently being mandated by the ARE. The annualized cost
of control for a packed bed scrubber (which would meet the
new requirement) on the hard chrome plater ($15,000) is equal
to the median of the control costs estimated for the other
sources. The estimated reduction in risk to the MEI achieved
by this mandated control (11 chances in a million), is similarly
close to the median risk reduction of the other controls examined
(9.5 chances in a million).
One possible MEI risk management approach is reducing the
risk of all individuals to a level below a given risk threshold.
For instance, if the threshold triggering control action was
established at 100 chances in a million (10~4), then hospital
sterilizers should be primary targets of control, since they
are the only sources that present higher risks. (Stage I
also estimated MEI risks from automobile emissions of benzene
at greater than 10~4. MEI risk reduction estimates were not
performed in Stage II because our mobile source analysis was
limited largely to information in the State Benzene Control
Plan.)
If a higher threshold was chosen, say 10~5, then control
of the other sources listed should be considered. Of the con-
trols considered, it is difficult to pinpoint the most attrac-
tive. Dry cleaning, hard chrome plating, and methylene
chloride degreasing controls reduce MEI risk by similar
amounts: on the order of ten chances in a million. If regula-
tory resources were limited, the source that affected the
largest population might be chosen first. In this case, one
might assume that there are more dry cleaners and that they
are closer to dense residential areas, and thus that they
expose a greater number of people to concentrations near the
MEI case. Alternatively, source prioritization might be
performed based on cost-effectiveness of reducing risk to the
highly exposed population. Table 2-11 shows that annualized
costs for dry cleaning and hard chrome plating controls are
greater than methylene chloride degreasing for similar risk
reductions. Thus, controlling methylene chloride would
-------
SUMMARY OF MEI ANALYSIS9
Source Type Control Method
Dry Cleaning
Decorative
Chrome
Plating
Hard Chrcme
Plating
Degreas ing
Converting perc
transfer to perc
dry-to-dry
Converting perc
transfer to CFC-113
dry-to-dry
Converting perc
dry-to-dry to
CFC-113 dry-to-dry
Polypropylene
Balls
Packed Bed
Scrubber
Refrigerated
Freeboard
Chillers
Pollutant
(Weight of
Evidence of
Carcinogenicty ) b
Pe rchloroethy lene
(B2)
Pe rch loroethy lene
(B2)
Pe rchloroethy lene
(B2)
Hexavalent
chromium (A)
Hexavlent
chromium (A)
1,1, 1-Trichloro-
ethane (D)
Methylene chloride
Emission
Reduction
(Ib/yr)
16,000
20,000
20,000
1.5
33
28,000
4,800
Annual izedc
Cost of
Control
(dollars)
15,000
34,000
9,800
240
15,000
18,000
2,800
Estimated
Baseline
Riskd
(Chances in
a million)
12
12
2
1.4
11
e
30
Estimated
Risk after
Controld
(Chances in
a million)
2
0
0
0.6
0.1
e
21
Estimated
Risk
Reduction
(Chances i
a million)
10
12
2
1
11
e
9
Hospital Wet Scrubbers
Sterilization
(B2)
Ethylene Oxide (Bl) 1,700 36,000
200
32
168
NJ
I
Ul
-------
2-46
Table 2-11 (Continued)
SUMMARY OF MEI ANALYSISa
a MEI = Maximum exposed individual.
b The weight of evidence of carcinogenicity for the compounds
included in the analysis varies greatly, from very limited
to very substantial. According to EPA's categorization of
levels of evidence of carcinogenicity, A = proven human
carcinogen; Bl = probable human carcinogen (limited human
evidence); B2 = probable human carcinogen (insufficient
human evidence but sufficient animal evidence; C = possible
human carcinogen; D = not classifiable.
c Annualized cost = annal operating costs plus capital recovery,
d Because of significant uncertainties in the underlying data
and assumptions, these estimates of individual risk are only
rough approximations of actual risk. They are based on
conservative estimates of exposure and potency and are more
likely to overestimate risks than to underestimate them.
e 1,1,1-Trichloroethane is not considered carcinogenic by the
EPA or the ARB at this time.
-------
2-47
appear to be more cost-effective. To obtain a more accurate
estimate of cost-effectiveness, estimation of the size of the
exposed population would be needed.
Interpretation of Cost and Risk Estimates of Direct
Control.
There is considerable uncertainty in the raw data and
the methodology used to produce the cost and risk reduction
estimates in this report. One of the most significant uncertain-
ties is the linearized multistage procedure used to calculate
risk. According to EPA's Cancer Assessment Group (CAG), the
actual risks faced at the modelled exposure levels are likely
to be no higher than those used in the calculations and may be
as low as zero. However, this conservative approach is standard
EPA procedure in protecting public health.
Use of "best-guess" estimates of cancer potency would
result in estimates of current risks and risk reductions lower
than the "reasonable upper bound" estimates assumed. Lower
risk reductions would, in turn, result in a greater expense per
reduced incidence and less cost-effectiveness. Other assumptions
in the analysis were likely to have the opposite effect. For
instance, benefits of reducing toxic air emissions besides
cancer risk reduction were not accounted for. Toxic emissions
might result in crop damage, materials damage, and adverse
health affects similar to those documented for criteria pollu-
tants. If these were included in the calculations, they would
increase the overall damage and risk reduction and make the
controls appear more cost-effective. Finally, dispersion
modelling, data collection, and cost estimation all may have
biased the cost-effectiveness calculation.
While the limitations and uncertainties of the analysis
should not be ignored, the study results are useful for comparing
various control strategies. However, given the constraints of
this study, the results do not justify immediate regulatory
action. Before decisions are made, more in-depth data collection
and control evaluation should be performed, such as that underway
in the Tanner process.
The analysis performed for this project is based on com-
monly used methods and the best available data, and the results
present valuable information including estimates of the effective
ness of controlling air toxics in Santa Clara County useful in
priority setting. The study does not claim that the 'actual1
cost-effectiveness of hospital sterilizers is precisely $3.1
million per reduced incidence. But it does suggest further
examination of this control should come before examination of
refrigerated freeboard chillers for perchloroethylene degreasing
($36 million/reduced incidence).
-------
2-48
Land-Use Controls
Table 2-12 summarizes the results of the land-use control
analysis that explored the relationship between excess individual
cancer risk and the distance between source and receptor.
Information such as this is presently used by the BAAQMD in
permitting new facilities. It could also be used by planning
agencies in deciding how close to allow housing units to be built
to existing pollution sources. A specific target level accept-
able risk could be chosen, and buffer zones established that
would allow distance sufficient to meet that level. Of course,
the costs and feasibility of such buffer zones would also need
to be weighed. Where it appears to be an attractive control
strategy, site specific information would be desirable.
While most of the controls discussed in this section are
under the regulatory authority of regional or state agencies,
the information developed in this portion of the analysis could
be put to direct use by local authorities, through the planning
and zoning processes.
Conclusions
As previously stated, the major analytic goal of this study
was to examine costs and effectiveness of controls for a range
of air toxic sources to help prioritize regulatory activity.
Taking account of current regulatory efforts, this general goal
was broken into three more specific study objectives which are
revisited below:
Determine whether the lEMP's broad-brush examination of
current air toxics risk management activity can suggest a
reorganization of local air pollution priorities.
The results do not suggest a major reorganization of local
air pollution priorities. While studies like this one may
suggest significant regulatory changes in other communities or
states, it appears as though most of Santa Clara Valley's
relatively well understood chronic air pollution problems are
being addressed by the BAAQMD and the ARE.
Certainly, more rigorous study is possible. Of the sources
considered, greater emphasis might be placed on ethylene oxide
sterilizers (particularly if MEI protection is considered a
primary objective) and on residential wood combustion. These and
other possible actions are discussed below.
Provide recommendations to the State Tanner process (ARE
and BAAQMD) based on local priorities and perspectives.
Recommendations could include input on the cost and
-------
2-49
Table 2-12
EXCESS CANCER RISK AS A FUNCTION OF DISTANCE
DOWNWIND FROM THE
Source
(Weight of evidence Emissions
of carcinogenicity )b (kg/yr)
Perchloroethylene Degreasing (B2)
small facility 3,000
medium facility 6,000
large facility 12,000
Trichloroethylene Degreasing (B2)
small facility 3,000
medium facility 6,000
large facility 12,000
Methylene Chloride Degreasing (B2)
small facility 3,000
medium facility 6,000
large facility 12,000
Ethylene Oxide Sterilization (Bl)
small facility 50
medium facility 200
large facility 400
Perchloroethylene Dry Cleaning (B2)
small facility 1,000
medium facility 12,000
large facility 25,000
Chrome Plating (A)
small facility 1
medium facility 5
large facility 10
Gasoline Station (B2)
small facility 2
medium facility 4
large facility 8
SOURCE
Distance
Estimated
10-5
220
340
200
370
560
510
800
1,210
290
710
1,050
340
510
500
1,400
2,175 >]
_
from Source at
Risk
10-6
550
850
1,380
1,020
1,650
2,520
2,200
3,500
5,590
1,270
3,100
4,820
270
1,380
2,190
2,180
6,400
L0,000
-
Level (m)a
10-7
2,400
3,850
6,200
4,700
7,600
>10,000
>10,000
>10,000
>10,000
5, 600
>10,000
>10,000
1,200
6,200
>10,000
>10,000
>10,000
>10,000
100
200
400
-------
2-50
Table 2-12 (Continued)
EXCESS CANCER RISK AS A FUNCTION OF DOWNWIND
~~ DISTANCE FROM THE SOURCE
Source
(Weight of Evidence Emissions
of Carcinoqenicity)h (kg/yr)
Distance from Source at
Estimated Risk Level (m)a
10
-5
10
-6
10
-7
Bulk Gasoline Storage (B2)
small facility 1,000
medium facility 2,500
large facility 5,000
200
700
1,100
1,700
3,000
4,800
7,700
>10,000
>10,000
Because of significant uncertainties in the underlying data
and assumptions, estimates of individual risk and desease
incidence are only rough approximations. They are based on
conservative estimates of exposure and potency, and are more
likely to overestimate risks than to underestimate them.
This data presents excess cancer risk as a function of
distance for a hypothetically, maximally exposed individual.
Maximum risk values at incremental distances from each source
were used to generate the values presented here.
The weight of evidence of carcinogenicity for the compounds
included in the analysis varies. According to EPA's categor-
ization of levels of evidence of carcinogenicity, A = proven
human carcinogen; Bl = probable human carcinogen (limited
human evidence); B2 = probable human carcinogen (insufficient
human evidence but sufficient animal evidence).
-------
2-51
effectiveness of air toxics emissions controls being
considered under Tanner.
Benzene and hexavalent chromium are far along in the Tanner
process and the IEMP study will probably add little to the
decision making process. Ethylene oxide, methylene chloride,
perchloroethylene, and trichloroethylene are in the review process
and control information presented in the report might provide
useful first cut estimations of cost, risk, and risk reduction.
PAHs are not yet under review and the results of this study
might encourage greater attention to this set of compounds.
Provide recommendations to regional and local agencies
(BAAQMD, Board of Supervisors, planning bodies, etc.)
on the need and approach for controlling sources not
included in the Tanner process, based on local priorities
and perspectives.
o Again, organic particulates may eventually be examined
under Tanner, but no date as been set to begin consider-
ation of these emissions from residential wood combustion,
automobiles, and other sources. Information from the
controllability study could encourage direct local
action on the issue, or a recommendation that the the
ARE hasten their consideration of these compounds.
o Glycol ethers are not considered under Tanner because
semiconductor production is not wide-spread throughout
the State. Control information generated in the report
may be useful to the BAAQMD in considering controls for
this source. Better toxicologic information is desirable,
however, before regulatory decisions are made.
o The land-use planning methodology presented could be
useful for local agencies responsible for city and
general planning.
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2-52
ACTION PLAN
The controllability study was conducted in two parts.
First, hundreds of toxic air contaminant sources were screened
down to a handful of source categories based on risk, feasibility
of control, data availability, and ongoing regulatory efforts.
Second, the nine sources selected through the screening exercise
were examined for cost-effectiveness. The control strategies
examined vary by source, but can be broken into three categories:
land-use controls, hardware controls, and raw material substitu-
tion. Based on the information generated in the study and on
expertise of individual members, IEMP participants made the seven
recommendations listed below.
Planning/Land Use
1) Local planning agencies should evaluate the establishment
of buffer zones as a strategy for reducing exposure to toxic
air contaminants. Chapter 7 of the controllability study
report (land-use controls) and an explanation of the utility
of the graphs of risk versus buffer zone size should be
forwarded to the agencies in charge of the city and County
general plans. To provide some guide for the use of these
risk estimates, this summary should include an explanation of
risk management guidelines used in EPA national programs.
Specifically, sources presenting lifetime risk of excess
cancer to the maximum exposed individual (MEI) of greater than
100 chances in a million (10~4) are controlled where practical.
Sources presenting risks of 100 to 0.1 chances in a million
(10~4 to 10~7) are considered for control, with cost and other
factors weighed against risk. Risks below 0.1 chances in a
million (10~7) are a lower priority for control.
Hardware Controls & Raw Material Substitution;
2) Control of emissions from EtO sterilizers should remain
a high priority. EtO is scheduled for review as a toxic air
contaminant by the ARE. However, control of the largest
source of EtO emissions (sterilizers) is currently the respons-
ibility of the Department of Food and Agriculture. Stage I
estimated that EtO from hospital sterilizers may present one
of the largest airborne toxic risks in the County (albeit to
a small number of highly exposed individuals), and the control-
lability study demonstrated that existing controls are rela-
tively cost effective (although the IEMP noted that control
of air emissions may result in waterborne contamination).
Therefore, controls should not be delayed.
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Despite the pesticidal use of ethylene oxide by hospitals
and other sources, the IEMP recommends that the ARE investi-
gate sterilizer controls and encourages the air districts to
implement control regulations based on ARB's research. In
addition, the IEMP recommends that the ARB be assigned respons-
ibility by the California legislature for controlling EtO
sterilizers under the Tanner process.
3) The results of the controllability study should be for-
warded to the ARB and the cost effectiveness of methylene
chloride refrigerated freeboard chillers and EtO sterilizer
wet scrubbers should be highlighted. In evaluating compounds
as toxic air contaminants, the ARB performs controllability
analyses similar in form, but more thorough in practice, to
those conducted in this project. However, in selecting
pollutants, sources, and controls for ARB's early in-depth
study, decisions must be based on limited information.
Results generated in the IEMP should be used as an input to
those decisions and highlight methylene chloride refrigerated
freeboard chillers and EtO sterilizer scrubbers as controls
worthy of in-depth study.
4) BAAQMD should initiate rulemaking on the cost-effective
measures identified in the controllability study, including
methylene chloride refrigerated freeboard chillers and EtO
sterilizer wet scrubbers. Because many of these sources are
present in the district, and controls have been identified as
not only available but also cost-effective measures for
reducing health risks, the BAAOMD should develop stationary
source control rules for these sources.
5) As a part of its overall air toxics inventory, BAAQMD
should improve its data base on emissions (including glycol
ether emissions) from industries concentrated in Santa Clara
County. Attention to the toxic emissions of these facilities
is appropriate because (1) processes (and thus emissions)
from high-tech industries change at a rapid pace; (2) State
priorities may not address these chemicals and processes
because semiconductor and high-tech facilities are not as
predominant statewide as they are in Santa Clara County; (3)
the public continues to be concerned about possible health
risks from these sources; and (4) uncertainty exists as to
ambient exposure levels and toxicity of many of these chemicals,
The BAAQMD can usefully target effort at assessing risks from
chemicals and processes that are gaps or low priorities for
the ARB.
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Health Effects Research
6) Further research leading to phasing out the use of toxic
glycol ethers should be performed by ARE, AQMD, EPA, and
private industry. Research should include efforts to find
alternative chemicals and processes that allow reduced glycol
ether use and emissions, and thus reduced glycol ether
associated risk.
7) EPA should present its best comprehensive assessment
of the health affects of TCA. TCA (1,1,1-trichloroethane) is
of concern because of its wide-spread emissions in the County.
EPA's current position is that insufficient evidence exists
to identify TCA as a possible or probable human carcinogen,
teratogen, or reproductive toxin. Ambient environmental
levels in air and water are below estimated thresholds for
other toxic effects. However, toxicologic work on TCA has
been ongoing, and concern in the community still exists.
Therefore, the IEMP committees requests that an updated assess-
ment of cancer and non-cancer health affects and research be
provided.
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OTHER SUBCOMMITTEE ACTION
Action Plan Issues Based on Multiple Studies
In addition to the recommendations that are based on one
of the three studies, the air action plan contains three
recommendations that emerged out of several of the studies.
1) EPA, ARE, BAAQMD, and local planning bodies should
increase attention to residential wood combustion (RWC)
controls. The BaP monitoring effort confirms the Stage I
result which tentatively identified PAHs as one of the larger
known categories of airborne toxic risk in the Valley.
Although the contribution of wood stoves to total PAH emissions
may be small, controlling their PAH emissions is the most
cost effective strategy examined in the controllability
study. EPA's New Source Performance Standards (NSPS) for wood
stoves will limit emissions from new stoves, but state and
local agencies can direct efforts at existing stoves. Specific
suggestions are as follows:
a. BAAQMD's plans to produce an area source inventory
of PAHs by June, 1988 should be encouraged.
b. The ARB should consider stove controls in developing
suggested control measures for compliance with the
State and federal PM-10 standards.
c. The County and cities should work with the BAAQMD to
generate performance requirements (or other control
mechanisms) for wood stoves that would be implemented
upon property transfer or during major remodelling.
Economic incentives should also be considered.
Follow up on this topic might be an appropriate
activity for the Toxics Policy Council being recom-
mended by the IEMP Institutional Subcommittee.
d. Innovative ways to address fireplace emissions should
be pursued.
2) Local agencies, the BAAQMD, and the ARB should emphasize
public education efforts. Where pertinent, these education
programs should emphasize the economic benefits accrued to the
source owner. For example, efficient wood stoves not only
pollute less, but they require less wood, thus decreasing
fuel costs. This might be another activity appropriate for
the proposed Toxics Policy Council (see Chapter 4, institu-
tional issues). Public education has been identified as a
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high-priority activity for this group. Two specific education
targets are as follows:
a. The effects of residential wood combustion emissions
on air quality could be better publicized. In parallel,
voluntary stove owner control activity should be
explained. Specifically, the BAAQMD could make avail-
able a pamphlet explaining proper stove operation, as
well as the effects on emissions of burning curtailments
and replacement of inefficient stoves.
b. BAAQMD's new pamphlet on voluntary pollution control
action could be widely publicized. These actions
include the following (What Can You Do To Help Clean
The Air?, BAAQMD pamphlet, 1987).
- Educate yourself about air pollution and its control.
- Communicate your concern to your family, friends,
and government representatives.
- Keep informed about emerging environmental issues.
- Reduce your driving. Carpool or use public tran-
sportation. On smoggy days combine or postpone
trips as much as possible. Check "Smog Phone" for
daily air pollution levels: (415) 673-SMOG.
- Keep your car in good shape. Get a tune-up, as
needed, to keep it running well. Do not remove
catalytic converters or other emission control
equipment.
- Don't "top-off" your tank at self-service gasoline
stations.
- Support transit funding and bus/carpool facilities.
- Don't throw color print, plastic, or other trash
in a fireplace or wood stove.
- Don't use fireplaces or wood stoves on days when
levels of "smog" or carbon monoxide are high or
predicted to be high. Burn only dry clean wood
and have an adequate air supply to the combusion
chamber. Use of a catalytic combustor vastly
reduces air pollution emissions.
- Don't burn trash, garden prunings, leaves, or
grass cuttings in your backyard.
- Avoid activities that use internal combustion
engines whenever it is smoggy; e.g.: lawnmowers,
pleasure boats, and pleasure driving.
- Avoid the use of consumer products in aerosol form.
- Support legislation for strong pollution control
measures.
- Recycle.
- Report industrial pollution and backyard burning
to the District's toll free number: (800) 792-0836.
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3) The County and Cities should institute non-smoking
ordinances. Both smokers and non-smokers are exposed to
carbon monoxide and particulates from cigarette smoke. While
ambient environmental pollution levels are not expected to be
significantly effected by this source, indoor pollution
levels may be.
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Issues Not Addressed by the IEMP
IEMP participants identified seven issues that are insuf-
ficiently addressed by the present mix of regulatory agencies
and research projects. Several of these issues address types
of toxic exposure outside the scope of the IEMP, which focused
mainly on chronic exposures to toxic chemicals in the air and
water. The committees believed that further work in these
areas should be encouraged.
1) Occupational exposures. Specifically, the IEMP supports
additional study of the health effects of occupational exposures
to toxic chemicals in Santa Clara County and opposes a reduction
in funding for Cal-OSHA. The IEMP recommends that the proposed
Toxics Policy Council and the Inter-Governmental Council (IGC)
pursue the recommendations made in the IEMP Occupational
Exposure Study.
2) Cumulative exposures. The IEMP supports research on the
effects of exposure to multiple pollutants including synergistic,
antagonistic, and additive effects. Examples of the first are
people who smoke cigarettes and are exposed to asbestos.
Epidemiologic studies suggest that these people face far higher
risks of lung cancer than would be expected by simply summing
the risks of the individual hazards.
3) Indoor air pollution. The degree to which indoor air
pollution represents a public hazard has not been well
established. However, most people spend more time indoors
than outdoors, and various pollutant concentrations are
greater inside than out. Of particular concern are tobacco
smoke and radon. As a result of AB-3052, indoor air exposure
will be assessed under the Tanner process.
4) Noninhalation pathways. Air pollution, especially
particulate matter, deposits on the ground and water and
results in exposure via noninhalation pathways. For example,
exposure occurs by ingestion of the following:
- crops contaminated by surface-deposition;
- milk, meat, and eggs from animals grazing on contaminated
crops;
- surface water, groundwater, and fish contaminated by
pollutants deposited in surface water;
- mother's milk;
- soil containing deposited pollutants.
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5) Assessment and enforcement of regulations of hazardous
materials transport. California Highway Patrol enforces
regulations governing the transport of hazardous materials on
California highways. Typical violations of these regulations
involve improper shipping papers and chemical labeling.
The level of enforcement of these regulations would be a
potential target for improvement.
6) Periodic assessment of ambient monitoring for toxic air
contaminants. BAAQMD currently monitors for 10 volatile organic
compounds and 8 metals at 15 sites within the Bay area. IEMP
participants recommend periodic assessment of this monitoring
program (including the materials monitored, the analytic metho-
dologies, and the adequacy of the sites) to assure that regula-
tions are based on a reliable and comprehensive database.
7) Local officials should stay abreast of work being con-
ducted on episodic releases under AB-1021 and via the revi-
sions to the Uniform Fire Code. Episodic releases (accidental
releases that may have acutely toxic effects) have been an
ongoing concern of the IEMP. Original research was not con-
ducted on the topic because of time and resource constraints
and because significant work was being conducted by the Santa
Clara County Fire Chiefs' Association under AB-1021 and by the
Western Fire Chiefs' Association in their revisions to the
Uniform Fire Code. Local officals should continue to follow
and influence this work, and consider adoption of the model
regulations when they are completed.
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BIBILIOGRAPHY
Energy and Resource Consultants, Santa Clara Criteria Air Pollutant
Benefit Analysis, Office of Policy Analysis, US EPA, Final Report,^
May 20, 1987.
Flessel Peter; Wang, Yi; Kim, In-Suk, Sampling and Analysis of
Polycyclic Aromatic Hydrocarbons in Santa Clara Valley, California
Department of Health Services & California Public Health Foundation
Draft, June 26, 1987.
Radian Corporation, Air Toxics Controllability Analysis, Volume
I, Office of Policy Analysis, US EPA, Final Report, May 27, 1987.
Radian Corporation, Air Toxics Controllability Analysis, Volume
II, Office of Policy Analysis, US EPA, Final Report, May 29, 1987.
Hinman, Keith; Schwartz, Don; Soffer, Eileen, Santa Clara Valley
Integrated Environmental Management Project; Revised Stage One
Report, Office of Policy Analysis, US EPA, May 30, 1986.
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CHAPTER THREE
DRINKING WATER ISSUES
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TABLE OF CONTENTS
INTRODUCTION 3-1
Subcommittee Objective 3-6
Stage II Drinking Water Workplan 3-7
EFFECTIVENESS OF HAZARDOUS MATERIALS ORDINANCES 3-10
Summary of Analysis 3-10
Objective of Study 3-10
Methodology 3-12
Conclusions 3-13
HMSO Action Plan 3-16
PROTECTION OF PRIVATE WELLS 3-22
Summary of Analysis 3-22
Objective of Study 3-22
Methodolgy 3-25
Conclusions 3-32
Private Wells Action Plan 3-33
AQUIFER MANAGEMENT 3-37
SANTA CLARA VALLEY WATER DISTRICT AQUIFER
MANAGEMENT STUDY 3-37
Summary of Analysis 3-37
Objective 3-37
Methodolgy 3-38
Conclus ions 3-43
EPA AQUIFER MANAGEMENT STUDY 3-44
Summary of Analysis 3-44
Objective 3-44
Methodolgy 3-48
Results of Analys is 3-57
Conclusions 3-73
Aquifer Management Action Plan 3-74
REDUCTION OF THMS IN DRINKING WATER 3-82
Summary of Analysis 3-82
Background 3-82
Current THM Reduction Activities 3-88
THM Action Plan 3-92
ADDITIONAL ISSUES OF CONCERN 3-93
BIBLIOGRAPHY 3-95
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3-1
CHAPTER THREE:
DRINKING WATER ISSUES
INTRODUCTION
This chapter discusses the drinking water issues addressed
in Stage Two of the IEMP. First, the formation of a drinking
water subcommittee and a workplan to target priority issues are
described. Then, work on each priority issue, including the
results of research conducted and actions recommended by the
IEMP participants is discussed in turn. Finally, a list of
issues outside the scope of the IEMP Stage Two effort, but
identified by the IEMP as deserving of attention from
environmental managers, is presented.
Background
Toxic contamination of drinking water and groundwater has
been a subject of widespread and often passionate concern in
Santa Clara Valley since the 1981 discovery that a leaking
solvent storage tank at Fairchild Camera and Instrument had
contaminated underground supplies of drinking water. The
existence of some forms of contamination, such as nitrates
from agricultural practices and naturally occurring inorganic
chemicals, have been known for a number of years. However, the
discovery of contamination of Fairchild, and subsequently
of other solvent and fuel storage sites, dramatized the
increasing vulnerability of high-quality local groundwater
to the rapid residential and industrial growth of the last
few decades.
Surface water sources of drinking water are also exposed
to contamination of various types. Imported surface water,
which supplies half of local drinking water needs, can be
contaminated by pathogenic organisms, runoff containing
pesticides, and other sources. Disinfection of imported
surface water to protect against disease produces by-
products that pose a risk of cancer.
Increased concern about drinking water contamination in
recent years has resulted in the initiation of a number of
programs and activities to reduce the threat of contamination
and exposure. These programs include hazardous materials
ordinances, contaminant site identification and clean up
efforts, increased monitoring at drinking water wells, and
trihalomethane reduction efforts, to name just a few.
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3-2
One of the important objectives of the lEMP's Stage One
analysis of toxic health risks was to assist in setting program
priorities by comparing these various types of drinking water
contamination to each other and to other environmental exposures,
such as toxicants found in the air. The Revised Stage One
Report concluded that, overall, exposure to toxics through
drinking water appeared to be slightly less significant than
that in air. Among the drinking water contaminants, exposure
to disinfection byproducts (such as chloroform) in imported
surface water accounted for the largest estimated cancer risk
in the general population.
Groundwater risks were, in general, judged to be much
smaller than risks from surface water, because of natural
hydrogeologic protection and a set of preventive, clean up and
drinking water use regulations and activities. However,
individuals drinking from unregulated private wells were
projected to be potentially at much greater than average risk
from a variety of contamination sources. Finally, the Stage
One analysis pointed out that, while people can be fairly
effectively protected from exposure to contaminants in ground-
water, such contamination nevertheless appears to exact a
significant toll on groundwater resources. (Clean up, for
example, can involve pumping a great deal of water out of the
ground, resulting in aquifer depletion, possible subsidence,
and other problems).
Because of the importance of risk and resource issues
involving drinking water and groundwater, the extent of public
concern about this issue, and the direct local role in
managing water resources, the IEMP decided that Stage Two
should target several important drinking water and groundwater
issues. The IEMP therefore established a subcommittee to
study these issues, and developed a workplan to guide the
subcommittee's activities.
Drinking Water Subcommittee
The Drinking Water Subcommittee was formed late in the
summer of 1986. Subcommittee membership was chosen with
several objectives in mind: technical expertise; representa-
tion of relevant regulatory agencies at both staff and policy-
making level; and representation of an array of interests
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3-3
and groups active in groundwater and drinking water issues.
Members include elected officials and representatives of local
and regional agencies, environmental, industry, and citizens'
groups, and the university community. The breadth of interests
represented was intended to allow the subcommittee to perform
a representational and consensus-building role, in addition
to providing technical expertise.
Members of the subcommittee and the organizations they
represent are presented in Table 3-1. The IEMP would also
like to acknowledge persons who were not formally members of
the subcommittee, but who were nevertheless active participants
in the subcomittee's review and deliberative activities. A
partial list of these individuals is presented in Table 3-1
also. The IEMP would like to express its appreciation of all
participants' generous contribution of time, energy and
expertise.
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IEMP Drinking
Susanne Wilson (Chair)
Dan Kriege (Vice-Chair)
Sharon Albert
Cliff Bowen
Jacqueline Bogard
James Easton
Glenn Hildebrand
Nancy lanni
Roger James
Arthur Jensen
Peter Jones
Pat Kwok
Sara Malaun
Kenneth Manaster
David Morell
June Oberdorfer
3-4
Table 3-1
Water Subcommittee Members
Supervisor.- County of Santa Clara
Manager, Santa Clara Valley Water
District, Operations and
Maintenance
Councilwoman, City of Gilroy
District Engineer, CA Department
of Health Services, Public Water
Supply Branch
Clean Water Task Force/ Santa Clara
County Mftg. Group
Executive Director, CA Water
Resources Board
Environmental Health Specialist,
Santa Clara Environmental
Health Services, Water Program
Councilwoman, City of San Jose
Executive Director, San Francisco
Bay Regional Water Quality
Control Board
Deputy General Mgr., San Francisco
Water Department
Program Manager, San Jose Fire
Department Hazardous Materials
Program
Principal Sanitary Engineer,
San Jose Dept. of Water Pollution
Control
League of Women Voters
Professor, Santa Clara University
School of Law
Special Assistant to the Executive,
County of Santa Clara
Professor of Geology, San Jose
State University
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Table 3-1 Continued:
Ted Smith
Peter Snyder
Chuck Wilhelm
Kirk Willard
Scott Yoo
Executive Director, Silicon Valley
Toxics Coalition
Member, San Francisco Bay
Regional Water Quality Control
Board
Director, Office of Environmental
Mgmt., City of San Jose
Chief, Lockheed Missiles and
Space Company Environmental
Compliance Program
Water Quality Mgr.,
Water Company
San Jose
The Subcommittee would also like to acknowledge and express its
gratitude to the dedicated non-members who made significant
contributions to the work of the Subcommittee: Bob Brownstein,
assistant to Supervisor Wilson; Dave Chesterman, Santa Clara
Valley Water District; Les DeBaun, Bay Area League of Industrial
Associations; Lee Esquibel, Santa Clara County Health Dept.;
Mike Kent, Citizens for a Better Environment; and Gary Lynch,
San Jose Office of Environmental Management.
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Subcommittee Objective
In September 1986, the subcommittee adopted the following
objective statement:
Develop a valley-wide water management strategy which
protects public health; which preserves and utilizes existing
water resources, both surface and ground water, in a cost
effective manner; and which protects the quality of all waters
by cleaning up existing pollution and preventing future water
pollution in the Santa Clara Valley.
Elements of the Objective:
1) Review existing data on private wells and develop
alternative private well management options.
2) Evaluate the effectiveness of the Hazardous Materials
Storage Ordinances and recommend options for improvements.
3) Analyze and develop an aquifer management strategy that
will:
a) evaluate the technical, management, economic, and
policy relationships between surface and groundwater
quality and quantity.
b) Develop a methodology for evaluating policy alternatives.
c) Assess the health impacts, resource impacts, and
costs of clean up alternatives.
d) Assess the health impacts, resource impacts, and
costs of well head treatment.
4) Assess the feasibility of adopting a valley-wide
decision-making process for setting clean up priorities
and standards.
Subcommittee Activities
During Stage Two, the subcommittee provided technical
and policy input to EPA on analytic studies; and, upon the
conclusion of those analytic studies, developed recommenda-
tions on actions needed in each area.
Following its objective statement, the subcommittee
adopted the Stage Two Drinking Water Workplan targeting selected
priority issues to be addressed during Stage II. The sub-
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3-7
committee played an active role in reviewing the studies
identified in this workplan in various stages of completion.
Several subcommittee members played key roles in producing
these studies.
The subcommittee was also charged with developing recom-
mendations on necessary actions in the priority areas studied.
The subcommittee proved a generally effective forum for
developing consensus among the diverse groups represented.
Subcommittee recommendations were formalized in the Drinking
Water Subcommittee Action Plan. These recommendations are
presented at the end of each of the sections in this chapter
discussing a discrete Stage Two project.
Stage Two Drinking Water Workplan
In contrast to the workplan for air issues in Stage Two,
the IEMP decided that its efforts to address drinking water
issues would be more effective if directed at key policy
and management issues than they would be if oriented toward
further risk assessment or basic data collection. There are
two reasons for this emphasis. First, a great deal of ground-
water and drinking water data are being collected through
drinking water quality, clean-up and hazardous materials,
contamination prevention programs; the IEMP, with its limited
resources and time, could add little to this body of informa-
tion. Second, to a greater degree than in air, programs
affecting groundwater and drinking water quality (e.g.,
hazardous materials storage regulation by cities, water
management and treatment by the Santa Clara Valley Water
District) are under the direct control or strong influence of
local authorities.
Programs to prevent health risk from and prevent contamin-
ation of groundwater and drinking water include a wide range
of activities:
(1) programs to prevent contamination from occurring;
(2) programs to clean up or limit the spread of
contamination;
(3) programs to protect individuals from exposure
to contaminated water; and
(4) cross-cutting and overall management programs.
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The projects in the Stage Two Drinking Water Workplan,
listed below, attempt to address key issues in each of these
areas.
Effectiveness of Hazardous Materials Storage Ordinances.
Local "hazmat" programs were developed as a regulatory response
to the discovery of groundwater contamination at Fairchild
and other sites using hazardous materials. Local ordinances,
developed in advance of state and Federal programs to regulate
underground tanks and other storage facilities, are the
lynchpin of contamination prevention activities in the Santa
Clara Valley- The IEMP study evaluated the programs' successes
and problems so far (they have only been in place a few years),
and developed recommendations for improvement.
Protection of Private Wells. For a variety of reasons,
individuals drinking from private wells are potentially at
significantly higher-than-average risk of exposure to contam-
inants. This study analyzed options and presented recommenda-
tions on protecting this high-risk group from exposure to
contaminants.
Aquifer Management. This project involved two complemen-
tary studies, under the direction of the Santa Clara Valley
Water District (SCVWD) and EPA respectively, that examined
mechanisms for improved overall management of groundwater
resources and drinking water supply:
o SCVWD Groundwater Management Study. This study
examined groundwater management activities, which have
been complicated by recently increased concerns about
groundwater quality, and made recommendations for
improvement.
o EPA Aquifer Management Study. This study attempted
to develop a common framework and set of objectives
to link the activities of the many agencies involved
in groundwater/drinking water management. A key
policy question facing the Santa Clara Valley - the
selection of clean up levels for contaminated ground-
water sites - was examined using the approach developed
in the study.
Trihalomethane (THM) Reduction. As an outgrowth of the Stage
I risk estimates and in anticipation of more stringent Federal
requirements, the SCVWD is examining alternative disinfection
methods that would reduce THM formation. This report summarizes
the SCVWD work, as well as relevant activities by the San
Francisco Water Department (SFWD) and EPA.
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Outline of Chapter
The remainder of the chapter discusses subcommittee activi-
ties on each priority drinking water issue targeted in
Stage Two:
o Effectiveness of Hazardous Materials Ordinances;
o Protection of Private Wells;
o Aquifer Management; and
o Trihalomethane Reduction.
In each issue area, the report presents a description of
analysis or research, a discussion of results and a set of
subcommittee recommendations. Following the discussion of
the above issues, the report presents a list of:
o Additional Issues Deserving Attention.
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3-10
EFFECTIVENESS OF HAZARDOUS MATERIALS STORAGE ORDINANCES
SUMMARY OF ANALYSIS
Objective Of Study
The IEMP Stage I analysis indicated that the Hazardous
Materials Storage Ordinances (HMSOs) in effect in Santa Clara
County are likely to significantly reduce future risk from ground-
water contamination. The relatively low aggregate risks from
consumption of groundwater that were estimated in Stage I were
partially attributable to assumptions that the HMSOs will be
implemented and managed effectively. These assumptions were of
concern to the local community since, at the time of the Stage I
analysis, policymakers had little information on how well the
ordinances were actually being implemented in each jurisdiction.
Because these programs are the centerpiece of efforts to prevent
groundwater contamination, EPA decided to examine the effective-
ness of the HMSO implementation as part of its Stage II analysis.
The purpose of the study, therefore, was to document the
nature of the ordinances and their implementation, to determine
their effectiveness in identifying and eliminating environmental
and public safety hazards, and to make recommendations regarding
organizational or regulatory changes that could result in addi-
tional benefits, particularly with respect to making the regula-
tory programs more efficient and more effective.
At the same time, the study results can be used in the
development of similar programs in other locations or at other
levels of government. The Hazardous Materials Storage Ordinances
have been in effect for over two years in many of the cities in
Santa Clara County. These cities were among the first in the
country to adopt such comprehensive local ordinances for hazard-
ous materials regulation. As a result, Santa Clara County has
accumulated significant experience with the implementation of
such ordinances. More recently various state laws have mandated
several elements of these ordinances for the entire State of
California. In one form or another, it appears that federal
regulations will also result in many similar new requirements
for registration and monitoring, as well as more stringent
construction and design requirements to ensure the containment
of hazardous materials. These other programs can benefit from
the experience in Santa Clara County that the study documents
and analyzes.
Background
In December of 1981, an underground tank was discovered to be
leaking at an industrial site in South San Jose. An estimated
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43,000 gallons of 1,1,1-trichloroethane (TCA) had leaked, and
that chemical was found to have contaminated a drinking water
supply well downgradient of the site. The duration of the leak
was not determined, but it appeared that the residents of that
area had been exposed to TCA in their drinking water for a
period of several months, or possibly several years. The
residents were justifiably alarmed. They attended meetings of
the City Council and the County Supervisors to express their
concern and ask what regulatory mechanism had failed to prevent
this leak and to prevent the detection of contamination in the
well. They discovered that the underground storage of non-waste
industrial chemicals was essentially unregulated. Individual
residents, along with organized groups including the Santa Clara
Center for Occupational Safety and Health (and later, the
Silicon Valley Toxics Coalition) demanded a range of actions
from local (and state) officials in response to this incident.
They insisted that steps be taken to provide for the regulation
of underground chemical storage, to assure that similar accidents
did not occur in the future.
The news media provided a significant amount of coverage
to this incident and to the citizens' response. The general
population became concerned about this issue, particularly in
the South Bay where half the population derives its water
supply from groundwater sources. As other companies with
underground tanks carried out precautionary checks of their
facilities, additional leaks and groundwater contamination
sites were detected. The initial leak was no longer perceived
as an isolated incident.
The unfolding discovery of fairly widespread groundwater
contamination incidents led to an overwhelming public sentiment
that new regulation was necessary to ensure adeguate and informed
response to chemical emergencies, to protect the environment
(groundwater and air) from undetected low level releases, and for
somewhat less well-defined objectives such as "control of
hazardous materials" and "community right-to-know."
In response, in February of 1982, the Santa Clara County
Fire Chief's Association made the first documented decision to
initiate the development process that eventually resulted in
the "Santa Clara County Model Hazardous Materials Storage
Ordinance." The Santa Clara County Intergovernmental Council
(IGC), a coordinating body of elected officials from the County
Board of Supervisors, each of the fifteen cities, and several
special districts, endorsed the Model Ordinance in May 1983.
In the following months, nearly all the cities, as well as the
County, adopted HMSOs that were almost identical to the Model
Ordinance. There are currently eleven separate HMSO-based
programs covering all fifteen cities and the unincorporated
areas of the County.
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Methodology
This study of HMSO effectiveness involved the collection
and interpretation of a large amount of information from State
agencies, local ordinance implementing agencies, and from
individuals who were involved in developing the ordinances and
the implementation programs. Numerous personal interviews were
carried out; in addition, written materials were collected and
reviewed whenever they were available in order to obtain detail
and to assess the extent of available documentation.
A major source of information was the the HMSO implementa-
tion questionnaire that was circulated by the Intergovernmental
Council's Environmental Safety Committee. That survey effort
collected most of the written program documentation that was
reviewed for section 5 of this study, as well as some of the
summary data that is discussed in sections 7 and 8.
In addition to providing an assessment of program implementa-
tion for all of Santa Clara County based on the above sources of
information, the study included a detailed review of three imple-
mentation programs. For these three jurisdictions, the study
involved a review of all available forms, guidelines, procedures,
summary reports, etc., as well as a review of approximately 750
representative files on actual facilities. By this method the
study developed a more detailed understanding of the implementa-
tion process than was possible by the general program review.
Based on the information collected in the general program
reviews, the detailed reviews, and on the information available
from the IGC questionnaire, it was possible to draw a number of
conclusions about the effectiveness of the ordinances and their
implementation programs. Some of these conclusions are listed
below. All are described in more detail within the full
contractor report.
Intent of the Model Ordinance
The study began by examining the intentions of those who
developed the Model Ordinance. The intent of the Model Ordinance
development effort was consistently described by program staff
as the provision of local regulation to ensure safe storage of
hazardous chemicals, with emphasis on prevention of releases
from containment. The availability of chemical storage informa-
tion for emergency response personnel, the safety of such
personnel during responses, detection of existing contamination
(already outside of containment), and public access to chemical
storage information (public "right-to-know") were also among the
objectives that were identified (although the model ordinance
that was developed did not address the issue of detection of
pre-existing contamination).
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Conclusions
Permitting of Facilities
Overall, the HMSO programs have been remarkably successful
at identifying and contacting facilities that store hazardous
materials, and in bringing such facilities into the regulatory
process.
Hazardous Materials Management Plans (HMMPS)
The review of HMMPs constitutes a major program activity,
involving a significant fraction of the staff resources in HMSO
implementation. According to the IGC survey, approximately
4,000 facilities in Santa Clara County have submitted HMMPs.
Although this activity has resulted in the collection of signi-
ficant amounts of information at the HMSO program offices, it
appears that the major benefit of the HMMP element is an increase
in safety planning and awareness at the permitted facilities.
There appears to be limited direct utilization of HMMP
information by emergency personnel, by the public, by the city
planning departments, or, in fact, by any persons or agencies
outside of the facility itself.
Inspections
The inspection of facilities represents another major
fraction of the effort involved in HMSO implementation. Vir-
tually all of the 4,000 facilities that have submitted HMMPs
have been inspected, many of these more than once. Most of
these inspections resulted in several required improvements in
the safety of chemical storage. Changes required as a result
of inspection included separation of incompatible chemicals,
proper storage and labeling of chemicals, modification of
emergency equipment and procedures, and improvements to monitor-
i :y systems. Many of these changes were considered significant
in reducing hazards. It appears that significant benefit
results from inspections, including actual required improve-
ments, an increase in awareness, and perhaps additional care
resulting from the knowledge that an inspection may occur.
Although inspections represented a very effective program
element, it appears that their effectiveness could be improved
by more thorough documentation and by better information manage-
ment, after definition of specific information needs.
In general, most or all of the programs divided inspection
responsibilities between dedicated HMSO staff and fire depart-
ment personnel with other responsibilities (prevention and/or
suppression). This arrangement appears to be a reasonable
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3-14
compromise for program efficiency, provided that all inspections
adequately addressed the HMSO program priorities, regardless of
who carries them out.
Coordination With Other City Programs
Interaction with the building department represented one
of the more important enforcement tools available to the HMSO
programs, at least in cities where the HMSO program signoff was
required for construction or modification of permitted facili-
ties. Such a signoff requirement provided a powerful tool that
could work in most, or all, cities but is apparently under-util-
ized by many.
Even in the cities with the most coordination between the
HMSO program and other city programs there is room for consider-
able improvement. For instance, there is currently a lack of
incorporation of HMMP information into planning processes (and
minimal incorporation of the planning processes into HMSO
programs). Within the fire departments, coordination between
fire suppression and HMSO program personnel was less than
optimal.
Requirement of Secondary Containment
The programs have been successful in requiring secondary
containment for new tanks. By firmly implementing this require-
ment, the programs have resulted in innovation in the design
and manufacture of tank facilities with secondary containment,
and they have forced the resolution of some of the problems
that were predicted or initially encountered.
Monitoring of Tanks and Piping
The ordinance programs were found to be taking effective
steps to prevent future releases. Except for certain issues
(discussed below) relative to monitoring and reporting, the
HMSO programs appear to be detecting leaks and related contamin-
ation with a reasonable degree of success. Although some leaks
have been detected through HMSO monitoring systems, a greater
number appear to have been detected as a result of testing
required by the Regional Water Quality Control Board (RWOCB),
or by soil sampling at the time a tank was removed or a facility
closed.
In the three cities that were studied in detail, it appeared
that monitoring systems had been installed at approximately
80-90% of the facilities for which monitoring was required.
However, the information in the files was often inadequate to
confirm the installation and operation of the monitoring system.
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The types of monitoring systems that have been installed are
divided approximately evenly among three categories: groundwater
monitoring wells, vadose zone (vapor) monitoring systems, and
miscellaneous other systems. However, an observed trend towards
vapor monitoring raises serious questions about the interpreta-
tion of results and the definition of a "reportable release" for
these systems.
Leak Reporting
Most programs do not require routine reporting of monitor-
ing results. In general, reporting is only required for speci-
fied "reportable releases."
The HMSO programs have received large numbers of "leak
reports." Most of the "leak" reports are based on soil sampling,
either upon tank removal or during the installation of monitoring
wells. Review of these reports indicates that there is very
little information in the local program files documenting the
significance of the soil contamination, and there are very few
files containing any indication that further investigation was
carried out.
Leak Response
Most of the programs appear to be providing effective,
routine notification to State agencies when leaks are reported.
However, there appears to be significant variation among programs
in the severity of incident that is defined as a leak, and
therefore reported. Regarding HMSO program response to leak
reports, the local program staff (or appropriate local response
unit) is responding to emergencies where a public safety hazard
is present, and they are providing the supervision to alleviate
that hazard. HMSO programs are not formally becoming involved
in long term clean up of environmental contamination, but they are
apparently providing informal advice at sites where the State
does not respond in a timely manner.
It appeared that very few of the fuel leak sites detected
under HMSO programs had received any guidance directly from
State agencies regarding clean up of environmental contamination.
The local program files that were reviewed as part of this
study generally did not contain any indication that the the
State agencies had provided any response, not even a written
notification of legal responsibilities regarding further invest-
igation and cleanup.
Tracking of State Agency Response - Few of the programs
maintain a formalized protocol for tracking the nature and
status of the State agencies' response to leak reports referred
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by the city. Such tracking appears to be desirable to ensure
that a State response occurs, or to document the lack of response,
if that is the case.
Tracking and Reporting of HMSO Program Status
Monthly summary reports to the city council, containing
totals for various program activities (such as permits and permit
applications), and for sites in various categories (such as leak
sites), were very useful in describing the achievements and
status of the program and in planning the allocation of resources.
Such monthly reports contained information similar to that con-
tained in the IGC survey report and did not require a major
effort to compile; however, they are not included in most programs
at the present time.
ACTION PLAN FOR HAZARDOUS MATERIALS STORAGE ORDINANCES
The IEMP forwards the following recommendations on the
HMSOs to the agencies named below. These recommendations were
developed by the lEMP's Drinking Water Subcommittee and reviewed
and approved by the Public Advisory Committee and the Intergovern-
mental Coordinating Committee. These recommendations are based
on the findings of the IEMP report entitled, "Implementation
Effectiveness of the Hazardous Materials Storage Ordinances in
Santa Clara County," other analyses available to the subcom-
mittee, and on the experience and expertise of subcommittee
members.
These recommendations were offered as possible steps that
could be taken in order to increase the effectiveness of HMSO
implementation programs. While they were primarily directed at
implementing agencies in the Santa Clara Valley, they were also
relevant to State and Federal underground tank and hazardous
materials programs. Recommendations are grouped into four
categories: Inspections, Information Management, Monitoring and
Reporting, and "Leak" Response and Site Cleanup.
Inspections
1. Coordinate inspection activities to minimize duplication.
Inspection activities for various programs (e.g., hazardous
materials, fire prevention, fire suppression) should be coordi-
nated to minimize the collecton of duplicate information by
closely related programs for slightly different uses. Effort
could be saved by additional program coordination, and there
is potential to improve the efficiency of program implementa-
tion. However, additional training and better written guidance
for inspections are essential for maintaining inspection
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quality if the inspection elements from multiple programs
are combined. In the long run, coordination of HMSO
inspection activities with pretreatment, Waters and
LaFollette inspections has the potential to reduce duplica-
tion and the burden on regulated firms.
2. Define minimum program guidelines for training and inspections.
An effort should be made to reach consensus on minimum guide-
lines to be used by all programs on such issues as training
and inspections. The programs could have variations, much as
individual city ordinances vary from the IGC model ordinance,
but such variations should be documented and shared among
programs. A starting point could include a review of statutory
requirements to improve the understanding of precisely what
the inspectors must be trained to do. The County may be
able to assist in this effort, but a forum such as the Fire
Chiefs' Hazardous Materials Subcommittee would be most
appropriate. The effort should result in a product rather
than just discussion.
3. Improve documentation of inspections. The documentation of
inspection results should be more thorough, particularly
where no violations or necessary improvements are noted.
An inspection yielding those results is an important product
of the program, and it was found to be extremely difficult
to locate documentation of such inspections in the program
files.
Information Management
4. Computerize selected information for program management.
Selected information on site classification, types of storage,
types of chemicals, quantity ranges, and status of compliance
should be computerized, at least at the program office level,
for purposes of program management and documentation.
5. Explore the possibility of centralizing data collection. The
advantages and feasibility of centralized collection of data
should be evaluated.
If the necessary information is not more detailed than what
is computerized at a local level for program management (as
suggested above), then the actual paper transfer to a central
location would not be difficult relative to any effort to
collect the information anew.
However, because of overlapping programs and broader environ-
mental goals, there are needs and uses for the data currently
being collected at the local level besides HMSO program
management that ought to be considered. Some of the broader
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goals for which information might usefully be collected and
computerized include long-term planning, source and waste
reduction, community education, emergency response planning,
and groundwater management, as well as identification and
remediation of soil and groundwater contamination and
immediate emergency response.
The computerization and centralization of data can begin
modestly and expand as needs and uses are better defined.
There is a need for the policy makers who are requesting
information to work closely with the program managers who
have the information in order to define what specific
purposes the data will serve. The Data Management Systems
Subcommittee that was formed as a result of the City-County
Agreement may be the forum in which to address these issues.
Consider computerizing selected monitoring data. It would
appear that significant additional benefit could be obtained
by requiring reporting of routine monitoring data (on a
periodic basis and in summary form—see below) and maintain-
ing that data in a centralized computer database.
Encourage use of Hazardous Materials Management Plans (HMMP)
information for emergency response. Significant effort should
be made to encourage use of the HMMP information as a routine
part of emergency response at regulated sites. However, it
is not clear that extensive computerization of the data
contained in the individual site HMMPs, either at the cities
or in a centralized database, would be the most effective
method for improving the accessibility or utilization of this
information.
Monitoring and Reporting
8. Require periodic summary reports of self-monitoring information^
Currrently, firms are required to collect a substantial
amount of monitoring information which they do not report to
the regulatory agency. The reporting procedures should be
modified to require the submission of routine "self-monitoring
reports" from all facilities where monitoring is required,
regardless of whether reportable releases are detected. It
does not appear to be an effective use of resources, or of
authority, to require the collection of information without
routinely reviewing the content and the quality of that
information. The information could be reported in summary
form and submitted periodically (quarterly or semiannually)
and signed by a responsible person at the facility.
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9. Improve definition of "reportable release". The definition of
"reportable release" should be improved. Specifically, thres-
hold values should be defined for all acceptable monitoring
systems. A "positive" result, requiring notification of the
HMSO program that a suspected leak has occurred, should be
clearly defined.
10. Define "reportable release" for systems relying on vadose
monitoring. For monitoring systems which rely on vadose
monitoring, a reasonable definition of a reportable release
should be developed. Without such a definition, the ordinance
provisions are not truly enforceable. The collection and
analysis of information on vadose monitoring by the SCVWD
should provide some technical data to support this effort.
If such a definition is not possible, the HMSO staffs (or
someone) should reconsider whether such systems should be
accepted by HMSO implementation programs.
11. Require monitoring systems that provide information on both
tank integrity and contamination around tanks. HMSO programs
have primarily emphasized prevention of future tank leaks,
and thus monitoring increasingly has focused on systems that
detect breaches of tank integrity. However, another signifi-
cant benefit of HMSO monitoring has been the detection of
contamination around tanks, from sloppy handling, pipeline
leaks, or other pre-existing contamination. Tank and pipe
tests and leak sensors, inventory reconciliation, internal
level sensors, and vapor wells in backfill immediately
adjacent to tanks are examples of tests that monitor tank
integrity, while soil sampling and groundwater monitoring
are necessary for the detection of contamination around tanks.
The Subcommittee recommends that monitoring requirements
take both objectives into account, and not focus exclusively
on tank integrity.
12. Duplicative reporting requirements should be minimized as
agency coordination improves and data management systems are
developed.
"Leak" Response and Site Cleanup
13. Require investigation of pre-existing contamination.
Monitoring under the HMSOs, like the State Regulations,
emphasizes the monitoring of existing tanks and piping inte-
grity. Although it is important to monitor system integrity
effectively, it is also important to identify sites where
pre-existing contamination might be present. At sites without
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monitoring to detect pre-existing contamination, such as
former or inactive tank sites, the RWQCB (for industrial
chemicals) and the SCVWD (for fuel tank sites), should begin
subsurface investigations to detect pre-existing contamination.
Oversight of investigation of pre-existing contamination
should be the responsibility of the SCVWD, the RWQCB and/or
local agencies.
14. Local agencies should request a written response from the
state agency once a contamination site is reported. The roost
significant gaps identified in the effectiveness of the
ordinances were related to lack of further investigation and
cleanup at sites where fuel contamination was detected through
monitoring or closure activities. Large numbers of fuel
contamination sites have been reported by HMSO programs to the
responsible state agencies. The local agencies should insist
that the state agency provide formal (written) notification
to the site's owner/operators, relative to their responsibility
under State law.
15. Consider local screening of fuel sites for groundwater
contamination. A large proportion of fuel contamination sites
detected under the HMSOs involve confirmed soil contamination,
without any information on the groundwater impact or hydro-
geology. The local HMSO programs should consider requiring
ground water sampling at these sites, in coordination with
the SCVWD and RWQCB, as specified in the Regional Board's
existing guidelines. This would allow for an immediate
screening of many sites to determine their potential impact
on groundwater and the possible need for immediate response.
16. Push for guidelines for soil contamination from fuel. Local
governments should continue their effort to obtain a coordi-
nated set of guidelines from state and federal agencies with
regard to residual soil contamination for fuel, or fuel
constituents, taking into account potential groundwater
contamination, air quality and public health. Such guidelines
would also facilitate the screening process and would simplify
the determination of necessary initial responses at fuel leak
sites.
17. Develop guidelines for and document actions taken with
regard to local response activities. Varying levels of
investigation and cleanup for fuel sites have, in the past,
been required directly by local HMSO programs. Whatever
level of initial response is provided, it should be acknow-
ledged, standardized and documented. Written guidelines
should be developed, or existing guidance should be formally
adopted, if adequate, for whatever level of response activity
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the local programs decide is appropriate. Such guidelines
should also specify procedures for documenting what was
required, what was accomplished, and what data were collected
at each site.
18. Set priorities for fuel cleanup efforts. As agencies move
to clean up identified fuel leak sites throughout the county
they may be unable to respond to all sites as quickly as
desired. As a result, the sites should be prioritized for
cleanup. The methodology for identifying areas of basin
sensitivity developed in the 205 (J) Report and further
developed in the SCVWD's aquifer management analysis
(discussed later in this chapter) could be used for prioriti-
zation. Other methods may be appropriate but should reflect
the same concepts.
19. Explore federal funding for fuel site cleanup. As agencies
move to clean up fuel sites county-wide, they should explore
the possibility of receiving EPA Underground Storage Tank (UST!
Trust monies, administered through the SWRCB, to provide
funding for oversight activities. In addition, the SCVWD
and RWOCB should explore possible State and Federal sources
to fund cleanup for sites with absent or recalcitrant
responsible parties.
Implementation
The IEMP has identified the following groups and agencies
to whom these recommendations should be forwarded:
o Intergovernmental Council
o Hazardous Materials Subcommittee of the Fire
Chiefs Association
o City Managers
o HazMat Programs
o Inspections Task Force
o Data Systems Management Committee
o RWOCB
o EPA-UST
o Tanner Implementation Committee
o Fee Structure Task Force
o POTWs
o SCVWD
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PROTECTION OF PRIVATE WELLS
SUMMARY OF ANALYSIS
Objective of the Study
The objective of this project was to investigate policy and
program options designed to reduce health risks from the
consumption of contaminated water from private wells.
Background and Scope
This analysis was undertaken by EPA's IEMP in response to
the Stage I findings that people drinking water from private
wells could face relatively high risks of contacting cancer.
Contamination of private wells may also pose risk of noncancer
health effects. These risks result from the lack of both
regulatory and natural geologic protection for private wells.
In this analysis, private wells were defined in accordance
with definitions from California regulations, where wells are
divided into three groups: 1) large public system wells having
200 or more connections that are regulated by the state; 2)
small public wells having 5-199 connections (or serve over 25
nonresidents more than 60 days per year) that are regulated by
county health departments; and 3) private wells having fewer
than 5 connections that are essentially unregulated. According
to local water district registration lists, there are some
3,700 private wells in Santa Clara County that are used for
household purposes.
Private wells may pose greater health risks to users than
do public wells for several reasons. First, private wells
generally draw from the shallow aquifer that does not benefit
from the clay confining layer that may protect deeper public
wells. Second, private wells are not monitored regularly, and
thus early detection of contamination is less likely than for
well monitored public wells. Private wells may also be impro-
perly constructed and therefore more vulnerable to contamination.
Based on these concerns, an initial sampling program for
private wells was undertaken in 1985 by the RWQCB and the Santa
Clara County Health Department (SCCHD). The objective of this
sampling was to determine the presence and extent of contamination
in private wells. The sampling program began with 171 wells
that were analyzed for organic chemicals and bacteriological
contamination. Generally, these 171 wells were chosen from
areas near known incidents of groundwater contamination from
industrial chemical leaks.
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The initial results indicated that bacteriological
contamination was more widespread than initially expected, while
the presence of organic chemicals was less prevalent than
expected. About 8% of the 171 wells were found to have organic
chemical contamination, with 3% contaminated above state action
levels. About 36% of the wells tested were found to have
bacteriological contamination and failed to meet state drinking
water standards.
A second phase of testing is currently underway and is
expected to include some 1200 private wells. The policy
options described in this report are intended to assist
decisionmakers in determining the nature and extent of any
follow-up or ongoing programs addressing private well contamin-
ation.
The report describes different categories of contamination
problems, outlines current efforts to protect private wells,
and evaluates approaches to reduce health risks from private
well contamination. Based upon this information, input by the
SCCHD and other subcommittee members, a countywide program for
private wells was developed and is described under the heading
"Action Plan For Private Wells."
Contamination Problems Affecting Private Wells
The most important and common contamination problems
affecting private wells fall under the following categories.
Nitrates Contamination
High nitrate levels are thought to pose a risk of
methemoglobinemia ("blue baby" syndrome) to infants under six
months of age. The EPA and the State have set a drinking
water standard of 45 ppm to protect this population, but nitrate
levels near or in excess of this health standard are found
in much of the South County. Past and current agricultural
practices, garden fertilization, animal husbandry, and septic
systems may contribute to high nitrate levels.
Industrial Contamination (primarily organic chemicals)
Exposure to some organic chemicals is thought to increase
the risk of cancer and other chronic health effects. Some 55
private wells are known to have been contaminated in the past
from identified industrial releases in Santa Clara Valley.
However, over the last several years, storage and monitoring
practices and site-investigation procedures in the County
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have improved, partly as a result of new requirements and partly
due to voluntary actions on the part of industry. These changes
have helped lessen the risk of contaminant releases and undetected
contamination incidents.
Fuel Contamination (primarily tank releases)
Exposure to various chemical components of fuels are
thought to pose the risk of cancer and other chronic health
effects. This risk may be mitigated if the toxic constituents
rapidly transform into harmless substances as some evidence
suggests, and if the characteristic taste and odor of gasoline
alert well owners to its presence. There are at least 714 fuel
release sites in the County although no known contamination of
private wells has yet occurred in Santa Clara County. (Note,
however, that such contamination has occurred elsewhere and
that no distinct effort has been made in Santa Clara County to
search for wells contaminated specifically by fuels.) There are
far more fuel tank sites in the County than industrial sites, and
less has been done in terms of prevention, detection, and
clean-up for fuel sites. In addition, responsible parties are
often difficult to identify or less able to cover financial
liabilities.
4) On-site Contaminants (primarily pathogens)
Exposure to bacteria, viruses, and other micro-organisms
can have effects ranging from stomach upset to hepatitis or
dysentery. Recent testing by the SCCHD found that more than
one-third of the private wells tested had excess levels of
bacterial contamination, although this does not necessarily
translate into a health threat. Pathogens present in soils,
septic field leachate, and leaky sewer lines can enter wells
that are poorly located or improperly constructed. Pathogens
can also enter domestic systems during storage of pumped water
or transport of that water to the point of use.
Current Programs to Protect Private Wells
Several existing regulatory programs are directed at
better understanding and reducing health risks from private
well problems. The Santa Clara Valley Water District's (SCVWD)
Ordinance 85-1 sets standards for well location, construction,
and destruction, and is an important preventive measure in re-
ducing health threats from pathogens. The SCVWD also maintains
a listing of private wells covering the entire Valley, although
Gavilan Water District's well list may be more complete in the
South County. The two water districts share the effort of
maintaining a 60 well groundwater monitoring network that may
help illustrate trends and identify developing problems that
could affect private wells.
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The SCCHD, which has county level authority to maintain
drinking water safety, is also undertaking monitoring and
cataloging efforts. Specifically, they are constructing an
overview map of sites and activities which potentially endanger
private well users and they are monitoring about 1,200 private
wells (roughly one-third of those wells that may be used for
domestic purposes) on a one time basis. Other SCCHD programs
that affect private wells include the septic tank permitting
process, the requirement for testing new wells with two to four
connections, and a new, voluntary nitrate testing for high-risk,
low-income families.
Finally, the RWOCB provides protection from contamination
from known release sites through their site investigation
process, which includes investigating and testing nearby private
wells. Similarly, local HMSOs safeguard groundwater generally
from releases of hazardous materials from underground tanks.
Methodology for Evaluating Private Well Protection Programs
The report analyzed policy approaches for reducing health
risks from private wells. Five general approaches were con-
sidered: preventing or reducing contamination through controls
on sources, monitoring drinking and groundwater, preventing use
of contaminated wells, upgrading existing wells to standards for
new wells, and implementing outreach and education efforts.
Each of these approaches was considered for each of the four
private well contamination problems and a set of the most
promising options was developed. Options were chosen for
detailed analysis based on the potential for health risk reduction,
the potential for local action, costs, uncertainty, and whether
they focused specifically on private wells rather than general
aquifer issues.
After they were described, the program alternatives were
evaluated against six criteria:
1. Effectiveness in reducing health risks.
2. Ease of implementation considering necessary legal or other
authority, technical expertise, increased agency workload,
public reaction, etc.
3. Flexibility, or the ability to respond to new information
without significant loss of investment.
4. Administrative costs.
5. Equity of cost distribution.
6. Effectiveness in addressing related groundwater concerns
such as problems of conduit wells.
Programs dealing with the individual contamination problems
are discussed first, followed by a discussion of considerations
in establishing an overall private wells program.
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Private Well Protection Programs By Type of Contamination
This section presents a summary of the most promising
program alternatives. Table 3-2 compares these alternatives
with the six criteria. Some of these evaluations are also
mentioned below.
Nitrates Contamination
The study developed and analyzed a program for reducing
risk from nitrates in private wells that builds on current SCCHD
efforts and involves public outreach, testing when wells of
concern are identified (i.e., those wells used by households
with infants in high nitrate areas), counseling to persuade
households at risk to provide a temporary alternative supply
for infants, and financial assistance for households in need.
Outreach could be directed towards households using wells in
high nitrate areas and women seeking obstetric and pediatric
care. Well testing could be made available, possibly at public
expense, upon delivery of a water sample to designated locations.
Counseling on potential risks and alternative water supplies
could be provided to households with or expecting infants when
tests indicate high nitrate levels. Financial assistance might
be available to assist in providing temporary alternative water
supplies.
This program rates high when evaluated by the above-listed
criteria. Administrative costs are relatively low (estimated
at less than $20,000 annually), and implementation should be rela-
tively easy as the program should not require new legislation or a
significantly increased burden on any agency. In addition, the
program can respond readily to new information without a signifi-
cant loss of investment (flexibility). However, the program does
little to address related groundwater concerns and addresses a
problem where the actual risks are uncertain.
Industrial Contamination
Many elements of a comprehensive strategy to protect ground-
water from industrial contamination are already in place in Santa
Clara County. Additional local programs focusing on private wells
should be designed to complement or improve upon existing activities
Three such activities are described in the report.
Monitoring; The SCVWD is establishing a network of wells
that will be sampled regularly to track groundwater quality and to
provide early warning of industrial contaminants moving toward
private wells. In 1985, Gavilan WCD established a similar system
with 60 wells monitored bi-annually. One possible program element
would be to extend these groundwater monitoring networks.
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3-27
TABLE 3-2
RATINGS OF PROGRAM ELEMENTS
Program Element Nitrate
Program
Effectiveness Exc.
Ease of Very
Implementation Good
Flexibility Very
Good
Industrial Fuels
Program Program
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
Fair Good
to
Very
Good
Very
Good to
Exc.
Good
Very Fair
Good
Poor
Fair
Good Fair
Fair
Good to
Very Good
On-Site
Program
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
Unknown
Exc.
Exc.
Exc.
Exc.
Fair
Exc.
Exc.
Fair
Administrative
Exc.
(1 ) Good
(2) Good, or
Poor
(3) Fair to
Good
Good
(1) Exc.
(2) Exc.
(3) Poor to
Fair
Eguity
Good to
Very Good
(1) Poor to
Fair
Good
(1) Exc.
Related GW
Concerns
(2)
(3)
Poor (1)
(2)
(3)
Exc.
Exc.
Fair Good
Exc.
Exc.
(2)
(3)
(1)
(2)
(3)
Exc.
Fair
Good
Good
Very
Good
SOURCE: ICF Technology, Inc., Groundwater Contamination and
Santa Clara Valley, Final Rep-rt, April 28, 1987.
Private Wells
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The effectiveness of additional monitoring is dependent on
the reliability of existing plans for monitoring networks, as well
as on monitoring conducted under the HMSOs and site monitoring
under clean-up efforts. Given the extensive existing monitoring
programs in the Valley, network extensions will probably yield
decreasing returns in terms of identifying threats to private
wells. However, because this program is merely an extension of
existing activities, it should be fairly easy to implement, and
relatively inexpensive. In addition, it appears to be a flexible
program with potential benefits for related groundwater concerns.
A related option would be to focus on monitoring private
wells per se instead of groundwater generally. Drinking well
monitoring detects both local and regional contamination (e.g.
septic tanks), while groundwater monitoring may detect only
regional contamination. Well testing on a regular basis or at
property transfer is discussed separately.
Active Investigation and Intervention: This is a much
more aggressive program than simply monitoring as above. It in-
volves empowering the County to investigate the effects of known
groundwater incidents on private wells. The County would be em-
powered (by a delegation of authority from the RWQCB and/or by
local ordinances) to test wells, order the use of alternative
supplies, and be reimbursed by responsible parties. This program
has the potential to offer significant risk reduction through
aggresive intervention. However, implementation of such a program
is blocked by considerable political, legal, and financial obstacles,
and necessitates an organization that is willing and capable of
leaping these hurdles.
County Role in Resource Damage Assessments Under SARA;
Under the Superfund Amendment and Reauthorization Act (SARA),
states are required to identify trustees to assess damages to
natural resources. Compensation for these resources can be
recovered from responsible parties and used to restore, replace, or
acquire the equivalent of the damaged resources. The County or
other local agency could try to secure a role in implementing this
legislation to obtain remedial action and funding. However, since
no rules have been promulgated and no legal precedent set, there
is great uncertainty over the ability of Santa Clara County to take
advantage of SARA's resource damage section. In theory, efforts
under SARA could result in resources from responsible parties being
shifted to private well cleanup. However, considerable County
effort would need to be applied to this option with no guarantee of
return.
Fuel Contamination
Private well fuel contamination problems could be included
under the proposed program for industrial contamination. However,
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because of the many differences between industrial and fuel
contamination problems discussed in the report, an effort specifi-
cally designed for fuel problems may be appropriate. As a result,
in addition to the industrial contamination options, the report
describes a multi-pronged effort at developing a local program
specifically for fuel site remediation and at securing federal
funds to offset costs of such a program (UST Trust).
Because current programs have been largely ineffective,
local initiatives could make a major contribution to the effective
ness of fuel site remediation. However, the SCVWD has recently
sent four employees to RWQCB for training in fuel site clean-up,
and an effort that goes significantly beyond this may be very
capital and labor intensive and severely handicapped without an
influx of federal funds. Assuming that federal UST Trust monies
will be available, the cost and effectiveness of this program
would be favorable. However, it is unclear whether such monies
will be easily obtained, making implementation of the program
described uncertain. As such, a more modest program might be
considered.
On-Site Contamination (Pathogens)
The initial phase of the program that addresses on-site
pathogen contamination emphasizes outreach and counseling for
owners of wells shown to be contaminated in SCCHD or other
testing. Counseling would focus on explaining the potential
risks and the remedial alternatives available to the well
owner. A second phase of the program could include expanded
outreach with well testing and counseling as appropriate to
owners of wells thought to be at risk. If a significant threat
to health is believed to remain despite counseling efforts, a
gradual shift from voluntary remediation to mandatory compliance
could be developed through new ordinances. Costs of outreach and
counseling should be relatively low, but remediation may be
difficult to obtain because the costs of city water hook-up
(the preferred long term alternative water supply) are both
high and most equitably charged to the well owner. Given the
uncertain risks of pathogens, a voluntary program may not be
effective as well owners may not believe that mitigation is
necessary. However, a mandatory program could face consider-
able public opposition and legal obstacles.
Considerations for Overall Private Well Programs
Coordinated Private Wells Program
Since many of the program elements for addressing different
private wells contamination problems are similar, it may be more
efficient to develop and implement these program elements on a
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coordinated basis. Such a coordinated program could be primarily
an assemblage of program elements already outlined.
A coordinated effort could begin with public outreach,
education, and counseling. The outreach portion would identify
well owners and inform them of all potential contamination risks.
For wells that have not already been tested under SCCHD testing
programs, or where there is the possibility of new or undetected
problems, selected voluntary monitoring might follow to define
more precisely what risks, if any, particular well owners face.
If monitoring results identify a problem, owners could receive
notification and counseling about remediation alternatives (such
as hook-up to city water, home treatment, bottled water). Remedi-
ation would be voluntary and could involve limited public assist-
ance as appropriate.
Under a coordinated program there could be follow-up on
voluntary remediation efforts to determine whether well owners
are responding to the counseling on their own and with what
effect. If counseling and voluntary remediation are not providing
adequate health protection, mandatory efforts may be appropriate.
For instance, a general well testing program, such as that outlined
in this report (and summarized below), could be implemented.
Alternatively, testing might be conducted only when there is
reason to suspect a problem (for example, in high nitrate areas
where an infant is in the household, or following identification
of a nearby contamination site). When testing identifies a
significant health threat, the SCCHD might require that remedial
steps be taken.
If a mandatory program is desired, local agencies would need
to seek greater authority than currently exists. For instance, a
single ordinance might be drafted for wells with fewer than five
service connections that specifically authorizes the SCCHD to
test such wells, and to require closure and use of alternative
supplies in cases where a health threat exists, regardless of the
type of contamination or source. (An ordinance authorizing
routine well testing when no immediate health threat is suspected
may need to be backed up by a change in state law.) In addition,
local agencies may seek a delegation of authority from the RWQCB
so that they can require responsible parties to pay for the
remedial efforts they mandate.
A coordinated program can tie together program elements for
different problems when they are similar in approach (e.g., out-
reach, counseling, etc.). However, it need not preclude efforts
targeted to specific problems. For instance, efforts that focus
on site remediation for fuels and industrial contaminants (such
as those outlined in the report) could proceed at the same time.
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A coordinated program may be advantageous in terms of reducing
administrative complexity, costs, and effort: a single ordinance
might suffice for all problems, staff needs may be reduced by a
coordinated outreach and counseling effort, sample collection
costs might be reduced since multiple laboratory tests could be
performed on the same sample. On the other hand, a coordinated
program may lose some of the advantages of a finely tailored
program: outreach efforts would not be targeted directly to
specific well owners thought to be at risk which may increase
costs; general outreach may also confuse well owners because they
may not realize that they face particular risks (for instance,
well owners in high nitrate areas may not recognize that they
face a greater health threat from nitrates than typical well
owners); a sampling effort that tests a larger number of wells
for a wide range of contaminants may increase costs over
a focused testing effort.
Overall Monitoring Program
With the exception of fuels (and some organics) contami-
nation above taste and odor thresholds, the private wells problems
discussed in the report are likely to be detected only if wells
are tested. In the past, private well monitoring in Santa Clara
County has been ad hoc. Currently, systematic one-time testing
of a large sample of private wells by the SCCHD is underway.
This report contains many suggestions for testing private wells
at particular points in time, such as when problems are suspected
or when property is sold. However, it is possible to design
and implement an overall monitoring program.
One possible overall monitoring scheme is regular ground-
water monitoring of a network of strategically selected wells.
This is discussed in the fuel and industrial sections, although it
could also provide valuable information regarding movement and
severity of nitrate plumes.
Another monitoring strategy is periodic monitoring of all
private wells in a manner similar to public well testing. The
frequency of the testing and the chemicals for which samples are
tested could depend on the well's location (e.g., proximity to
industrial sites or high nitrate areas), past testing results
(e.g., indications of previous bacterial contamination), the
cost of testing (e.g., tests for pathogens are far less expensive
than tests for organics), and other factors.
A major concern of a regular and comprehensive monitoring
program is cost. Since there are over 3,700 private wells in
the county used for household purposes, expenses for such a
program add up quickly. If all wells are tested once every
five years for pathogens and nitrates, and half the wells
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(those in "industrial" areas*) are tested for organics, the
report estimates program costs of $200,000 annually: $70,000
for testing expenses and roughly $120,000 for staffing (an
estimated three FTEs) and other administrative costs. Such
high program costs might necessitate extraction fees or other
funding sources outside of current program budgets.
Alternatively, periodic monitoring could be required at
the owner's expense. This would avoid the issue of public
funding, but would raise new legal and administrative obstacles.
Of course, enforcing the program could be costly in and of
itself.
Regardless of who pays, a change in State law might be
necessary before a valid local ordinance requiring monitoring and
subsequent remediation could be enacted.
The effectiveness of a regular monitoring program, would
depend on how often contamination is detected and what follow-up
steps are taken. Monitoring does not by itself reduce risk; the
monitoring information must be used for preventive, protective,
or remedial efforts in order to reduce risk. The findings of the
SCCHD's current testing program should provide important clues as
to how effective a regular monitoring program might be.
Conclusions
1. The program outlined in this study for addressing risks from
nitrates contamination appears promising. It is a relatively
simple and inexpensive effort that targets the specific population
at risk.
2. The program outlined for addressing risks from pathogenic
contamination, particularly initial phases that emphasize
outreach and counseling, also appears promising. The more
aggressive phases of the program that involve mandatory remedia-
tion are less promising given the high cost of remediation and
the uncertain risks posed by pathogens.
3. The programs developed for fuel and industrial contamination
focus on the sources of contamination more than on programs at
the wellhead. The reasons for this focus include a) the fact
that the source of these these contaminants may be pinpointed
more easily than the sources of nitrates and pathogens with great
benefits for the groundwater resource generally, and b) the
concern expressed by the drinking water subcommittee that focusing
on the well was, quite literally, ignoring the "source" of the
problem.
* If testing for organics is conducted only in "industrial1
areas, then on-site sources of organics and resultant
contamination may not be detected.
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As a result of this focus, the complete programs described
in this study to protect against fuels and industrial contamina-
tion tend to be more ambitious and more difficult to implement
than those directed at nitrates and pathogens.
However, as noted under the "coordinated program" section,
a more limited program of outreach and counseling, such as that
proposed for nitrates and pathogens, could be instituted for fuels
and industrial contaminants.
4. For many of the programs, the report raised the option of
a local agency requiring remediation if a health threat is
identified through monitoring. This option implicitly assumes
that some standard will be employed to determine when such a threat
exists. One way to implement such an option would be for local
agencies to institute mandatory well standards for private well
owners. These standards could duplicate state standards (and
action levels) that apply to public wells. Such an option is
clearly an aggressive step that would require a new local ordi-
nance, possibly a change in State law, and additional county
resources to implement and enforce.
ACTION PLAN FOR PRIVATE WELLS
The following action plan elements contain the IEMP
participants' recommendations for a County-wide private wells
program. The recommendations are based on the IEMP report
entitled, "Groundwater Contamination and Private Wells in Santa
Clara Valley," summarized in the IEMP Stage II Report, on the
input of the County Health Department, as well as on the
experience and expertise of the participants.
The program described below is intended to follow the
current well testing program with a set of measures to reduce
exposure and risk. The IEMP believes that the SCCHD
would be the logical agency to implement this program.
The basic program elements are as follows:
1. The SCCHD should complete the private wells testing program
currently underway and should follow up on monitoring results
with counseling efforts as described below.
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2. The SCCHD should implement an outreach and counseling
effort as follows;
a. Expand current outreach and counseling effort for
households with infants potentially at risk from high
nitrate levels in drinking water. Public health
nurses presently inform expectant mothers of the risks
from high nitrates in private well water. This program
could be expanded to include all health care providers.
Counseling would include advising households of the risk
to infants, of the availability of testing for a fee, and
of the available alternative water sources should high
nitrate levels be confirmed.
b. Notify private well owners and users of potential risks
and inform them that they can (voluntarily and at their
own expense) have their wells tested and sanitary surveys
conducted. Notification could be through mailings to all
well owners on SCVWD's well lists, and other appropriate
means. The SCCHD can continue to provide a list of
certified water testing laboratories upon request.
c. Counsel owners and users of contaminated wells identified
through program elements no. 1, 2b, 3 or 4 as to their
remediation alternatives. Remediation alternatives would
vary depending on the type of contamination (nitrates,
organics, bacteria, etc.) as well as the severity, of
contamination, the accessibility of public water, and
other factors. The alternatives might include hook-up to
public water supplies, use of home treatment unit or
bottled water, on-site housekeeping improvements, and
others. The list of approved water treatment devices
being developed by the State Department of Health Services
DOHS will be helpful in providing recommendations for
alternatives.
d. Require that owners notify users of that well (e.g.
tenants, employees) of the full results of any chemical
analysis of the water and point out any exceedances of
drinking water standards or action levels.
3. The SCCHD should implement the following testing program
for existing private wells;
a. Require testing of private wells at the time of property
transfer. The required tests would be determined by the
SCCHD after a review of potential identifiable hazards in
the vicinity of the water source. A sanitary survey
would also be conducted. Costs would be borne by the
property owner.
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b. Require that results be disclosed to the parties to the
transaction, possibly through a mechanism analogous to
the "transfer disclosure form" currently required by the
State, and to the SCCHD to become part of the public
record. Results would also be disclosed to subsequent
users of the well (e.g., tenants, employees).
c. Remedial efforts would be at the discretion of the
private parties to the transaction, unless the well was
found to be a source and subsequent conduit of materials
outside the well or a health problem.
4. The SCCHD, in conjunction with the SCVWD, should require
that owners of private wells constructed in the future comply
with the following standards (Enforced through the building
site permitting process, a well use permitting process or a
similar mechanism):
a. Require a minimum 50 foot sanitary seal as part of con-
struction standard (currently required and enforced by
the SCVWD);
b. Require 100-foot separation of private well from septic
tank/septic leach field site (currently required);
c. Require initial disinfection of well (currently required);
d. Require testing for water quantity;
e. Require water quality testing and sanitary survey before
use; testing could be conducted for a broad range of
substances, at the discretion of SCCHD;
f. Require that water quality meet relevant existing state
water quality standards for public systems and quantity
standards before use; periodic inspections to followup on
remedial efforts would be conducted at the discretion of the
SCCHD;
g. Require that the results of the above testing be disclosed
to financial institutions and prospective buyers, and to
the SCCHD and/or the SCVWD to become part of the public
record; and
h. Require that the property owner be responsible for the
costs of the new testing/remediation/permitting process.
5. The relevant agencies should perform vigorous investigation
and cleanup activities at all contamination sites. While
the above measures designed to reduce exposure at the wellhead
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are the primary focus of these recommendations, efforts to
find and control contaminant plumes are an important part of
an overall program to protect groundwater sources of drinking
water. Current efforts, such as the effort to train SCVWD
staff for cleanup, should be encouraged. Agencies may also
want to explore other options to help support investigation
and cleanup at potential contamination sites, such as pursuing
SARA and UST Trust funds.
Implementation Strategy
The SCCHD would logically implement most of the program
elements. The outreach and counseling efforts require no new
authority. The requirements for wells at time of property trans-
fer or at the time of construction would involve new authority,
either through a change in State law or through County and city
ordinances. A County ordinance alone would not be sufficient
because County authority generally does not extend into the
boundaries of an incorporated city. Recognizing current budget
limitations within Santa Clara County, the program proposed here
is designed to recover costs. Existing staff should be capable
of handling those efforts that cannot be covered by fees, such as
outreach and counseling, once the existing private well testing
program is concluded.
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AQUIFER MANAGEMENT IN SANTA CLARA VALLEY
SUMMARY OF ANALYSIS: SANTA CLARA VALLEY WATER DISTRICT STUDY
Objective of Study
The purpose of this study was to evaluate groundwater
management in Santa Clara County in order to recommend changes
in current practices and/or to consider new alternatives in
groundwater management.
Background and Scope
This project was undertaken because of concerns that
aquifer management, i.e. groundwater management, needed to be
reexamined in light of new groundwater contamination problems.
Aquifer management was selected as an important focus in Stage
Two for several reasons: concern for protecting groundwater
resources as well as human health; concern about the cost,
resource impact and effectiveness of cleanup and prevention
activities; and concern about the effectiveness of coordination
and the consistency of direction among the many agencies involved
in aspects of groundwater/drinking water supply and regulation.
To address these concerns, Stage Two aquifer management projects
attempted to: (1) clarify the objectives of aquifer management;
(2) address some key issues currently facing the Valley; (3)
identify opportunities for agency cooperation; and (4) generally
make recommendations for improvements to current management
practices.
In Stage II of the IEMP, two projects on aquifer manage-
ment were conducted. One of the projects was prepared under the
direction of the Santa Clara Valley Water District and entitled
"Groundwater Management in the Santa Clara Valley". That study
is summarized here. The other project, prepared by EPA and
entitled "Aquifer Management Project: Evaluation of Groundwater
Cleanup Policies", is summarized in the following section. The
two studies address different aspects of the same issue, and
are intentionally complementary.
The SCVWD report takes a broad look at groundwater manage-
ment, and asks how traditional water supply management (practiced
in the Santa Clara Valley for decades by the SCVWD) is compli-
cated by increasing problems of contamination. Included in the
SCVWD report are documentation of groundwater resources, defin-
ition of current groundwater management practices, evaluation of
contamination problems, and assessment of current groundwater
quality protection and cleanup programs. Alternatives for
groundwater quality management are also described and assessed.
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Methodology
Researchers who contributed to the report reviewed existing
information and planning documents, and also conducted in-depth
discussions with those involved in groundwater management in
Santa Clara Valley. The study focuses on current conditions as
well as projections for a planning period to the year 2020.
The study area was the Santa Clara Valley and its underlying
groundwater basin, including the Santa Clara, Coyote, and
Llagas subbasins (see map - figure 3-1). Much previously
widely scattered information is compiled in the report with an
eye to informing the non-technical reader. The evaluation and
recommendations were provided by outside consultants (rather
than in-house staff) in order to assess more independently the
current management practices.
Summary of Report
The major areas covered in the SCVWD report are summarized
below. Topic areas include: geographical situation and hydro-
geology, water demand and supply, current groundwater management,
water quality, groundwater quality protection and cleanup,
value of the groundwater basin, and alternatives for groundwater
quality management.
Geographical Situation/Hydrogeology
The geology of the Santa Clara Valley is characterized by
discontinuous lenses of clay, silt, sand and gravel. Portions
of the Santa Clara and Llagas subbasins contain a lower confined
aquifer and an upper unconfined aquifer. Hydraulic separation
between shallow and deep aquifers is generally considered to be
consistent throughout the confined area with the exception of
artificial connections through improperly constructed or aban-
doned wells. The principal recharge in these subbasins occurs
in the forebay (i.e., away from San Francisco Bay) along elevated
basin edges.
Water Demand and Supply
Population and total water demand have increased signifi-
cantly since the 1950's. The SCVWD projects and tracks both
water demand and water supply to assist in planning. The water
demand projections are based upon projections of future land
use in the county, using a model that projects land use into
type and quantity of water demanded for specific parcels of
land in the county. Using this approach, water demand in Santa
Clara County is projected to increase to 468,000, 498,000 and
549,000 acre/feet/year (afy) in 1990, 2000, and 2020 respectively.
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Fig. IH-1 Santa Clara Groundwater Basins
COYOTE
GROUNDWATER
BASIN
SANTA CLARA VALLEY
GROUNDWATER
BASIN
10
LLAGAS
GROUNDWATER
BASIN
miles
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Sources of water supply for Santa Clara County include
imported water, local surface water and local groundwater.
While a shortfall in water supply could occur in the Santa
Clara and Llagas subbasins in the year 2000, temporary depletion
of groundwater storage can fulfill water demands. Water supplies
are projected to be sufficient to meet projected demands in the
Coyote subbasin in the year 2000 and in all three subbasins in
the year 2020.
The availability of an adequate supply of water
during periods of drought was examined. Two scenarios were
envisioned - a moderate drought in which all sources of water
supply are reduced to 75% and a severe drought in which the
water supply is reduced to 50%. The analysis assumes that
the deficit in water supply will be compensated through
increased groundwater pumpage and depletion of groundwater
storage (about 4.7% of storage "per year in a severe drought),
and a 20% decrease in water demand due to conservation efforts.
The analysis indicates that a moderate drought would result
in average drawdowns across the basin of about 1-6 feet/year.
A severe drought would result in average drawdowns of 11-19
feet/year. While it appears that sufficient water exists in
groundwater storage to compensate for a severe drought,
pumpage would be concentrated, resulting in local problems such
as water level decline, subsidence and seawater intrusion.
Additional deep wells may also have to be drilled.
Current Groundwater Management
The goal of groundwater basin management is to achieve a
sufficient quantity of water in areas of demand while maintaining
the quality of the water at the highest level. The yield of a
groundwater basin can be changed by both artificial recharge of
water into the basin, reduced opportunity for natural rechage
through urbanization, and overpumpage. Overpumpage can result
in at least two undesirable consequences: land subsidence and
saltwater intrusion. Currently, these two problems are mitigated
through an extensive program of artificial recharge. In addition
to these management concerns, shallow groundwater conditions have
posed a flooding problem in years with high rainfall. In order
to evaluate any of these potential water quantity problems, the
changes in water levels are actively measured by the SCVWD in
monitoring programs that include 350 wells.
Groundwater basin modeling, although not an active part of
current management efforts, has been investigated on several
occasions as a tool in groundwater management. At least five
groundwater basin models have been developed or are in progress.
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Early Department of Water Resources (DWR) models could not be
calibrated with actual conditions due to the lack of historical
data. A cost/benefit model was developed and used for analysis
of the artificial recharge program by Reichard and Bredehoeft.
The SCVWD was developing a predictive model of the basin that
was 75% complete when funding was cut.
Water Quality
The quality of surface water and groundwater is influenced
by both naturally occurring and human-introduced constituents.
SCVWD programs exist to monitor local surface water quality,
imported surface water quality and, most recently, groundwater
quality. The monitoring program for groundwater quality is in
response to the most recent water quality concern - groundwater
contamination by industrial solvents, gasoline and agricultural
chemicals.
The extent of groundwater contamination, largely resulting
from leakage or spillage at sites where hazardous materials have
been used or stored, has been extensively documented elsewhere.1
The Regional Water Quality Control Board's site investigation
program had identified 106 industrial sites with soil or ground-
water contamination, as of October 1986. These sites typically
show contamination with organic chemicals such as widely used
solvents. In addition, as of April 1987, at least 489 fuel
leak sites were under investigation. Contamination has affected
at least 94 water supply wells (38 large public water supply
wells and 56 private wells) in the Santa Clara Valley.
Cleanup efforts for industrial sites are proceeding,
albeit slowly. Cleanup for fuel leaks is still only in the
initial stages of assigning regulatory responsibility and
funding responsibility, with the RWQCB training SCVWD staff to
begin fuel leak cleanups. The location of contamination
plumes near existing water supply wells suggests that adverse
impacts are possible unless careful monitoring and management
practices are followed.
1 See, for example: (1) Department of Health Services, Regional
Water Quality Control Board 12, Santa Clara County Public
Health Department, Santa Clara Valley Water District,
U.S. Environmental Protection Agency, Groundwater and Drinking
Water in the Santa Clara Valley: An Updated White Paper,
September 8f 1986; (2) San Francisco Regional Water Quality
Control Board, SEEHRL- U.C. Berkeley, and Santa Clara Valley
Water District, Assessment of Contamination from Leaks of
Hazardous Materials in the Santa Clara Groundwater Basin,
205-j Report, UCB/SEEHRL Report No. 85-6, July 1985.
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Groundwater Quality Protection and Cleanup
Current groundwater protection programs are designed
to diminish point source release of contaminants (HMSO and
Underground Storage Tank (UST) investigations), and inter-
aquifer transport of contaminants (conduit well sealing
program). There are several additional protection programs
that might be considered including: groundwater protection
zones; groundwater management zones and groundwater basin
modeling. These programs are discussed more fully under the
heading of alternatives for groundwater quality management.
Value of the Groundwater Basin
The benefits of the groundwater basin are its natural
yield, treatment, storage and conveyence capacities. The
costs of the current system of groundwater use include:
purveyors' costs for groundwater development (installing wells,
pumpage costs); costs incurred by the SCVWD for basinwide
management, including recharge facilities; and cost associated
with programs for groundwater quality protection and cleanup.
Alternatives considered to the use of the groundwater
basin include: increased imported surface water; increased
capture of local surface water; wastewater reuse; urban water
conservation; transfer of water from agricultural areas; and,
desalinization of San Francisco Bay Water. Consideration of
the above alternatives indicated that the replacement of a small
portion of the groundwater yield probably is possible at
reasonable cost; however, replacement costs of a significant
portion of the basin would be prohibitive. It is also
doubtful that any of the alternatives could provide adequate
storage and protection of water resources in the event of
a drought or emergency.
Alternatives for Groundwater Quality Management
Several additional groundwater quality management
activities were outlined in the report for consideration by the
IEMP. Three of the most important recommendations were to
establish groundwater basin protection areas, groundwater
management zones and a groundwater basin modeling program.
Groundwater protection areas represent areas where
productive aquifers occur and where there is currently little
opportunity for contamination because industry is not located
in the area. Communities could consider protecting these areas
from future contamination by land use measures such as zoning
by-laws, ordinances, or tax incentives. Santa Clara County does
not currently use these groundwater management tools.
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Groundwater management zones are another groundwater
protection tool not utilized in Santa Clara County- Ground-
water management zones are areas where productive aquifers
currently exist with industrial areas of known contamination.
To avoid the loss of groundwater use in these areas, special
attention could be given to well location and design, pumpage
rates and intensity of groundwater cleanup.
Groundwater basin modeling could be used to assist in
the management of the basin. A predictive model could assist
in testing current hypotheses about how the basin functions.
For example, a model could assist in answering questions
about the amount of recharge, the occurrence of leakage through
the confining layer or the impact of drought upon groundwater
levels. In addition, basinwide modeling could provide
information for specific groundwater contamination investi-
gations such as regional transmissivities, groundwater gradients
and limits to the aquifer system, such as subsidence effects.
Conclusions
The SCVWD study provides recommendations for improvements
to the current set of activities comprising groundwater manage-
ment, (three of the most important such recommendations are
summarized above). Relying on these recommendations and others
provided by EPA in its aquifer management study, and the
knowledge of subcommittee members, the IEMP developed a
unified set of aquifer management recommendations. These
recommendations are presented at the conclusion of the
description of the EPA aquifer management study.
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AQUIFER MANAGEMENT IN SANTA CLARA VALLEY
SUMMARY OF ANALYSIS: EPA AQUIFER MANAGEMENT STUDY
Objectives and Scope
This section summarizes EPA's Aquifer Management Study of
Stage II of the Santa Clara Valley Integrated Environmental
Management Project (IEMP). The full report is composed of
two parts which are outlined in this summary. The first
section provides an overview of the problem and objectives in
aquifer management and identifies the agencies and activities
which affect the management of the groundwater basin. The
second section, the major part of the report, analyzes in
depth a major issue of concern - the aquifer wide implications
of toxic contamination and cleanup.
The objectives of this study were twofold. First, this
study tried to develop a meaningful framework for clarifying
the common goals and guiding the related activities of the
many entities involved in groundwater/drinking water management
and protection. Second, the study attempted to assess the
health and groundwater resource impacts of alternative clean-up
policies, clarifying the trade-offs involved in the "how
clean is clean" decision.
Background
Stage I of the Santa Clara Valley Integrated Environmental
Management Project concluded that effective environmental
management of drinking water, and particularly groundwater,
should take into account not only risks to human health, but
also the current and anticipated impact of contamination on
groundwater as a natural resource. Besides damaging human
heath, contaminants, and some programs (such as well closure
and groundwater clean-up) that protect people from their effects,
may damage groundwater and result in other economic costs.
In addition, a number of different agencies independently
regulate aspects of water supply, water quality, and health
protection. The SCVWD manages groundwater use and surface
water importation, ensuring the supply of good quality drinking
water. The cities and Santa Clara County operate the Hazardous
Materials Storage Ordinances (HMSOs), which help to prevent
groundwater contamination. The Regional Water Quality Control
Board is the lead agency on groundwater quality and clean-up of
existing contamination, with EPA and other agencies involved.
The State and County Health departments regulate the quality of
finished drinking water, so as to protect public health.
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3-45
Because of the perceived importance of considering the
effects of groundwater-related programs on the entire aquifer
system, and the division of responsibility for such programs
among agencies, the IEMP in Stage II explored the need for
an overall "aquifer-wide management" approach to integrate
programs and objectives.
Perhaps no issue illustrates the need for such an approach
as much as the problem of addressing groundwater contamination.
Cleanup levels are determined by the RWQCB with concurrence
from the DOHS. But groundwater cleanup levels affect water
supply, which is the responsibility of the SCVWD, as well as
the water quality of drinking water wells, which are controlled
by the DOHS (Sanitary Engineering Branch) and the County.
Contaminant migration is also influenced by improperly constructed
or closed wells (the SCVWD has a program that addresses this),
well pumpage rates (not currently regulated), and other factors.
Because final cleanup levels have, for the most part, not
yet been set, and because of the importance of this issue to
the Valley's groundwater system, the IEMP decided to examine
the aquifer-wide impacts of various cleanup levels in Stage
Two.
Overall Approach to Aquifer Management
EPA first attempted to identify the key objectives in
aquifer management, then to outline the agencies involved in
various activities affecting groundwater or drinking water.
Objectives of Aquifer Management
Aquifer management in the Santa Clara Valley groundwater
basin, or elsewhere, is concerned with two basic problems:
water quantity and water quality. The two main objectives of
aquifer management are:
o Effective resource protection and use; and
o Health protection.
Protection of the groundwater natural resource involves
preserving not only a quantity of high-quality water used for
drinking water, but also an aquifer system that provides
free storage, treatment and distribution of drinking water.
Effective use of groundwater resources means intelligent management
of those resources over the long run so as to avoid costly,
long-term damage to groundwater resources (e.g. contamination
of valuable drinking water supplies) as a result of activities
with littel benefit (e.g. cheap waste disposal). Resources
should be preserved for their highest-valued use.
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3-46
Protection against health risk involves controlling or
preventing human exposure, through drinking water, to
toxic contaminants that have gotten into the groundwater
system.
Often, the same policies and activities activities will
assist in achieving both aquifer management objectives. This
is so in the case of the HMSO programs that protect both
health and the groundwater resource. However, in other
cases, the objectives conflict and involve tradeoffs. For
example, during a drought, water purveyors may need to use
lower-quality water to provide sufficient quantity. Similarly,
groundwater pumping for cleanup involves trading off the use
of large quantities of water in the short run for continued
maintenance of groundwater quality in the long run.
Aquifer management involves balancing three other key
concerns besides water quality and water quantity:
o cost-effectiveness;
o equity; and
o public process.
Consideration of cost-effectiveness involves weighing
desirable objectives, such as resource or health protection,
against costs, so that limited resources are used most
efficiently. In addition, the impacts of policy decisions
should be equitable. In the context of pollution control,
equity typically means that the costs of a program should be
levied on those responsible for creating the problem and/or
on those who stand to benefit from the program, and that
innocent parties should not bear the adverse impacts of
problems created by others. One way to balance the interests
of the community in decision-making is to have a public
process that encourages input to policy-making agencies.
These objectives and concerns are useful criteria for
evaluating the desirability of various groundwater
policies. Although the study did not directly address equity
and public process in the Stage Two analysis, they are important
considerations in public and regulatory debates on issues of
groundwater management.
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3-47
Aquifer Management Activities and Institutions
A wide range of activities and institutions affect
groundwater resources or drinking water quality in some way,
and thus fall under the general category of aquifer management.
These activities and institutions are described in
detail elsewhere, and are only briefly reviewed here.l
From the point of view of water quantity or supply, ground-
water management is primarily a task of feeding and withdrawing
water in appropriate balance. Water is fed through natural
recharge and through artificial recharge of local and
imported water. Water is withdrawn through well pumping.
Since the aquifer functions as a natural storage system,
input and output may be out of balance in a given year. This is
because storage may be built up in a wet year or drawn down
during a dry year. However, consistently drawing down
groundwater supplies creates a problem if replacement supplies
are unavailable or expensive. In addition, input and withdrawal
must be in balance over time or problems will develop, such
as intruding saltwater, subsiding land, and increasing pumping
costs. Water quantity activities, then, are those affecting
either recharge or withdrawal.
Water quality activities affect the same physical system
and therefore fall into the same categories of recharge and
withdrawal. Protecting the quality of recharge water
encompasses a number of activities to prevent contamination
from hazardous materials, prevent the contamination of recharge
ponds through runoff, and so on. At the withdrawal end of
the system, well siting and construction standards are designed
to ensure that withdrawn water is of high-quality. Drinking
water monitoring and standards provide a last line of defense
to protect individuals from being exposed to impure water.
In addition, some water quality preservation activities are
intended to prevent in-the-ground contamination of pure water
by contaminated water. Such in-the-ground measures include
slurry walls, well pumping to reduce plume movement, and
potentially, in situ cleanup via biological treatment.
Current cleanup technology entails a withdrawal of water from
the groundwater system, although the intent is to prevent the
spread of contamination to pristine waters.
1. More detailed reviews of toxic and water management programs
are found in the reports entitled "Institutional Analysis" by
CH2M-Hill and "Groundwater Management in Santa Clara Valley"
by O.K. Todd Consulting Engineers, and "Aquifer Management
Project: Santa Clara Valley Integrated Environmental Management
Project," by EGA, Inc. and ICF, Inc.
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3-48
Table 3-3 outlines the various agencies involved in
the different aspects of aquifer management, following the
categorization described above.
Methodology for Evaluating Alternative Groundwater Cleanup Policies
The objective of this portion of the study was to examine
an aquifer management policy issue - cleanup levels - in
light of the overall aquifer management objectives discussed
above. The
"how clean is clean" question is one of the most sensitive
and important environmental management issues confronting
Santa Clara Valley decision-makers. This analysis seeks to
inform the policy debate by providing analysis on the impacts
of alternative policies.
The method developed to aid decision-making on groundwater
cleanup levels attempted to compare different cleanup policies
in terms of their human health and groundwater resource
impacts. To the extent possible, impacts were estimated
quantitatively. The study was designed to provide information
to IEMP participants that would clarify the impacts and
trade-offs of alternatives, thus assisting IEMP participants
to reach their own, informed conclusions.
The general approach used was to model representative
groundwater plumes under typical conditions in different
parts of the groundwater basin. Plume impacts were estimated
under alternative possible cleanup requirements. Impacts
were then aggregated by the number of contaminant plumes
assumed for the basin and overall basin-wide impacts estimated
under the different cleanup policies. Impacts estimated in
this way included:
o Health risks from exposure to toxic pollutants in
drinking water;
o Resource costs, i.e., volumes of water contaminated,
losses in drinking water well production and water losses
due to clean-up; and
o Direct costs of clean-up and treatment.
A number of sensitivity analyses were performed to
examine the importance of key uncertainties, such as the
likely amount of future contamination and future policies
for closing drinking water wells.
-------
AQUIFER MANAGEMENT ACTIVITIES AND INSTITUTIONS
RECHARGE
QUALITY/
PREVENT
TABLE 3-3
INSTITUTION
RECHARGE
QUANTITY
CONTAMINATION
CLEANUP/
PREVENT
MIGRATION
WITHDRAWAL/
PREVENT
EXPOSURE
FEDERAL
EPA
Bureau of Reclamation
STATE
Department of Water Resources
State Water Resources Control Board
Regional Water Quality Control Board
Food & Agriculture
Dept. of Health Services-
Sanitary Engineering Branch
Toxic Substances Control Division
Epidemiohgical Studies
LOCAL
Santa Clara Valley Water District
City of San Francisco
Local Planning
Local Environmental
Fire and Building
Local Health
Solid Waste
Water Purveyors
Supply
Manage Supply
Water Rights
Artificial Recharge
Surface Water Supply,
Water Conservation
Surface Water Supply
Urban Development
RCRA
CERCLA
Policy Regulations
Waste Discharge Regulations
Agricultural Land Use
RCRA Regulations
Well Sealing, Closure, &
Construction; Recharge
Urban Development, Zoning
Waters, Tanner Programs,
Hazardous Materials Storage
Ordinances
Hazardous Materials Storage
Ordinances
Regulation on Septic Tanks
Policy
Multi-Site Cooperative Agree-
ment, CERCLA, RCRA
Groundwater Strategy
Waste Discharge Requirements
Set Cleanup Levels
Standards Development, Concur
on Cleanup
Advisory on Cleanup, Fuel Tank
Follow-up, Conduit Well
Sealing
Maximum Containment Level
(MCL) Standards
Set Policy
Drinking Water Standards.Well
Siting Review (large systems)
Standards Development
Pump Tax, Well Construction,
Surface Water Treatment
Surface Water Treatment
Regulate Wells (small
systems) and Septic Tanks
Groundwater Extraction
Wellhead Treatment
u>
-e-
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3-50
An important aspect of the approach used in this study
was the attempt to place an economic value on resource impacts.
To do this, we estimated the potential lost use of groundwater
due to contamination, and estimated the cost of obtaining
replacement supplies. Note that while lost use is related to
the extent of contamination, they are not the same thing
(i.e., the IEMP approach to estimating resource losses implicitly
attaches a higher value to groundwater that is used or might
be used than to that which is not used). While EPA believes
that the economic valuation of resource losses is a useful
approach, the estimated volumes of water affected under
different policies and assumptions are also presented and may
be used directly by the reader who is uncomfortable attaching
dollar values to environmental resources.
The method used to estimate health risks from ground-
water contamination and subsequent drinking water exposure
follows EPA Risk Assessment Guidelines and is described in the
Revised Stage One Report; that description is not repeated
here. (The exposure methodology in this study is somewhat
simpler than the Stage One approach, and is described in
detail in supporting technical reports.) Estimation of direct
costs, such as the expense of drilling and pumping wells and
treating contaminated water, is straightforward.
A step-by-step outline of the methodology is presented
in Figure 3-2 and discussed below.
Step One; Define Cleanup Levels
The methodology specified the following three differing
cleanup levels or objectives:
(a) removal of contaminated soil only;
(b) removal of contaminated soil and cleanup
of contaminated groundwater to drinking water standards
or State action levels; and
(c) removal of contaminated soil and cleanup of groundwater
to nondetectable levels.
Under the cleanup actions modeled in this analysis,
a plume is first contained at the furthest point at
which contamination is detectable. Then the plume is pumped
until the cleanup level (either standards, or non-detectable)
is reached everywhere within the plume. This stringent
definition of cleanup increases the estimated volume of water
required to achieve the target level relative to a cleanup
strategy that seeks to contain a smaller plume.
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3-51
FIGURE 3-2
GROUNDWATER CLEANUP ANALYSIS
DEFINE CLEANUP LEVELS
1) Soil Only
2) Standards/Action Levels
3) Non-Detectable
WELLHEAD
TREATMENT
VS.
REPLACING
WELLS
DIVIDE BASIN INTO ZONES
1) Bay/Muds
2) Confined
3) Recharge SE
4) Recharge NW
MODEL PLUMES
8 plumes (2 in each zone) for 3 cleanup levels
Outcome of Modeling=lmpacts
1) Volumes pumped for cleanup
2) Area contaminated
3) Direct costs (treating GW/drilling wells)
AGGREGATE IMPACTS FOR BASIN
Mulitply by # of sites assumed for basin, under
different cleanup policies:
Q Maximum cleanup
Q Cleanup varies by zone
Q Clean up to DW standards
<-
^
1
ISranslafc impacts into risk factors, resource tosses
and doi!arvalut
CLOSED
VOLUMES
FO« CLEANUP
OF REPtAC£M0tT
SUPM.Y
SENSITIVITYCASES
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3-52
The three cleanup levels defined for this analysis are
not, of course, the only options available. It may be
appropriate to consider containing only the high-concentration
segments of plumes and/or cleaning up to some level between
standards and non-detectable. In this analysis, we chose to
examine these three cleanup levels because they represented
the upper and lower bounds of plausible cleanup requirements.
Step Two: Divide Basin Into Zones
The methodology divided the basin into four zones in
order to capture important differences in (1) hydrogeologic
characteristics; (2) numbers of contaminated plumes; and
(3) use of the groundwater basin as a drinking water source.
Short descriptions of the four zones follow (see Figure 3-3):
- Bay/Muds Zone; characterized by few wells; slow
groundwater movement.
- Confined Zone; characterized by many public and private
wells; more permeable soils (sand); presence of a confin-
ing layer (i.e. aquitard) that may protect deeper wells;
industrial activity; many leaks.
- Recharge Zone; characterized by many wells; unconfined
aquifer; extremely fast groundwater movement; extremely
permeable soils; recharge area for entire basin; fewer
but larger plumes. Further subdivided into two zones.
1) South East; groundwater closer to surface, largest
current plumes.
2) North West; groundwater 150 - 200 ft below surface,
slower groundwater movement.
Characterizing the hydrogeology of the Santa Clara Valley
groundwater basin as being composed of four zones is a
significant simplification of a very complex hydrogeology.
However, this simplification was the only practical approach
in an analysis of this breadth, and the most important
hydrogeologic variations are captured by differentiating
among zones.
Step Three; Model Plumes
The next step was to use a finite element computer model
(the "Coupled Flow, Energy and Solute (CFEST)" model), which
is commonly used to model the impacts of cleanups at Superfund
sites. Eight plumes were modeled (one large and one small
plume in each of the four zones) under the three different
cleanup levels. The following impacts were projected;
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3-53
Figure 3-3
SANTA CLARA VALLEY GROUNDWATER BASIN ZONES
BAY SANDS/
MUD ZONE
San
Jose
>
Y\
SANTA
CLARA
COUNTY
SANTA CLARA VALLEY
GROUNDWATER BASIN
N
\\
SAN I
MATED •
COUNTY |
X
INLAND CONFINED
ZONE
COYOTE GROUNDWATER
BASIN
EAST RECHARGE
ZONE
LLAGAS
GROUNDWATER
BASIN
WEST RECHARGE
ZONE
SANTA CRUZ
COUNTY
mites
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3-54
- Volumes of water pumped in clean-up operations, along
with estimates of duration of pumping;
- Amount of Groundwater Contaminated, i.e., volume or
area affected by plume;
- Cost of cleanup/direct cost which is defined as the cost
of drilling wells and treating discharge water (soil
removal costs, or additional cleanup expense, were not
calculated). The resource value, or cost of the water
itself, is estimated in step 5.
Using eight representative plumes to characterize the
range of contamination sites is a simplified representation
of a much more complex reality. As with the hydrogeologic
simplification, it was the only practical approach in an analysis
of this scale, and was thought to capture the most important
elements of actual variation among plumes.
Step Four; Aggregate Impacts to Obtain Basinwide
Perspective
The amounts of water contaminated and pumped and the
cost of cleanup were taken from the individual scenarios
described in step 3 and then multiplied by the number of
sites (large or small) that were assumed to be contaminated.
The methodology
used three different estimates of sites: existing sites only,
and a low and a higher estimate of future contamination
incidents. The aggregated results use
the low estimate of future sites as the base case.
Basin-wide impacts were estimated under different basin-
wide cleanup "policies" (the least stringent policy, minimal
cleanup, was included as a base of reference and is not
under serious consideration as a policy in Santa Clara Valley).
We combined the cleanup levels with zones to obtain three
different types of policies:
Maximum cleanup in all zones (Max);
- Variable cleanup - cleanup to different levels
in different zones (Variable); and
- Cleanup to drinking water standards and action levels
in all zones (Standards).
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3-55
The following chart shows how the cleanup levels and zones
were combined into basin-wide cleanup policies:
Policies Evaluated
Cleanup Subbasin Zones
Policies
Bay Confined E Recharge W Recharge
Maximum Max Max Max Max
Cleanup
Variable I Soil only Standards Max Max
Variable II Soil only Soil only Max Max
Variable III Standards Max Standards Standards
Cleanup to Standards Standards Standards Standards
Standards
Minimal Clean up Soil Only Soil Only Soil Only Soil Only
Policies were chosen, after consultation with the IEMP
Drinking Water Subcommittee, to represent basinwide cleanup
policies of interest in the Santa Clara Valley.
Significant uncertainty is introduced in this aggregation
step. Sensitivity analyses (described below), varying the
number of likely future contamination incidents and the
hydrogeology of the basin, explore some of these uncertainties.
In general, the analysis attempts to characterize hydrogeology
and numbers of plumes in a conservative way, so as to avoid
underestimating impacts. Thus, aggregate impacts, particularly
water volumes required for cleanup, are more likely to have
been overestimated than underestimated.
Step 5; Translate Impacts Into Risk Factors, Resource Losses
And Dollar Value of Resource Losses
Volumes contaminated were translated into two factors:
human health risk and groundwater resource losses. This was
accomplished by using the intermediate step of determining
the numbers of wells affected and then translating the well
contamination into either risk, in cases where wells are
contaminated at low levels and presumed to ramain in service;
or numbers of wells closed (and therefore well production lost,
requiring replacement) in cases where wells are contaminated at
high levels. In addition, these two factors are influenced
by well closing policies. Two separate cases were chosen for
investigation:
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3-56
a) wells are assumed to close whenever contamination
meets or exceeds standards (base case); and
b) wells are assumed to close whenever contamination
is at detectable levels.
Sensitivity analysis was also performed on the effective-
ness of the confining layer. The first case assumes that the
confining layer is 100% effective in guarding deep public
wells from contamination in the Bay Muds and Confined zones.
The second case assumes that the confining layer is not at
all effective and all public wells below the confining layer
are affected. Clearly, neither assumption is wholly accurate.
However, for purposes of this analysis, the all or nothing
assumptions clearly provide lower and upper bounds on possible
impacts.
Both the volumes pumped and the well production lost
were translated into dollar figures by determining how much
replacement surface water (the most available substitute)
would cost. Volumes pumped were assumed to need full replace-
ment because the levels of water in the aquifer need to be
maintained at current levels over time. Well production
losses were assumed to need total replacement as well.
The cost of replacement supplies of water was estimated
based upon surface water entitlements, water reclamation
costs and the purchase of water from fanners. These supply
curves took into account that obtaining a small increment of
water would be relatively inexpensive, but a large amount of
water would be more difficult to obtain and consequently more
expensive.
Dollar value of water was estimated using two sensitivity
cases for cost curves: local cost, i.e. likely out of pocket
costs to Santa Clara Valley; and social costs, i.e. costs to
society at large. Two discount rates were used: 10% and 3%.
Translation of physical impacts into potential health
risk introduces additional uncertainty into this analysis.
Health risk estimates are designed to be conservative and are
more likely to overestimate than underestimate actual risk.
Estimating the economic value of replacing groundwater
resources is also problematic. A number of sensitivity cases,
described below, provide a reasonable range of resource
replacement costs, assuming the estimates of physical impacts
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3-57
are correct. This analysis, however, does not attempt to
place an economic value on the intrinsic or aesthetic value
of groundwater, as distinct from its use value.
Step 6; Assess Risks and Costs of Wellhead Treatment
The intent of this part of the analysis was to compare
two alternative policies at the drinking water wellhead:
(1) treating contaminated wells and (2) closing contaminated
wells and finding replacement supplies of drinking water. To
date, almost forty major drinking water supply wells have
been affected by detectable levels of contamination, several
at levels high enough to require well closure. Additional
wells are likely to be contaminated in the future.
Since closing wells and obtaining replacement drinking
water supplies is expensive, and since replacement supplies
themselves may entail health risks, the IEMP thought it
important to examine the cost and risk impacts of treating
contaminated wells as compared with closing them. The costs
of wellhead treatment were researched and estimated. A case
was examined in which wells were treated with carbon absorption
rather than closed, if contamination before treatment was
less than 500 ppb.
Results of Analysis
Tables 3-4 through 3-13 presents the results of this
analysis. Substantial analytic simplifications were necessary
because of time, resource, and data constraints. This analysis
is adequate for its intended purpose — comparison of policies.
It is not intended to predict the effects of those policies
precisely.
Comparison of Cleanup Policies
Tables 3-4 through 3-10 compare the calculated costs and
benefits of each cleanup policy to a baseline set of impacts
under "Minimum Cleanup" basin-wide. Each table presents
results under two bounding assumptions: that the confining
layer is completely effective, and, alternatively, that it is
not at all effective. Three types of results are presented:
1. Health risks avoided. The first column presents
the estimated number of cancer cases reduced by a
particular cleanup policy, as compared to "Minimal
Cleanup." Risk estimates reflect both exposure to
groundwater contaminants and exposure to trihalo-
methanes in surface water, in cases where wells are
assumed to be closed and individuals switched to
surface water.
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3-58
In reviewing estimates of human health risk presented
in this report, it is important to remember that
quantitative estimates are too uncertain to be
regarded as literal predictions of impacts. Rather,
they are intended to provide a basis for comparison
among policies. For a fuller discussion of risk
assessment methods and uncertainties, see the Stage
One Report.
2. Groundwater resource impacts. Column two presents
the estimated volume of water preserved through
cleanup. Since the major benefit of preserving
groundwater is to allow its use as drinking water,
column three presents the estimated well production
saved as a result of reduced contamination. Column
four presents the estimated replacement cost of this
water (and hence the value of avoiding such replacement).
Cleanup also has groundwater resource costs.
Column five presents the quantity of water that must
be pumped under a given cleanup policy, and column
six presents the replacement cost of this water.
3. Direct costs. Cleanup entails a direct cost for
drilling extraction wells and pumping and treating water,
in addition to the resource cost of the lost water
itself. The estimated direct cost for basinwide
implementation of each cleanup strategy is presented
in column seven.
The benefits of cleanup calculated in this analysis were
human health risks avoided and drinking water well production
saved, while the costs were the groundwater pumped in cleanup
and the direct costs of cleanup. Column eight presents the
sum of calculated benefits and costs, excluding health benefits.
Cleanup Policy Impacts Under the "Base Case"
Results under Base Case assumptions are presented in
Table 3-4.
Health Risks Avoided. The estimated reductions in risk from
cleanup are strongly influenced by assumptions about
the effectiveness of the confining layer. Cleanup to Standards
provides the greatest benefits, with incrementally smaller
reductions in risk projected for more aggressive
cleanup. Interestingly, Variable Cleanup Policy III
(maximum cleanup in the confined zone) reduces risk about as
much as Maximum Cleanup in all zones does. This
suggests that the greatest risk reduction benefit in cleaning
up contamination beyond the limits of the drinking water
standards may be obtained by aggressive cleanup in the confined
zone.
-------
COMPARISON OF CLEAN-UP POLICIES
BASE CASE: Wells close at standards, 10% discount rate, social cost of water
TABLE 3-4
CLEANUP POLICIES
Confining Layer Effective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Cleanup
Confining Layer Ineffective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
BENEFITS OF CLEANUP
Risk
Avoided
Est. cancer
cases in 70
years1
7
7
4
7
7
0
31
25
3
31
25
Minimum Clean-Up | 0
IMPACTS UNDER
MINIMUM CLEANUP
Confining Layer Effective
Confining Layer Ineffective
RISK
Cancer Cases
7
31
GW Saved
From Con-
tamination
1000 acre-ft.,
greatest extent
in 30 years
693
481
374
434
183
0
693
481
374
434
183
0
^^^^^^^^^^^
GW CON-
TAMINA-
1000-acre-ft
1082
1082
DW Well Production
Saved: 2
1 000 acre-ft $ millions
over 70 years
404 34
404 34
404 34
404 34
404 34
0 0
1815 85
1748 84
404 9
1815 86
1815 87
0 0
^^^^^^^^^^^TO^^^^^^B
DW WELL
PRODUCTION LOST
1000-acre-ft $ millions
414 36
1903 104
|
COSTS OF CLEANUP
GW Pumped in Cleanup: 2
1 000 acre-ft. $ millions
over 70 years
7434 808
7180 773
6941 718
2377 425
2159 405
0 0
7434 809
7180 776
6941 731
2377 430
2159 409
0 ()
GW PUMPED IN j
CLEANUP: 2
1000 acre-ft $ millions
0 0
0 0
Direct Costs
of Cleanup
$ millions over
70 years
213
208
193
120
117
0
213
208
193
120
117
NET
BENEFITS
$ millions over
70 years
($987)
($947)
($877)
($514)
($488)
0
($937)
($900)
($915)
($464)
($439)
0 I 0
DIRECT COSTS
OF CLEANUP
$ millions
0
0
1. Weight of evidence for carcinogenic!ty of compounds observed in groundwater in Santa Clara Valley ranges from A (proven human carcinogen) to E (no evidence of human
carcmogenicity). Representative substances modeled in this analysis were perchlorethylene (B2, probable human carcinogen) and 1,1,1 trichlorethane (not currently classified).
Health risk estimates are uncertain and are more likely to overstate the risks than to understate them (see text).
2. Estimated economic value of similar quantities of water may be different because the estimated value of water rises as TOTAL volume affected (well production and cleanup
impacts) increases.
SOURCE: ICF, Inc., Revised Evaluation of Alternative Groundwater Cleanup Policies for the Santa Clara Valley Groundwater Basin: Exposure, Risks, and EOA, Inc., Valuation
of Resource Impacts, June 1987. Tables C-6A - C6H
EOA, Inc., Evaluation of Alternative Groundwater Cleanup Policies, June 1987, Tables 12-15, 20.
-------
3-60
Variable Cleanup Policy I (aggressive cleanup in the
Recharge Zone, minimal cleanup in the Bay Muds Zone) reduces
about the same amount of risk as cleanup to Standards does,
while Variable Cleanup II (aggressive cleanup in the
both Recharge Zones, minimal cleanup elsewhere) actually
provides less protection than uniform cleanup to Standards.
Resource Impacts and Direct Costs. The basin-wide extent
of groundwater contamination was projected to be potentially
significant, and the corresponding reduction due to cleanup
was also quite large. Maximum Cleanup reduces contamination
substantially more than cleanup to Standards, with other
policies falling in between. (Bear in mind that the analysis
did not account for some factors that may reduce the amount
of groundwater contaminated, such as transformation of
contaminants into harmless products and geologic structures
that inhibit flow.) However, in terms of well production
saved, all policies above minimum cleanup perform equally,
except for Variable Cleanup II if the confining layer is
ineffective. This difference between extent of contamination
and well production affected occurs because wells are assumed
to stay open so long as contamination levels remain within the
limits set by the standards. Thus no additional well production
is saved by cleaning up to levels beyond those required by
the standards. (Well closure policy is varied in a sensitivity
case, described below.)
The most striking result of this analysis is the very
large groundwater resource impact projected under all options.
Because very large quantities of groundwater will be necessary
for cleanup under all options, the estimated resource costs
of cleanup appear substantially larger than the resource
benefits of cleanup ($405 to $809 million in resource costs
compared to $9 to $87 million in resource benefits). These
results should be interpreted with caution, however, as some
expert reviewers have commented that the estimated resource
impacts of cleanup may be overestimated. A sensitivity case,
described below, addresses this issue.
The high estimated resource costs and direct costs
suggest that aggressive cleanup may be quite costly.
Interestingly, aggressive cleanup in the confined zone (Variable
III) appears far less resource-intensive than aggressive cleanup
in the recharge zones (Variable Policies I and II), although
the health risks and resource benefits are estimated to be
just as great.
-------
3-61
Cleanup Policy Impacts Under Different Assumptions
The effects of uncertainties on the estimated impacts
of the cleanup policies were examined by varying key
assumptions in sensitivity analyses. Sensitivity analyses help
to identify plausible upper and lower bounds on impacts, as
well as to identify which pieces of information or policy
choices have the most influence on impacts.
o Confining Layer Effectiveness (all Tables). As noted,
the effectiveness of the major confining layer has
a significant impact on the overall impacts of
contamination and hence the benefits of cleanup activi-
ties. Assumptions about the confining layer effectiveness
also have an impact on the relative ranking of the
policies. If the confining layer is ineffective,
aggressive cleanup in the confined zone (Variable III)
looks relatively attractive, while minimal cleanup in
that zone (Variable II) looks unattractive.
o Well Closure at Detection. Because of uncertainty
about future policies concerning what levels of
contamination will be permissible in water served to
people, we examined an alternative case in which wells
were assumed to be closed at any detectable level of
contamination. While this is clearly an extreme
assumption, it provides a useful upper bound on well
production impacts. In this case, presented in Table
3-5, the risk reduction benefits of cleanup are greater
than in the base case, particularly if the confining
layer is assumed to be effective. (Ironically, the
larger estimated risk reduction in this scenario is due
primarily to reduced exposure to trihalomethanes in
surface water rather than to reduced exposure to ground-
water contaminants. In addition, the groundwater
resource benefits of aggressive cleanup relative to
cleanup to standards are far greater than in the base
case; Maximum Cleanup, and all Variable policies, offer
substantial benefits over cleanup to Standards. However,
even under this stringent well closure assumption, the
resource costs of cleanup still appear significantly
greater than the resource savings.
-------
COMPARISON OF CLEAN-UP POLICIES
WELLS CLOSE AT DETECTION All other assumptions as in base case
TABLE 3-5
CLEANUP POLICIES
Confining Layer Effective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Cleanup
Confining Layer Ineffective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
BENEFITS OF CLEANUP
Risk
Avoided
Est cancer
cases in 70
years1
16
16
16
NA
10
0
32
23
12
NA
18
MnimutnClean-jJp | 0
GW Saved
From Con-
tamination
1000 acre-ft.,
greatest extent
in 30 years
693
481
374
434
183
0
693
481
374
434
183
__*>___
DW Well Production
Saved: 2
1000 acre-ft. $ millions
over 70 years
1689 48
1689 48
1689 48
NA NA
868 -8
0 0
4071 102
2808 49
1688 24
NA NA
2030 3
0 0
COSTS OF CLEANUP
GW Pumped in Cleanup: 2
1000 acre-ft. $ millions
over 70 years
7434 806
7180 771
6941 716
2377 NA
2159 404
0 0
7434 814
7180 779
6941 731
2377 NA
2159 403
__o_ °
Direct Costs
of Cleanup
S millions over
70 years
213
208
193
142
117
0
213
208
193
142
117
0
llllfllltllsBlllsi
NET
BENEFITS
$ millions over
70 years
($971)
($931)
($861)
NA
($529)
$0
($925)
($938)
($900)
NA
($517)
1.$°
miii
u>
I
IMPACTS UNDER
MINIMUM CLEANUP
Confining Layer Effective
Confining Layer Ineffective
RISK
Cancer Cases
16
34
GW CON-
TAMINA-
1000-acre-ft.
1082
1082
DW WELL
PRODUCTION LOST
1000-acre-fL $ millions
1729 55
4277 131
GW PUMPED IN
CLEANUP: 2
1000 acre-ft. $ millions
0 0
0 0
DIRECT COSTS
OF CLEANUP
$ millions
0
0
1. Weight of evidence for carcinogenicity of compounds observed in groundwater in Santa Clara Valley ranges from A (proven human carcinogen) to E (no evidence of human
carcinogenicity). Representative substances modeled in this analysis were perchlorethylene (B2, probable human carcinogen) and 1,1,1 trichlorethane (not currently classified).
Health risk estimates are uncertain and are more likely to overstate the risks than to understate them (see text).
2. Estimated economic value of similar quantities of water may be different, because the estimated value of water rises as TOTAL volume affected (well production and cleanup
impacts) increases.
SOURCE: ICF, Inc., Revised Evaluation of Alternative Groundwater Cleanup Policies for the Santa Clara Valley Groundwater Basin: Exposure, Risks, and EOA, Inc., Valuation
of Resource Impacts, June 1987. Tables C-6A - C6H
EOA, Inc., Evaluation of Alternative Groundwater Cleanup Policies, June 1987, Tables 12-15, 20.
-------
COMPARISON OF CLEAN-UP POLICIES
INCREASED FUTURE USE OF GROUNDWA TER All increased demand for water met by groundwater,
other assumptions as in base case
TABLE 3-6
CLEANUP POLICIES
Confining Layer Effective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Cleanup
Confining Layer Ineffective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Clean-Up
MIMIim«MUMIIIIlllMII Hi •IMIIIMMII
BENEFITS OF CLEANUP
Risk
Avoided
Est. cancer
cases in 70
years1
7
7
4
7
7
0
34
27
3
21
27
GW Saved
From Con-
tamination
1000 acre-ft..
greatest extent
in 30 years
693
481
374
434
183
0
693
481
374
434
183
0 0
DW Well Production
Saved: 2
1000 acre -ft $ millions
over 70 years
432 36
432 36
432 36
NA NA
432 36
0 0
2022 94
1913 90
432 6
NA NA
2022 93
0 0
&sssBwtB&smimximsa&&aamaS&8K/&SSB&
COSTS OF CLEANUP
GW Pumped in Cleanup: 2
1000 acre-ft. $ millions
over 70 years
7434 808
7180 773
6941 718
2377 425
2159 405
0 0
7434 809
7180 776
6941 731
2377 430
2159 409
Direct Costs
of Cleanup
$ millions over
70 years
213
208
193
120
117
0
213
208
193
120
117 1
NET
BENEFITS
$ millions over
70 years
($985)
($945)
($875)
NA
($486)
0
($928)
($894)
($918)
NA
($433)
0 0 I 0 | 0
fflmBBMB^B5BHIHBIIIIIIEE^EE^EE"^E^^^^^^BE"a8BKBW~
I
CT>
U)
IMPACTS UNDER
MINIMUM CLEANUP
Confining Layer Effective
Confining Layer Ineffective
RISK
Cancer Cases
7
36
GW CON-
TAMINA-
1000-acre-fL
1082
1082
DW WELL
PRODUCTION LOST
1000-acre-fL $ millions
442 38
2111 110
GW PUMPED IN
CLEANUP: 2
1000 acre-fL $ millions
0 0
0 0
DIRECT COSTS
OF CLEANUP
$ millions
0
0
1. Weight of evidence for carcinogenicity of compounds observed in groundwater in Santa Clara Valley ranges from A (proven human carcinogen) to E (no evidence of human
carcuiogenicity). Representative substances modeled in this analysis were perchlorethylene (B2, probable human carcinogen) and 1,1,1 trichlorethane (not currently classified).
Health risk estimates are uncertain and are more likely to overstate the risks than to understate them (see text).
2. Estimated economic value of similar quantities of water may be different, because the estimated value of water rises as TOTAL volume affected (well production and cleanup
impacts) increases.
SOURCE: 1CF, Inc., Revised Evaluation of Alternative Groundwater Cleanup Policies for the Santa Clara Valley Groundwater Basin: Exposure, Risks, and EOA, Inc., Valuation
of Resource Impacts, June 1987. Tables C-6A - C6H
EOA, Inc., Evaluation of Alternative Groundwater Cleanup Policies, June 1987, Tables 12-15, 20.
-------
COMPARISON OF CLEAN-UP POLICIES
REDUCED PLUMES 3 Fewer and smaller plumes in Recharge Zones, other assumptions as in base case
TABLE 3-7
CLEANUP POLICIES
Confining Layer Effective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Cleanup
Confining Layer Ineffective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
BENEFITS OF CLEANUP
Risk
Avoided
Est. cancer
cases in 70
years
6
6
3
NA
6
0
31
24
2
NA
24
GW Saved
From Con-
tamination
1000 acre-ft.,
greatest extent
in 30 years
347
241
187
217
92
0
347
241
187
217
92
Minimum Clean-Up | 0 | 0
MPPMPMPHBIBM^^
DW Well Production
Saved: 2
1000 acre-ft. $ millions
over 70 years
2% 26
296 27
296 27
NA NA
296 27
0 0
1708 83
1640 81
290 25
NA NA
1708 83
0 0
a^^ajAiMiiiiiirx^^iiJ^
COSTS OF CLEANUP
GW Pumped in Cleanup: 2
1000 acre-ft. $ millions
over 70 years
2890 266
2636 241
2396 196
NA NA
918 137
0 0
2890 272
2636 246
23% 203
NA NA
Direct Costs
of Cleanup
$ millions over
70 years
90
86
71
NA
54
0
90
86
71
NA
918 139 1 54
NET
BENEFITS
$ millions over
70 years
($330)
($300)
($240)
NA
($164)
0
($279)
($251)
($249)
NA
($110)
0 0 1 0 | 0
ssssssassss^fc^
to
I
IMPACTS UNDER
MINIMUM CLEANUP
Confining Layer Effective
Confining Layer Ineffective
RISK
Cancer Cases
7
36
GW CON-
TAMINA-
1000-acre-ft.
541
541
DW WELL
PRODUCTION LOST
1000-acre-fL $ millions
298 29
1788 97
GW PUMPED IN
CLEANUP: 2
1000 acre-ft. $ millions
0 0
0 0
DIRECT COSTS
OF CLEANUP
$ millions
0
0
1. Weight of evidence for carcinogenicity of compounds observed in ground water hi Santa Clara Valley ranges from A (proven human carcinogen) to E (no evidence of human carcinogenicity).
Representative substances modeled in this analysis were perchlorethylene (B2, probable human carcinogen) and 1,1,1 trichlorethane (not currently classified). Health risk estimates are uncertain
and are more likely to overstate the risks than to understate them (see text).
2. Estimated economic value of similar quantities of water may be different, because the estimated value of water rises as TOTAL volume affected (well production and cleanup impacts) increases.
3. Separate hydrogeologic modeling of plume movement was not performed for this case. Extent of contamination was assumed to be roughly half that of the base case, and other values were
calculated accordingly. See text.
SOURCE: ICF, Inc., Revised Evaluation of Alternative Groundwater Cleanup Policies for the Santa Clara Valley Groundwater Basin: Exposure, Risks, and EOA, Inc., Valuation of Resource
Impacts, June 1987. Tables C-6A - C6H
EOA. Inc., Evaluation of Alternative Groundwater Cleanup Policies. June 1987, Tables 12-15. 2O.
-------
3-65
o Increased Future Groundwater Use. Another factor that
might increase the value of cleaning up the groundwater
basin is if future use of the basin were greater than
the SCVWD now projects. The impacts under the assump-
tion of increased future groundwater use are presented
in Table 3-6. Risk and resource benefits of cleanup
are slightly greater than in the base case, but not
enough to affect overall impacts or the comparative
rankings of the different policies.
o Reduced Plumes in Recharge. Several expert reviewers
were concerned that the base case analysis might
significantly overstate the groundwater resource impacts
of cleanup due to lack of site-specific data, inability
to model geologic complexities adequately, and/or over-
estimation of the number and size of plumes. To address
this concern in part, a sensitivity analysis with
fewer and smaller plumes was performed.
Results of this case are presented in Table 3-7.
The resource and direct costs of cleanup under these
assumptions are indeed far lower than in the base case
(risk reduction and resource benefits are also slightly
lower). However, the resource costs of cleanup
still outweigh the resource benefits, and relative
rankings of the policies are unchanged.
EPA cautions that this analysis did not use
detailed, site-specific data in projecting cleanup
impacts, nor did it take account of real hydrogeologic
complexities. Thus, the impacts presented in this
analysis are intended to provide only a rough indica-
tion of basin-wide impacts, and the results of this
sensitivity case should not be interpreted as a
lower bound on possible cleanup impacts.
o Alternative Cost Assumptions. Tables 3-8, 3-9,
and 3-10 present results for alternative cost assump-
tions. The "Reduced Social Cost" case examines
impacts under the lower bound assumption that replace-
ment water supplies may be obtained for the actual
cost of transport and delivery (i.e., pumping, treating,
new facilities). The "Local Cost" case projects the
costs that the SCVWD might actually have to pay for
replacement water, which may differ from the water's
"true" social cost because of water regulation and
subsidization. An alternative discount rate (similar to
the interest rate) is also examined. None of these
alternative assumptions fundamentally alter the results
and comparative rankings discussed above.
-------
COMPARISON OF CLEAN-UP POLICIES
REDUCED SOCIAL COSTS Lower social costs of water, other assumptions as in base case
TABLE 3-8
CLEANUP POLICIES
Confining Layer Effective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Cleanup
Confining Layer Ineffective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Clean-Up
BENEFITS OF CLEANUP
Risk
Avoided
Est. cancer
cases in 70
years'
7
7
4
7
7
0
31
25
3
31
25
0
GW Saved
From Con-
tamination
1000 acre-ft.,
greatest extent
in 30 years
693
481
374
434
183
0
693
481
374
434
183
0
DVV Well Production
Saved: 2
1000 acre-fL $ millions
over 70 years
404 7
404 7
404 8
404 NA
404 8
0 0
1815 24
1748 24
404 -18
1815 NA
1815 26
COSTS OF CLEANUP
GW Pumped in Cleanup: 2
1000 acre-ft. $ millions
over 70 years
7434 408
7180 388
6941 356
2377 NA
2159 196
0 0
7434 412
7180 395
6941 368
2377 NA
2159 200
0 0 1 0 0
Direct Costs
of Cleanup
$ minions over
70 years
213
208
193
120
117
0
213
208
193
NET
BENEFITS
S millions over
70 years
($614)
($589)
($542)
NA
($313)
$0
($601)
($579)
($579)
142 I NA
117 1 ($291)
0 $0
OJ
I
01
IMPACTS UNDER
MINIMUM CLEANUP
Confining Layer Effective
Confining Layer Ineffective
RISK
Cancer Cases
7
31
GW CON-
TAMINA-
1000-acre-ft
1082
1082
DW WELL
PRODUCTION LOST
1000-acre-ft. $ millions
414 10
1903 34
GW PUMPED IN
CLEANUP: 2
1000 acre-fL $ millions
0 0
0 0
DIRECT COSTS
OF CLEANUP
$ millions
0
0
1. Weight of evidence for carcinogenicity of compounds observed in groundwater in Santa Clara Valley ranges from A (proven human carcinogen) to E (no evidence of human
carcinogenicity). Representative substances modeled in this analysis were perchlorethylene (B2, probable human carcinogen) and 1,1,1 trichlorethane (not currently classified).
Health risk estimates are uncertain and are more likely to overstate the risks than to understate them (see text).
2. Estimated economic value of similar quantities of water may be different, because the estimated value of water rises as TOTAL volume affected (well production and cleanup
impacts) increases.
SOURCE: ICF, Inc., Revised Evaluation of Alternative Groundwater Cleanup Policies for the Santa Clara Valley Groundwater Basin: Exposure, Risks, and EOA, Inc., Valuation
of Resource Impacts, June 1987. Tables C-6A - C6H
EOA, Inc.. Evaluation of Alternative Groundwater Cleanup Policies. June 1987, Tables 12-15, 20.
-------
COMPARISON OF CLEAN-UP POLICIES
LOCAL COSTS Local rather than social costs, other assumptions as in base case
TABLE 3-9
CLEANUP POLICIES
Confining Layer Effective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Cleanup
Confining Layer Ineffective
Maximum Cleanup
Variable I
Variable II
Variable HI
Standards
Minimum Clean-Up
mmM&mmmimijamffl&m
^^^Sa^S^^wsSS^^Sm^SSSSmSssSsSaSSSK
BENEFITS OF CLEANUP
Risk
Avoided
Est. cancer
cases in 70
years1
7
7
4
7
7
0
31
25
3
31
25
0
GW Saved
From Con-
tamination
1000 acre-ft.,
greatest extent
in 30 years
693
481
374
434
183
0
693
481
374
434
183
0
MUtflMWMBJtpty^
DW Well Production
Saved: 2
1000 acre-ft $ millions
over 70 years
404 22
404 22
404 22
404 NA
404 22
0 0
1815 73
1748 71
404 -11
1815 NA
COSTS OF CLEANUP
GW Pumped in Cleanup: 2
1000 acre-ft. $ millions
over 70 years
7434 846
7180 811
6941 756
2377 NA
2159 427
0 0
7434 846
7180 813
6941 761
2377 NA
1815 75 I 2159 430
0 0 1 0 0
Direct Costs
of Cleanup
$ millions over
70 years
213
208
193
142
117
0
213
208
193
142
NET
BENEFITS
$ millions over
70 years
($1,037)
($997)
($927)
NA
($522)
$0
($986)
($950)
($965)
NA
117 ($472)
0 I ,„.„„„ $0
U)
I
CT\
IMPACTS UNDER
MINIMUM CLEANUP
Confining Layer Effective
Confining Layer Ineffective
RISK
Cancer Cases
7
31
GW CON-
TAMINA-
1000-acre-fL
1082
1082
DW WELL
PRODUCTION LOST
1000-acre-ft. $ millions
414 24
1903 93
GW PUMPED IN
CLEANUP: 2
1000 acre-ft. $ millions
0 0
0 0
DIRECT COSTS
OF CLEANUP
$ millions
0
0
1. Weight of evidence for carcinogenicity of compounds observed in ground water in Santa Clara Valley ranges from A (proven human carcinogen) to E (no evidence of human
carcinogenicity). Representative substances modeled in this analysis were perchlorethylene (B2, probable human carcinogen) and 1,1,1 trichlorethane (not currently classified).
Health risk estimates are uncertain and are more likely to overstate the risks than to understate them (see text).
2. Estimated economic value of similar quantities of water may be different, because the estimated value of water rises as TOTAL volume affected (well production and cleanup
impacts) increases.
SOURCE: ICF, Inc., Revised Evaluation of Alternative Groundwater Cleanup Policies for the Santa Clara Valley Groundwater Basin: Exposure, Risks, and EOA, Inc.. Valuation
of Resource Impacts. June 1987. Tables C-6A - C6H
EOA, Inc.. Evaluation of Alternative Groundwater Cleanup Policies, June 1987, Tables 12-15,20.
-------
COMPARISON OF CLEAN-UP POLICIES
3% DISCOUNT RATE All other assumptions as in base case
TABLE 3-10
CLEANUP POLICIES
Confining Layer Effective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Cleanup
Confining Layer Ineffective
Maximum Cleanup
Variable I
Variable II
Variable III
Standards
Minimum Clean-Up
BENEFITS OF CLEANUP
Risk
Avoided
Est. cancer
cases in 70
years'
7
7
4
7
7
0
31
25
3
31
25
0
GW Saved
From Con-
tamination
1000 acre-ft.,
greatest extent
in 30 years
693
481
374
434
183
0
693
481
374
434
183
0
nhlllll III IIIIJULmiMlimi
DW Well Production
Saved: 2
1000 acre-ft. $ millions
over 70 years
404 56
404 56
404 56
404 NA
404 56
0 0
1815 210
1748 188
404 10
1815 NA
1815 198
0 0
COSTS OF CLEANUP
GW Pumped in Cleanup: 2
1000 acre-ft. $ millions
over 70 years
7434 1350
7180 1291
6941 1225
2377 NA
2159 478
0 0
7434 1366
7180 1293
6941 1254
2377 NA
2159 483
0 0
Direct Costs
of Cleanup
$ millions over
70 years
350
344
327
142
136
0
351
344
327
142
136
NET
BENEFITS
$ millions over
70 years
($1,644)
($1,579)
($1,496)
NA
($558)
$0
($1,507)
($1,499)
($1,571)
NA
($421)
0 1 $0
ffl!l!!»SSSSli!l!^^»
(Ti
00
IMPACTS UNDER
MINIMUM CLEANUP
Confining Layer Effective
Confining Layer Ineffective
RISK
Cancer Cases
7
31
GW CON-
TAMINA-
1000-acre-fL
1082
1082
DW WELL
PRODUCTION LOST
1000-acre-ft. $ millions
414 3
1903 582
GW PUMPED IN
CLEANUP: 2
1000 acre-ft $ millions
0 0
0 0
DIRECT COSTS
OF CLEANUP
$ millions
0
0
1. Weight of evidence for carcinogenicity of compounds observed in groundwater in Santa Clara Valley ranges from A (proven human carcinogen) to E (no evidence of human
carcinogenicity). Representative substances modeled in this analysis were perchlorethylene (B2, probable human carcinogen) and 1,1,1 trichlorelhane (not currently classified).
Health risk estimates are uncertain and are more likely to overstate the risks than to understate them (see text).
2. Estimated economic value of similar quantities of water may be different, because the estimated value of water rises as TOTAL volume affected (well production and cleanup
impacts) increases.
SOURCE: ICF, Inc., Revised Evaluation of Alternative Groundwater Cleanup Policies for the Santa Clara Valley Groundwater Basin: Exposure, Risks, and EOA, Inc., Valuation
of Resource Impacts, June 1987. Tables C-6A - C6H
EOA, Inc.. Evaluation of Alternative Groundwater Cleanup Policies, June 1987. Tables 12-15. 2O.
-------
3-69
Effects by Zone
An important objective of this analysis was to identify the
the effects of different cleanup programs in different hydro-
geologic zones. Insight into differences by zone is given by
examining the three variable cleanup policies. In addition,
selected impacts broken down by zone are presented in Tables 3-11
and 3-12.
o Bay Muds. Risk and resource impacts are lowest in
this zone. While the costs of aggressive cleanup
are relatively low, the benefits of stringent cleanup
are also small compared to other portions of the
basin.
o Confined Zone. The benefits of cleanup depend on the
effectiveness of the confining layer. This zone may
be the most cost-effective area to concentrate
aggressive cleanup efforts, particularly if the confin-
ing layer is ineffective (compare Variable III to
Variable I and II).
o Recharge Zone. The Recharge Zone presents a Hobson's
choice between fast-spreading, extensive contamination
(see Table 3-11) and very costly, water-intensive
cleanup (see Table 3_^12). The high costs of Variable
Cleanup Policies I and II underline this policy
dilemma. Even allowing for possible overestimation
of cleanup water use and costs, it is clear that
resource impacts are greatest in the Recharge Zone,
where policy-makers face a difficult trade-off.
Treating Versus Closing Wells
Whatever cleanup policy is chosen, some drinking water
wells will inevitably be contaminated. (38 large public supply
wells have already been contaminated.) An important question
facing policy-makers is whether to close wells contaminated
above action levels, or, alternatively, to reduce contamination
by treatment, such as with granular activated carbon (GAC).
Well closure entails a cost for obtaining replacement surface
water (or groundwater) supplies, as well as exposure to
whatever contaminants are present in the replacement water.
Treatment, on the other hand, involves a cost too, as well as
a residual risk from exposure to low levels of contaminants
remaining in treated water.
Table 3-13 presents the results of such a comparison.
Perhaps surprisingly, widespread treatment may be more
costly than obtaining replacement supplies. Also, closure is
projected to entail a greater risk than treatment, since users
-------
3-70
TABLE 3-11
ZONE-BY-ZONE ANALYSIS OF THE IMPACTS OF CONTAMINATION
VOLUMES OF WATER CONTAMINATED
(acre-ft. and duration of contamination in years)
Hydrogeologic
Zone
Muds
-acre-ft.1
-years
Confined
-acre-ft.1
Recharge SE
-acre-ft.
-years
Recharge NW
-acre-ft.
-years
Soil Only
3300
>30
531,000
>30
Cleanup Level
SOppb/Standards Non-Detectable
2600
>30
406,000
29
471,000
>30
19,000
>30
1600
8
204,000
17
178,000
30
5,800
16
1 This figure is for groundwater above the confining layer only.
If the confining layer is permeable or is breached additional
water will be contaminated.
Source; "Evaluation of Alternative Groundwater Clean-up Policies,
Part IIA (EOA), Appendix 4, 4-3, 4-4.
-------
3-71
TABLE 3-12
ZONE BY ZONE ANALYSIS
RESOURCE LOSSES1
(close wells at standards)
(thousand acre.-ft./70 years)
Hydrogeologic Clean-up Level
Zone
Soil only 55 ppb/standards
Bay Muds
Confined
Recharge
Recharge
Confining
eff2
0*
0*
SE NA
NW NA
Layer:
not3
69
1,421
390*
24*
Confining
eff2
21
240
NA 1
NA
Layer:
not3
21*
317
,858
50
Non- detect able
Conf ini
eff2
36
458
NA
NA
ng Layer:
not3
36
535
6,764
187
* Indicates the lowest resources losses of the three clean-up levels
1 Resource losses = quantity of water pumped through clean-up plus
quantity of water lost when wells are closed.
2 Confining layer 100% effective in protecting public wells in
muds and confined zone.
3 Confining layer not effective, therefore all public wells
below confining layer are affected.
Source; "Evaluation of Alternative Groundwater Clean-up Policies,
Part II, B(ICF), Appendix C, Tables 3-G, 3-F.
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TABLE 3-13
WELLHEAD TREATMENT
Comparison of costs and risks associated with treatment of well water above standards with
those associated with well closure at standards and replacement of well water with surface
water.
MAXIMUM CLEANUP
STANDARDS
Confining Layer Effective
Treatment
Closure
Confining Layer Ineffective
Treatment
Closure
Risk
EsL cancer cases
in 70 years
0
0
0
2
Cost
$ million, total
over 70 years
9
2
52
19
Risk
Est. cancer cases
in 70 years
0
0
1
8
Cost
$ million, total
over 70 years
117
2
241
17
SOURCE: ICF, Inc., Aquifer Management Project: Santa Clara Valley Integrated
Environmental Management Project, June 1987. Tables C-5A - C-51, C-3E.2, C-3H
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of closed wells are assumed to be provided with surface water
replacement supplies (which present a risk of cancer from
THMs).
This analysis is only preliminary. It was not based on
site-specific engineering estimates or evaluation of likely
replacement supplies for particular wells. Thus, the cost and
risk impact of treatment versus closure should be evaluated on
a case-by-case basis.
Conclusion
This analysis demonstrates the importance of examining
the resource, in addition to health risk, impacts of ground-
water contamination and cleanup policies. The analysis also
highlights some key data gaps (e.g., the effectiveness of the
confining layer) and some difficult policy choices (e.g.,
cleanup requirements in the Recharge Zone). The analysis
provides information on the health risks, direct costs and
natural resource impacts of different cleanup regimes, which
should be useful as cleanup policy is developed for the Santa
Clara Valley. Further development of this approach,
particularly examination of additional cleanup policies and
more reliable prediction of the aquiferwide water impacts of
cleanup, would be desirable next steps in setting policy.
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ACTION PLAN FOR AQUIFER MANAGEMENT
The IEMP presents the following recommendations on Aquifer
Management in the Santa Clara Valley. These recommendations
were developed by the Drinking Water Subcommittee, and reviewed
and approved by the PAC and ICC. The recommendations are based
on the findings of the SCVWD report entitled "Groundwater Manage-
ment in Santa Clara Valley," the EPA report entitled "Evaluation
of Alternative Ground Water Cleanup Policies for the Santa Clara
Valley Groundwater Basin," and the experience and expertise of
Subcommittee and Committee members.
"Aquifer Management" is a broad term referring to the co-
ordinated planning and implementation of a set of management
activities that collectively attempt to provide for optimal use
and preservation of local groundwater resources. Management
objectives include production of adequate quantities of local
water and preservation of the quality of that water. Water
quantity and water quality objectives are interrelated.
Preservation of the groundwater resource from degradation is
necessary to assure adequate quantities for use, as well as to
protect against health risk.
The IEMP participants' findings and recommendations presented
below include suggested priorities for specific types of
activities under the headings Overall Basin Management, Cleanup
and Prevention of Contamination.
Each recommendation is directed at an agency or agencies.
Overall, the recommendations are directed at the agencies
primarily responsible for Santa Clara Valley groundwater
management; the Santa Clara Valley Water District (SCVWD),
the Regional Water Quality Control Board (RWQCB), EPA and
Santa Clara County and constituent cities.
Overall Basin Management
The IEMP finds that the groundwater of the Santa
Clara Valley basin constitutes a unique and highly valuable
natural resource. Local groundwater not only serves as a stock
of high quality drinking water, but also provides a natural
storage, distribution, and treatment system. The IEMP
believes that the EPA Aquifer Management Study has demonstrated
the importance of assessing groundwater resource impacts, in
addition to health risks and other costs, when evaluating
cleanup alternatives and other aquifer management policies.
Of course, other criteria are also important, such as fairness,
the obligation of a responsible party for cleaning up a
contaminated public resource, and an appropriately open process
for arriving at decisions.
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The IEMP also finds that both the EPA and SCVWD
Aquifer Management studies have demonstrated the importance
of employing a basin-wide approach to managing the entire
groundwater system. Because of competing demands for the use
of the groundwater resource and its vulnerability to degradation,
the groundwater basin must be managed carefully if it is to
provide the maximum beneficial use to Santa Clara Valley residents,
In particular, the cumulative effects of proposed cleanup
target levels should be assessed basin-wide instead of allowing
cleanup precedent to be established through site-by-site
decisions. Basin-wide analysis is also potentially important
for setting cleanup priorities, managing hydrologically
connected plumes, and integrating cleanup with other management
activities, such as well pumping, artificial recharge and
conduit well sealing.
The IEMP therefore makes the following recommendations:
Policy Analysis and Management
1. The RWQCB and EPA Superfund, in cooperation with the SCVWD,
should employ the method developed in the EPA Aquifer Manage-
ment Study, or an equivalent technique, for further evalu-
ation of the aquifer-wide impacts of cleanup policies. The
approach should examine the natural resource impact, health
risk and direct cost of alternative policies. This basin-wide
policy analysis should be used to develop overall decision
guidelines to guide cleanup decisions at specific sites.
In assessing the impacts of different cleanup policies
basin-wide, these agencies should assess policies in
addition to those examined in the EPA study. For example,
the impacts of cleanup to proposed levels between drinking
water standards and maximum feasible cleanup should be
studied. Cleanup policy assessment would be greatly
aided by development of a basin-wide groundwater model
(see #9 below). Possible support for this activity should be
explored through EPA's Superfund Multi-site Cooperative
Agreement with the RWQCB.
2. The San Francisco Bay and Central Coast RWQCBs, in cooperation
with the SCVWD, should assess the basin-wide impact of fuel
contamination (particularly from underground tanks) and
remediation options. (The EPA Aquifer Management Study
addressed only industrial contamination and cleanup options.)
Support for this activity might be obtained through grants
from EPA's UST program, administered by the State Water
Resources Control Board.
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3. The SCVWD should use the technique developed in the EPA
studyf or an equivalent method, for assessment of the aquifer-
wide impacts of aquifer management policies other than
cleanup, such as conduit well sealing and zoning to protect
sensitive areas.
4. In future integrated environmental management effortsf the
EPA should use a method of setting priorities that examines
both the risk and natural resource effects of groundwater
contamination.
5. The State Water Resources Control Board should revise
the State Groundwater Strategy to incorporate groundwater
quantity considerations/ in addition to its current focus
on groundwater quality. Effective groundwater management
must address both objectives in an integrated way. The
EPA Aquifer Management Study provides a framework for
management of both the quantity and quality of groundwater.
6. In the future, larger amounts of imported water will be
available for recharge in the Santa Clara Valley and the
effect of each recharge facility on groundwater levels will
become more important. Therefore, the SCVWD should evaluate
the maximum capability of each recharge facility with a view
toward future coordinated operation of the facilities to
achieve optimal basin management.
7. The SCVWD, in conjunction with the water purveyors,
should prepare contingency plans for operation of water
sources and water distribution systems under emergency
conditions. The potential exists for an emergency situation
wherein a substantial loss of available water might occur.
Five situations, for example, can be imagined: loss of a
portion of the groundwater storage due to contamination, loss
of imported water due to an earthquake, severe cutbacks on
imported water due to a statewide drought, and contamination
of recharge facilities through sabotage or vehicle
accidents (e.g. tanker trucks overturning and leaking their
contents into recharge ponds). Should such an event occur,
it will be important that plans exist for appropriate
responses by the District and the purveyors.
Management Tools and Data Needs
8. The SCVWD, in cooperation with the RWQCB, should collect
and interpret hydrogeologic data from individual cleanup
sites and other sources, allowing for a better projection of
aquifer-wide impacts of groundwater contamination and cleanup.
Better hydrogeologic data will assist in other aquifer manage-
ment activities as well. Some support for these activities
might be obtained through the EPA/RWQCB Multi-site Cooperative
Agreement, or through EPA's UST program.
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Specifically, the District and RWQCB should:
o Collect information allowing a better characterization
of the likely effectiveness of the major confining layer
in preventing contaminant transport. Such information is
critical in determining the importance of agressive
cleanup in the confined zone.
o Compile information from individual fuel contamination
sites and prepare regional site and plume maps describing
the dissolved constituents present in groundwater.
o Develop a gradually expanded groundwater level monitoring
program, in which some of the 250 currently monitored
water supply wells are replaced with permanent monitoring
wells.
9. The SCVWD should develop a predictive groundwater basin model
as an integral part of groundwater planning and management.
The basin model should be used to test hypotheses about how
the basin functions, to identify critical data gaps, and
to assist in projecting changes in the groundwater basin.
An aquifer-wide model could be a central tool for aquifer
management, providing the basis for input/output management,
projection of recharge needs, drought planning, and the
prevention of subsidence and saltwater intrusion. The
SCVWD has begun to develop such a model, and should
assess the its feasibility and usefulness. If appropriate,
these efforts should be continued, with a long term com-
mitment to refining and maintaining the model. Additional
support might be provided by EPA Superfund, through the Multi-
site Cooperative Agreement with the RWOCB or through
EPA's Office of Groundwater.
10. The existence of the SCVWD's library of drinking water and
groundwater information should be publicized. A wealth of
information exists related to groundwater conditions generated
by sources including the SCVWD, the Gavilan Water District,
consultants, industry, local jurisdictions, purveyors,
regulators, and task forces. The District has established a
library of this information that is available to interested
parties and the general public.
Cleanup
The IEMP finds that, while a state groundwater cleanup
policy exists (in the form of the SWRCB's "Statement of
Policy with Respect to Maintaining High Quality of Waters in
California," Resolution 68-16,) no clear consensus exists as
to the application of this policy. Similar uncertainty
exists as to target cleanup levels applicable to all sites
under Federal Superfund law.
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In attempting to address the need for more concrete clean-
up guidance, the IEMP finds it inappropriate to recommend
uniform target cleanup levels because cleanup costs and contamin-
ation impacts vary significantly from site to site, making no
one cleanup level appropriate for all situations. In addition,
cleanup decisions involve value judgments trading off competing
social objectives, so that no objectively "right" cleanup
target exists.
Despite the lack of an easy answer to the "how clean is
clean" question, the IEMP believes that recommendations
offered below will assist in developing a sensible and consistent
cleanup policy.
11. Because contamination and cleanup impacts vary significantly
in different sites and different hydrogeologic zones, the
RWQCBs should continue to develop and standardize a process
for cleanup decision-making, consistent with Resolution 68-16,
rather than establish across-the-board cleanup levels.
This process for establishing priorities and making decisions
should be flexible, but should be guided by overall policy
guidelines, developed under recommendations #1 and #2.
Site-specific decision-making should explicitly weigh the
appropriate factors such as health risk, groundwater
resource impact and direct cost, as developed in the EPA
Aquifer Management Study. It should also consider other
important but less tangible factors, such as fairness, due
process, and the responsibility incurred by damaging a
public resource.
12. The EPA, DOHS, RWQCB and responsible parties should develop
innovative cleanup strategies that involve lower resource
impacts. Ways to mitigate the resource impacts of cleanup
should be explored where the resource costs of cleanup are
high. For example, the costs, benefits and risks of recharg-
ing used cleanup water should probably be routinely examined.
Such recharge may not always justify the cost, however, and
raises the issue of introducing water contaminated at low
levels into clean sections of the aquifer. These impacts
could be estimated quantitatively in specific cases as an
aid to decision-making. Experimental techniques, such as
in situ biological treatment, should be further investigated.
13. Effective means of minimizing exposure at drinking water
wells should be in place, since some residual contamination
seems likely regardless of cleanup strategy. Currently, the
major gap in regulatory protection is private wells, for which
recommendations have been developed separately by the Drinking
Water Subcommittee. Treatment of contaminated wells may also
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be an appropriate policy to consider on a site by site basis,
either because of cost savings relative to replacing supplies
(although preliminary analysis suggests that replacement may
often be cheaper) or because of lower expected risk (where
the replacement supply is surface water containing THMs).
14. Where restoration of the aquifer is too costly (in direct
costs and/or resource impacts) or technically infeasible,
it may be useful to explore means of having responsible
parties fund measures that mitigate or compensate for the
residual impacts of their contamination. RPs could directly
address impacts of their contaminant plumes, or could
contribute to a fund that financed actions benefitting the
aquifer system.
Measures that might be financed in this way include:
treatment at public or private wells;
- conduit well sealing;
additional recharge facilities;
fuel tank program/follow-up;
collection of critical hydrogeologic information/-
database management;
basin-wide monitoring;
where these actions would have greater benefit than
attempted restoration.
Funding of the types of activities listed above as
compensation for residual damage to groundwater resources
clearly raises a number of legal and practical questions
that remain to be explored. Issues must be addressed such
as the adequacy of legal authority to arrive at such
settlements, the identification of an appropriate
administering agency, the creation of an equitable formula
for arriving at compensation, and the provision of some
certainty that a given settlement will not later be
reopened.
15. The SCVWD, The RWQCB, and the DOHS should develop and im-
plement coordinated activities in specially designated manage-
ment zones. Management zones are defined as areas within the
Santa Clara Valley where major groundwater resources occur
together with industrial areas and known groundwater contamina-
tion. Such areas are the most vulnerable to contamination of
groundwater resources. In the confined portion of the basin,
contamination is largely limited to the overlying unconfined
aquifer, while in the unconfined portion, the productive
aquifer is directly affected. To avoid loss of the use of
groundwater resources in these critical areas, attention must
be given to the control of existing contamination by the
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following activities: construction standards for new wells,
pumpage rates, and well siting. Presently, three separate
agencies share responsibility for elements of these
activities: DOHS, the RWQCB and the SCVWD. This Subcommittee
recommends that the District take the lead in coordinating
these activities with DOHS and RWQCB, with special attention
to high-risk management zones. Potential management zones
are identified in the SCVWD Aquifer Management Study.
Prevention of Contamination
The IEMP finds that the prevention of groundwater
contamination and the management of existing plumes is a critical
aspect of aquifer management. The EPA and SCVWD aquifer manage-
ment studies show that the impact of contamination can be
particularly severe in the sensitive Recharge Zone. Once
contamination has occurred in this area, one is faced with a
choice between extensive, low-level contamination on the one
hand and large resource impacts of cleanup on the other.
16. The SCVWD, RWQCB, EPA, the County and cities should make
prevention of further contamination of the Recharge Zone
a high priority. This suggests that it is probably important
to identify and map these areas carefully, and take steps
to protect them. It may be appropriate to target fuel
tank investigation and remediation efforts so that these
areas receive first attention. Zoning or other land-use
policies to prevent high-risk activities should be explored
(see recommendation #17).
17. The SCVWD, in cooperation with the cities and County of the
Santa Clara Valley, should study and implement protection
zones where groundwater is vulnerable but there is currently
little opportunity for contamination. Protection zones
should be targeted to areas that contain productive aquifers
and where future urbanization could adversely affect ground-
water resources. Protection zones should also be developed
and implemented in the high risk areas in the forebay zone
where industrial or other sources of contamination presently
exist. The SCVWD Aquifer Management Study provides maps of
the sensitive areas requiring special protection.
Protection zones should be implemented through narrowly
focused regulations that restrict the activities that pose
the greatest threats to groundwater quality. Protection
zone requirement could be in the form of either (1) more
stringent HMSOs (i.e. more frequent inspections and/or
reporting, prohibition of underground tanks, increased
monitoring), or (2) land use designations (i.e. establishing
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criteria for land use, restriction of certain chemicals).
The possibility of funding this activity through EPA's new
Wellhead Protection Program, which will result in grants to
the State for wellhead protection, should be explored.
18. Given the high number of conduit wells near contaminant
plumes, the SCVWD should accelerate the program to complete
the sealing of all targeted wells. In addition, as new solvent
sites and high density fuel leak areas are identified, the
program should be modified to include these areas. The
current EPA Superfund/RWQCB Multi-site Cooperative Agreement
(MSCA) provided funds for identification of current and
abandoned wells. Continued support for this activity
under the MSCA should be explored.
19. The DOHS and the SCVWD should continue to work cooperatively
to assure that all future wells are properly sited, screened,
and sealed in order to reduce the potential for contamination
of potable water supplies.
20. The cities and County of Santa Clara should encourage the
full implementation of their HMSOs by their respective target
dates. The HMSO program provides an essential first line of
defense against groundwater contamination.
21. The County, cities and SCVWD should work together to
investigate existing dry wells and to prohibit the
construction of any new dry wells. Dry wells have been
confirmed as conduits for groundwater contamination, and
should therefore be systematically removed and prohibited.
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REDUCTION OF TRIHALOMETHANES IN DRINKING WATER
SUMMARY OF ANALYSIS
Objective of the Report
The objective of this project was to compile and present
available information on the risks, regulatory activity, and
potential cost-effectiveness of controls for trihalomethanes
(THMs) in drinking water.
Background and Scope
Introduction
THMs in drinking water was the class of pollutants
identified in the Stage I IEMP risk assessment report that
represented the single largest health risk. The IEMP Drinking
Water Subcommittee decided, however, that the logical
follow-up to the Stage I finding was being conducted by the
Santa Clara Valley Water District's (SCVWD) THM control
alternatives investigation. Therefore, the IEMP did not
conduct its own THM risk management research as part of Stage II,
This document summarizes the THM issue in Santa Clara
County. It presents a brief technical background and a summary
of the results from Stage I. This section is followed by
discussions of THM toxicology, available control strategies,
and the current activities by the local agencies responsible
for surface water quality. Finally, a few recommendations
for local action are presented.
The information in this paper came from the IEMP Stage I
report, SCVWD's THM alternatives investigation, two IEMP
staff memorandums to the IEMP Drinking Water Subcommittee,
and a subcommittee discussion of the issue (March 20, 1987).
(See bibliography for references.)
Source of THMs
There are five types of disease-producing organisms
commonly found in surface water: bacteria, protozoa, worms,
viruses and fungi. The addition of disinfectants such as
chlorine, chloramine (chlorine plus ammonia), ozone, and
chlorine dioxide is the primary form of protection from these
pathogens. However, other unit processes such as coagulation,
filtration, and sedimentation can also provide substantial
reduction in health risk, primarily by physically removing
the microbes.
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Chlorine is by far the most prevalent disinfectant used
nationwide. Figure 3-4 shows a clear relationship between the
the increase of water treatment plants using chlorine and the
decrease in waterborne disease over the period from 1910 to
I960. However, in addition to protecting people from exposure
to pathogens, chlorine reacts with organic matter present in
the water to form THMs, a class of volatile organic chemicals,
including chloroform, bromoform, dichlorobromomethane, and
chlorodibromomethane.
Chloroform is considered by EPA to be an animal carcinogen
and a probable human carcinogen, and the other THMs are
assumed to be equivalently toxic.
Surface Water Delivery in the Valley
The South Bay Aqueduct delivers water from the Sacramento-
San Joaquin Delta to the SCVWD. The water is chemically
treated and disinfected at the Penitencia and Rinconada
treatment plants. The SCVWD then sells the water to various
city-owned and investor-owned water purveyors who distribute
it to approximately 370,000 people.
The San Francisco Water Department (SFWD) owns and operates
the Hetch-Hetchy distribution system, which delivers water from
the Sierras to the Santa Clara Valley, parts of Alameda County,
the Peninsula, and San Francisco. Hetch-Hetchy water serves
approximately 212,000 Santa Clara Valley residents through
several city-owned water utilities in the northern part of
the Valley.
THM Risks Estimated in Stage I.
Following the methodology of EPA's Office of Drinking
Water, the IEMP Stage I analysis used the Cancer Assessment
Group's (CAG) cancer potency score for chloroform, and applied
it to all four THMs. These compounds are also suspected to
present various non-cancer health risks, but only at levels
significantly above the 100 ug/1 regulatory standard (Maximum
Contaminant Level, or MCL).
The upper bound estimated increase in cancer incidence
caused by exposure to THMs in the IEMP study area was just
over one case per year. Since SCVWD surface water serves
almost twice as many Santa Clara County residents as does the
SFWD's water and since SCVWD THM levels are slightly higher,
roughly 2/3 of the total THM risk was attributed to SCVWD
water, and the remaining 1/3 to SFWD.
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3-84
Figure 3-4
New Concepts In Water Purification
250r
WATERBORNE
DISEASES
NO. OF
PLANTS
CHLORINATING
-I 0.000
8,000
si
- 6.000
DO
u. Z
- «.000 c
li
53
- 2.000
1910 1920 1930 1940 1950 I960
YEAR
Average annual number of waterborne disease outbreaks 1920-1960 and the
number of water plants using chlorine.
From: Gulp, New Concepts in Water Purification, Van Nostrand
Reinhold Conpany, New York, 1974
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3-85
Health risk attributed to THMs in Stage I only accounts
for exposure by ingestion of water. It does not include
exposure by inhalation of THMs that have volatilized out of
water in showers, saunas, water treatment plants, etc.
Inhalation may present significant health risk, and EPA plans
to list chloroform as a hazardous air pollutant (under Section
112 of the Clean Air Act) next year. However, not all chlorine
sources (e.g. showers) will be regulated.
The relatively high risk that THMs present in Santa Clara
County is not due to water purveyors serving water with
THMs exceeding the regulatory standard, but because the stand-
ard is set relatively high. Specifically, chronic exposure
to water with THM concentrations at the acceptable 100 ug/1
level results in a conservative upper bound lifetime risk
estimate of contracting cancer at 200 chances in one million.
EPA set the MCL this high in 1979 because, at that time,
achieving significally lower THM levels while still protecting
against pathogens was viewed as infeasible at reasonable
cost. Over the past decade, the cost-effectiveness of THM
control has improved.
Updated Toxicology Information
The present CAG score for chloroform (and thus THMs) is
based on a 1976 National Cancer Institute (NCI) study that
found a statistically increased incidence of tumors and carci-
nomas in mice and rats gavaged (injected directly into the
stomach) with chloroform dissolved in corn oil. Assuming an
equivalent dose/response relationship in humans and conserva-
tive exposure estimates, ambient concentrations of 0.5 ug/1
result in a one in one million excess lifetime risk of cancer.
EPA's Office of Drinking Water (ODW) recently proposed
that the CAG score be revised, based on the 1985 Jorgenson
study instead of the NCI. Jorgenson et al., administered
chloroform in drinking water to rats and mice and observed
lower levels of tumor incidence. If, as proposed by ODW, the
Jorgenson data on rat tumors is used to predict potency in
people, a one in one million risk would result at THM concen-
trations of 6 ug/1. Thus, if the newer bioassay study were
used as the basis for estimating chloroform's carcinogenic
potency, THMs would be treated as twelve times less toxic
than they were in the IEMP Stage I Report.
The initial findings of the Jorgenson study were available
when CAG set the current potency score. However, CAG used
the NCI study to conform with their policy of basing potency
values on the most sensitive animal population. CAG may,
however, reevaluate its position and follow ODW in using the
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Jorgenson study because the exposure mechanism in the NCI
study (gavaging THMs dissolved in corn oil) may yield
results not directly relevant to human exposures to THMs in
drinking water. This issue is still under review within EPA.
If the newer toxicity information had been used in Stage I,
exposure to existing levels of THMs would result in an estimated
increased cancer incidence of 0.1 instead of 1.3 cases per
year. Consequently, THMs would fall in the Stage I risk rank-
ing from first to sixth—behind benzene, carbon tetrachloride,
organic particulates, chromium, and arsenic.
Upcoming changes in THM Regulation
The current MCL for total trihalomethanes (TTHM) is 100
ug/1. However, ODW is undertaking a thorough examination of
the costs and benefits of disinfection technologies, and
intends to promulgate a new MCL in 1991. Water served in Santa
Clara County averages approximately 70 ug/1 TTHM for SCVWD
and 60 ug/1 TTHM for SFWD.
The one in one million lifetime risk level is often cited
as a target in promulgating EPA regulations. If this target
is used in setting the new THM MCL, 6 ug/1 would be the log-
ical standard based on the Jorgenson study. However, drinking
water regulations are often technology based, and the new THM
regulation may be derived from the concentrations achievable
with a specific technology (e.g., granular activated carbon
adsorption). If so, the MCL may be somewhat higher or lower
than 6 ug/1. Regardless of the precise value, EPA's current
assessment of disinfection technologies will probably reduce
the MCL below current ambient levels, even in light of the
possibility of a reduced toxicity estimate.
Possible Approaches to Reducing THM Levels
There are three approaches to reducing THM levels caused
by chlorination:
1) Remove THM precursors before chlorination;
2) Partially or entirely shift to an alternative disin-
fectant, (e.g. ozone, chloramine, etc. produce
THMs at lower levels than chlorine); and
3) Remove THMs after they are formed.
Removal of THM precursors
Reduced levels of organic matter result in reduced levels
of THM precursors that react with chlorine and form THMs.
During filtration, water flows through a porous medium (e.g.,
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sand, carbon, or diatomite) which removes suspended particles.
Other unit processes, such as coagulation, flocculation, and
sedimentation can facilitate the removal of suspended particles.
Coagulation involves the addition of a substance, such as
alum, which congeals particles and increases their size and
weight. Flocculation entails mixing water to facilitate the
coagulation of the suspended particles. Sedimentation means
settling the water so that the suspended particles drop to
the bottom of the container and the water becomes clarified.
Filtration technologies can provide considerable direct
protection against pathogens in addition to removing THM pre-
cursors. Water subject to algae growth must be oxidized
before filtration or the algae will clog the filters. But
where filtration can be used before chlorination, THM levels
are reduced in two ways: (1) filtration reduces THM precursors,
and (2) filtration reduces pathogens, thus lowering the level
of chlorination needed.
Alternative disinfectants
Disinfectants that produce lower THM levels (if they
produce any at all) can be substituted for chlorine. Chlorine
dioxide is a strong disinfectant that can be inexpensively
prepared and fed into the water at existing treatment facili-
ties. Ozone also functions well, but is more expensive and
requires the construction of feed facilities. Chloramine is
a weaker disinfectant but is inexpensive and easily injected
into the water.
A major disadvantage of using alternative disinfectants
to control THM concentrations is that they are themselves
oxidants, and produce other organic by-products. The health
effects of these by-products are poorly understood, and
little evidence exists to indicate whether they are more or
less dangerous than the by-products of chlorination. Addi-
tionally, each of the disinfectants itself has inherent
disadvantages. For example, ozonation does not leave a
residual to continue disinfection in the distribution system;
chloramine may itself be toxic; and chlorine dioxide produces
chlorite and chlorate, which are suspected toxins. Given the
toxicological uncertainties, the California Department of
Health Services (DOHS) has ruled that the residual concentrations
of chlorine dioxide, chlorite, and chlorate must be less than
1 mg/1 following treatment.
Finally, water is used for many purposes, and changes in
the chemical composition of tap water can have an array of
effects. For example, chloramines have resulted in problems
for dialysis machines and for fish maintained in tap water.
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3-88
Removal of THMs
A general drawback to THM removal is that THM formation
is not instantaneous, and precursors remaining in the water
after the removal process can react with remaining free
chlorine to form more THMs. Aeration and granular activated
carbon (GAC) adsorption facilities are considered the most
efficient. Unfortunately, they are expensive to construct
and to operate.
Current THM Reduction Activities
Santa Clara Valley Water District.
In an effort to reduce THM levels, the SCVWD has switched
from a full chlorination system to pre-chlorination/post-chlor-
amination at both Rinconada and Penitencia. After water passes
through their filtration facilities, it is now chloraminated
instead of chlorinated, resulting in THM reductions of up to 30%.
In addition, the District performed an in-depth analysis
of THM reduction alternatives, documented in the 200 page
THM Control Alternatives Investigation report. The District
is now proposing to spend an additional $1 million to follow
this study with construction of a pilot ozonation plant in
series with the Rinconada treatment facility. A reformatted
version of the results of the SCVWD study is presented in
Tables 3-14 and 3-15.
Calculation of cost effectiveness in reducing risk (dol-
lar costs per reduced cancer incidence) is made by comparing
the various alternative treatment technologies to the status
quo. SCVWD has been chloraminating for the last two years.
However, to ease comparison of the six alternatives, complete
chlorination is treated as the status quo.
Chloramination entails a negligible cost increase over
complete chlorination, and reduces risk by roughly 15%. Con-
struction and operation of chlorine dioxide pre-oxidation
facilities at both treatment plants avoids roughly 1/3 the com-
plete chlorination estimated cancer incidence at a 2% increase
in the average water bill ($0.1 million per case avoided).
Ozonation facilities would further reduce THM related risk at
approximately $2 million per case avoided, and is the option
receiving the most serious consideration by the District. Air
stripping and GAC adsorption facilities are more expensive, and
do not seem to offer additional THM or risk reduction. Therefore,
of the controls examined, ozonation appears to achieve the
maximum risk reduction in the least expensive manner.
-------
Table 3-14
Comparison of Candidate Treatment Alternatives
(Rinconada Treatment Plant)
Complete
chlorination (Status Quo)
Prechlorinat ion ,
pos t-chloraminat ion
Pre-ozonat ion
chlorine dioxide,
Pre-oxidation
Air-stripping
GAC- adsorpt ion
Projected
THM
80
70
<1 to <10
50
3 to <10
Estimated
Cancer
Cases
over plant
lifetime*5
12.6
11.1
<0.2 to <1.6
7.9
0.5 to <1.6
3 to <10 0.5 to <1.6
a Kennedy/Jenks/Chilton, Table 1-2
b Steckel, Further Analysis of the
Results of SCVWD1
Estimated
Reduction
in Cases
from
Status Ouoc
1.5
>12.4 to >11.0
4.7
12.1 to >11.0
12.1 to >11.0
s Trihalomethane
Total
Cost
($MM)d
23.0
23.1
49.3
26.7
62.8
Increased
Cost
over
Status
1 Quo ($MM)e
0.1
26.3 <2
3.7
39.8 3
Cost
per
Case
Avoided
($MM/case)f
0.1
.2 to < 2.4
0.8
.3 to < 3.6
Increase
in Water
Bill over
Status
Quo9
0%
13%
1%
19%
u>
i
00
VD
141.8 118.8 9.8 to <10.8 59%
Control Alternatives Investigation,
Memorandum to the IEMP Drinking Water Subcommittee, March, 1987.
c Projected cases per lifetime of complete chlorination facility minus the projected cases per lifetime of
alternative treatment facility.
d Steckel, Further Analys is...
e Cost (Net present worth) of alternative treatment minus the cost (NPW) of complete chlorination.
f "Increased Cost over Status Quo" divided by the "Estimated Reduction in Cases from Status Quo."
5 Steckel, Further Analysis...
NOTE: Because of significant uncertainties in the underlying data and assumptions, these estimates of
individual risk and disease incidence are only rough approximations of actual risk. They are based on
conservative estimates of exposure and potency and are more likely to overestimate risks than to underestimate
them. In addition, these results use the NCI-based CAG score used in Stage I. Cost effectiveness would look
significantly worse if the alternative Jorgenson-based CAG score were adopted.
-------
Table 3-15
Comparison of Candidate Treatment Alternatives
Complete
chlorination (Status Quo)
Prechlorination,
pos t-chlorani nat ion
Pre-ozonat ion
Chlorine dioxide,
pre-oxidat ion
Air stripping
GAC adsorption
Projected
THM
uq/ia
70
60
<1 to <10
40
3 to <10
3 to <10
(Penitencia
Estimated
Cancer
Cases
Over Plant
Lifetime*5
6.0
5.1
<0.1 to <0.9
3.4
0.3 to <0.9
0.3 to <0.9
Treatment Plant)
Estimated
Reduction
in Cases
from
Status QuoC
„-•_ -
0.9
>5.9 to >5.1
2.6
5.7 to >5.1
5.7 to >5.1
Total
Cost
($MM)d
11.6
11.7
22.2
13.5
30.4
70.6
Increased
Cost
Over
Status
Cost Increase
per in Water
Case Bill
over
Avoided Status
Quo ($MM)e ($MM/case)f Ouo9
_ __.__^
0.1
10.6 <1.
1.9
18.8 3.
59.0 10.
_m± — ,
0.1
8 to < 2.1
0.7
3 to < 3.7
4 to <11.6
__
0%
9%
1% I
o
17%
54%
a Kennedy/Jenks/Chilton, Table 1-3
b Steckel, Further Analysis of the Results of SCVWD's
Trihalome thane
Control
Alternatives
Investigation
,
Memorandum to the IEMP Drinkng Water Subcommittee, March, 1987.
c Projected cases per lifetime of complete chlorination facility minus the projected cases per lifetime of
alternative facility.
d Steckel, Further Analysis...
e Cost (Net Present Worth) of alternative treatment minus the cost (NPW) of complete chlorination.
f "Increased Cost over Status Quo" divided by "Estimated Reduction in Cases from Status Quo."
9 Steckel, Further Analysis...
NOTE: Because of significant uncertainties in the underlying data and assumptions, these estimates of individual
risk and disease incidence are only rough approximations of actual risk. They are based on conservative estimates
of exposure and potency and are more likely to overestimate risks than to underestimate them. In addition, these
results use the NCI—based CAG score used in Stage I. Cost effectiveness would look significantly worse if the
alternative .Jorgenson-based CAG score were adopted.
-------
3-91
San Francisco Water Department
With completion of projects funded by a 1985 $104 million
bond issue, SFWD plans to filter two of the three points of
entry into their distribution system (Crystal Springs and San
Andreas). The main Hetch-Hetchy line, which comprises approx-
imately 90% of the blend SFWD supplies to Santa Clara County,
will remain unfiltered. SFWD currently adds lime to the
Hetch-Hetchy water for corrosion control, and then disinfects
with chlorine. Filtration is projected to cost on the order of
a quarter to a half billion dollars and is not planned for
the immediate future. However, Hetch-Hetchy water has relatively
low levels of organic matter and SFWD is able to serve water
with THM concentrations lower than SCVWD despite the fact
that SCVWD has been much more aggressive in reducing THMs.
There are two conditions which may cause the SFWD to
change existing treatment practices and reduce Hetch-Hetchy
THM levels.
1) Recently passed amendments to the Safe
Drinking Water Act (SDWA) require all public
community drinking water supplies with surface
water sources to practice filtration under
appropriate circumstances. (This might include
other unit processes besides or in addition to
direct filtration.) The EPA is charged with
setting the criteria for these "appropriate
circumstances," and is expected to do so in
1988. In addition, DOHS has a policy requiring
full treatment (includes filtration) of all
surface water. However, the State has not yet
required filtration of Hetch-Hetchy water, and
it is unlikely that they will do so before EPA
promulgates the SDWA criteria.
2) EPA expects to reduce the THM MCL in 1991.
This could, theoretically, be followed by an
even more stringent State standard.
The SFWD's policy has been to wait for these regulations
before embarking on expensive construction programs that may
be deemed unnecessary or insufficient. The SDWA criteria may
take the form of performance standards instead of simply a
filtration requirement. If so, SFWD will implement processes,
which may or may not include filtration, to meet the standard.
However, the SFWD has an excellent record of serving high
quality water, and may be exempted from the new requirements
altogether.
-------
3-92
The SFWD similarly intends to comply with the new THM
MCL. They have chosen not to begin construction of a facility
that can achieve 6 ug/1 since some other level may ultimately
be required.
ACTION PLAN FOR THM REDUCTION
The IEMP finds that THMs pose significant health risks in
comparison with other toxic contaminants. Therefore, the
IEMP makes the following recommendations:
1. The San Francisco Water Department should continue working
with the State Department of Health Services (DOHS) and EPA
in promulgating criteria for how and which surface waters
need to be filtered, or otherwise treated, under the Safe
Drinking Water Act (SDWA) amendments. Further treatment
facilities for the main Hetch Hetchy line would serve the dual
purpose of lowering THM levels and lowering the risk from
microbial pathogens, and may be required by regulatory agencies.
Concerned consumers in the Santa Clara Valley—represented by
the county, cities, proposed Toxic Policy Council (see Chapter
Four: Institutional Issues), etc.—should stay abreast of
SFWD activities and provide input and recommendations when
appropriate.
2. The SCVWD should continue efforts at THM reduction, including
cost effectiveness analysis of control strategies, and con-
struction of its pilot ozonation plant. Concerned consumers
in the Valley, represented by County, cities, proposed Toxic
Policy Council, etc., should stay abreast of SCVWD activities
and provide input and recommendations on more permanent,
district-wide treatment decisions when appropriate.
3. EPA should complete its review of the chloroform toxicity
studies and develop a new Cancer Assessment Group (CAG)
score in a timely manner. A new chloroform CAG score will
provide a clear statement of risks to those making decisions
regarding water treatment. Local risk management agencies,
such as the SCVWD, need this information in the near future.
4. DOHS and EPA should promulgate standards in a timely manner
for (a) MCLs for disinfectant byproducts including THMs, and
(b) how and which surface waters need to be treated under the
SDWA amendments. Local agencies are in the process of making
decisions on treatment technologies without clear guidance
from EPA or the State as to future THM limitations. Local
organizations (SCVWD, SFWD, County, cities, Toxic Policy
Council, etc.) might provide input to the regulation
promulgation process.
-------
3-93
ADDITIONAL ISSUES OF CONCERN
The Drinking Water Subcommittee identified a number of issues
outside the scope of the IEMP but which the Subcommittee believes
deserve attention. The Subcommittee divided the issues of concern
into three categories: (1) "accomplishments", or issues that have
been addressed; (2) "in progress issues", where some existing
activity is under way; and (3) "unresolved issues".
*Asterisks denote priority issues as ranked by the Subcommittee.
Accomplishments
1. Adoption of Hazardous Materials Storage Ordinances
2. Improved Water Quality Monitoring (AB 1803)
3. Private Well Testing Program, Phase I
4. Wellhead Treatment by Water Purveyors in Selected Cases
5. Regional Board Site Management System for Solvent Leaks:
Plume Identification, Plume Definition, Aquifer Monitoring,
and Selected Extraction Wells
6. Abandoned Well Sealing Program
7. Los Paseos Neighborhood Epidemiological Study
8. IEMP Risk Analysis: Stage I
9. Public Education by Water Companies
10. Use of chloramination by Water District
In Progress
1. Household Hazardous Materials Clean Up Days
2. Water District Trihalomethane Study *
3. Water District Staff Assigned to Fuel Leak Management
4. Review of HMSO Implementation *
5. Private Well Monitoring: Phase II *
6. IEMP Stage II: Aquifer Management Analysis, Private Well
analysis *
7. Continuing Epidemiological Studies by DOHS
-------
3-94
8. Landfill Evaluation
9. Tanner Bill Implementation
10. MOD for Hazardous Waste Inspection Between County and DOHS
11. Waters Bill (Emergency Response Plans) Implementation
12. Ongoing Clean Up Management for Solvent Sites by RWQCB *
13. Deep Aquifer Monitoring
14. Water District Well Registration Program
15. Dry Wells Investigation
16. Analysis of Storm Run Off Issues
17. District Attorney's Task Force
18. Development of Standards by DOHS
19. Implementation of Fuel Leak Investigation and Clean Up
by SCVWD *
Unresolved Issues; Gaps in Program Development
1. Source Reduction *
2. Education and Outreach to General Public
3. Implementation of Hazardous Waste Regulation
4. Evaluation of Reproductive Risk from Exposure to Toxics,
Including Occupational Exposure
5. Design of "How Clean Is Clean" Consensus *
6. Evaluation of Wellhead Treatment
7. Assessment of Land Use Regulation
8. Toxics Transport Issues
9. Evaluation of Quality of Imported Water
10. Analysis of Risk from Cumulative Exposure to Toxics
11. Nitrate Problems in South County
-------
3-95
BIBLIOGRAPHY
Private Wells
ICF Technology, Inc., Groundwater Contamination and Private
Wells in the Santa Clara Valley, Final Report, April 28, 1987.
ICF Technology, Inc., Assessment of Administrative Costs and
Authorities Necessary to Institute Proposed Private Wells Program,
Memorandum from Rod Lorang and Jim Long to Keith Hinman. EPA,
May 4, 1987.
HMSOs
EGA, Inc., Evaluation of Implementation Effectiveness of
Hardous Materials Storage Ordinances in Santa Clara County, Final
Report, May 1987.
Aquifer Management
EGA, Inc., ICF, Inc., Evaluation of Alternative Groundwater
Cleanup Policies, Revised Draft Report, July 1, 1987.
(Final report anticipated Sept. 30, 1987).
EOA Inc, ICF, Inc., Aquifer Management Project; Santa Clara
Valley Integrated Environmental Management Project, Draft, January
1987. (Final report anticipated Sept. 30, 1987).
David Keith Todd Engineers, Groundwater Management in Santa
Clara Valley, Final Report, June 26, 1987.
THMs
Steckel, Andrew, Background on Trihalomethanes in Santa Clara
County, Memorandum to the IEMP Drinking Water Subcommittee, March,
1987.
Steckel, Andrew, Further Analysis of the Results at_ SCVWD's
Trihalomethane Control Alternatives Investigation, Memorandum to
the IEMP Drinking Water Subcommittee, March, 1987.
Kennedy/Jenks/Chilton, Trihalomethane Control Alternatives
Investigation, Santa Clara Valley Water District, Fianl Draft
Report, May 1986
Stage I
Hinman, Keith; Schwartz, Don; and Soffer, Eileen, Santa Clara
Valley Integrated Environmental Management Project: Revised Stage
I Report, Office of Policy Analysis, USEPA, May 30, 1986.
-------
CHAPTER FOUR
INSTITUTIONAL ISSUES
-------
TABLE OF CONTENTS
INTRODUCTION 1
Background 1
Institutional Analysis Subcommittee 2
Institutional Analysis Report 4
SUMMARY OF THE INSTITUTIONAL ANALYSIS 5
Agencies and Groups Active in Toxics
Management in Santa Clara County 5
Key Issues 5
Alternative Approaches to Toxics
Management in Santa Clara County 8
Alternative 1: Maintaining the
Status Ouo 9
Alternative 2: Coordination and
Communication Improvements 16
Alternative 3: Centralization/
Decentralization 18
INSTITUTIONAL ACTION PLAN 21
Evaluation of Institutional Needs 21
Institutional Management Structure 22
Toxics Policy Council 24
Toxics Coordination Staff 29
Advisory Toxics Task Forces 31
Summary of Conclusions 35
-------
4-1
CHAPTER FOUR:
INSTITUTIONAL ISSUES
INTRODUCTION
Background
The institutional framework in which environmental management
takes place has been an issue of great concern in the Santa Clara
Valley. Over the years, there has been a widespread perception
in the local community that effective risk and resource management
is hindered due to institutional and political problems such as
gaps and overlaps in activities, uncertainty over roles and
responsibilities, lack of resources, and the like.
Stage I of the Santa Clara Valley IEMP identified a number
of high priority risk and resource issues to be included in the
Stage II analysis. However, EPA and local participants recognized
that although such analysis may result in technically sound
recommendations for risk reduction and resource protection, the
success of any recommended strategy or program would also
depend on the effectiveness of institutional and political
arrangements for environmental management. In addition, there
was concern that once Stage II of the IEMP concluded, there
would be no continuing process for raising and addressing
environmental issues. Although Stage II was designed to focus
on high priority issues, a broader objective of the IEMP was to
work with local leaders to develop an environmental management
process that will endure long after the specific Stage II
projects are complete.
Given these considerations, EPA and local participants
agreed that an examination of institutional and political
issues in environmental management was a priority for Stage II
of the project. Therefore, in its transition from Stage I to
Stage II, the IEMP formed an Institutional Analysis Subcommittee
(the "subcommittee") specifically to focus on such issues. In
addition, the IEMP conducted an analysis of institutional and
political concerns designed to assist the subcommittee in its
work.
Since the IEMP institutional analysis work was begun,
several important pieces of legislation—the state Waters,
Tanner and LaFollette bills, the Federal Superfund Amendment
and Reauthorization Act (SARA), Title III—have mandated important
new local responsibilities in the management of hazardous and
acutely hazardous materials. These new requirements have, in
some cases, preempted subcommittee decisions as specific agencies
assumed responsibility for specific programs in compliance with
the legislation. More generally, the new requirements have
-------
4-2
contributed to the constant change within local environmental
management, forcing the subcommittee to try to assess something
of a moving target. On balance, however, the increased complexity
and importance of local toxics programs, and the likelihood of
additional legislation in the future, have made this subcommittee's
work even more important and topical than when it was begun.
This chapter summarizes the Institutional Analysis prepared
for the subcommittee and the deliberations and recommendations
of the subcommittee.
Institutional Analysis Subcommittee
The Institutional Analysis Subcommittee was formed in the
summer of 1986. Table 4-1 lists the members of the subcommittee.
Members were selected to represent a broad array of interests
and perspectives--the subcommittee includes elected officials,
representatives of local and regional agencies, and represen-
tatives of environmental, industry, and citizen groups, and
the university community.
In September 1986, the subcommittee adopted the following
Statement of Objectives:
Subcommittee Objective
Identify feasible institutional arrangements that can
efficiently and effectively protect the environment and human
health from toxic pollution in the outdoor air and drinking
water in the Santa Clara Valley.
Elements of the Objective
1) Identify the current activities and institutional
arrangements for toxics management in Santa Clara
Valley.
2) Identify issues of concern with regard to toxics
management in Santa Clara Valley such as gaps and
overlaps in authority, gaps or overlaps in activities,
resource constraints, etc.
3) Identify and assess institutional arrangements for
the implementation of the substantive risk management
recommendations of the IEMP Air Toxics and Drinking
Water Subcommittees.
4) Identify feasible alternative institutional approaches
to toxics management that would address the identified
concerns and achieve the subcommittee objective.
-------
4-3
TABLE 4-1
INSTITUTIONAL ANALYSIS SUBCOMMITTEE MEMBERS
Name
Representation
Lynn Briody (Chair)
Ann Coombs (Vice-Chair)
Delia Alvarez
Mike Belliveau
Jacqueline Bogard
Patrick Ferraro
Thomas Ferrito
Roberta Hughan
Roger James
Tom Lewcock
David Morell
John O'Halloran
Steve Pedersen
Peter Snyder
Chuck Wilhelm
Nancy lanni (ex-officio)
Ken Manaster (ex-officio)
Councilmember, City of Sunnyvale
League of Women Voters
Director of Public Health
County of Santa Clara
Research Director
Citizens for a Better Environment
Santa Clara County Manufacturing Group
Board of Directors
Santa Clara Valley Water District
Councilmember, Town of Los Gatos
Mayor, City of Gilroy, IGC and
State Air Resources Board
Executive Officer
Regional Water Quality Control Board
City Manager
City of Sunnyvale
Special Assistant to the County Executive
Santa Clara County
General Manager
Santa Clara Valley Water District
Director, Environmental and OSHA Affairs
Semiconductor Industry Association
Vice-Chair
Regional Water Quality Control Board
Director,- Office of Environmental
Management, City of San Jose
Councilmember,- City of San Jose
Professor of I *w, Santa Clara University
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4-4
5) Examine the advantages and disadvantages of the
alternatives identified in element t4 above.
6) Reach consensus and forward conclusions to the ICC on
the appropriate approaches for addressing the identified
concerns and achieving the subcommittee objective.
7) Determine next steps depending upon the conclusions
of the subcommittee and of the ICC.
Elements nos. 1, 2, 4, and 5 of the objective were addressed
by the IEMP Institutional Analysis report (the "report") prepared
by CH2M-Hill and summarized below. The report was prepared with
the guidance and input of the subcommittee. Using the report
as a source of information and a framework for evaluating
options, the subcommittee has worked to address all elements of
its objective.
Institutional Analysis Report
To assist the subcommittee in its work, the IEMP contracted
with CH2M-Hill to conduct an analysis of institutional issues.
The analysis was conducted over a period of roughly six months
with input and guidance from the subcommittee. The resulting
report does not provide a detailed blueprint of a specific
institutional structure, nor does it recommend the adoption of
any general or specific measures. Rather, the analysis was
designed to provide information and a methodology for the
subcommittee and other local decision-makers to use in recommending
institutional measures. A draft report was presented to the
subcommittee in early 1987, and the final report was completed
in July 1987.
Methodology
The methodology of the Institutional Analysis report
involved the following steps:
1. Review existing laws and regulations on toxics as well as
existing information on the responsibilities, activities,
resources, and concerns of federal, state, regional, and
local agencies and groups involved in toxic management in
Santa Clara County.
2. Develop a list of guideline questions to be used in interviews
and solicitation of input from other parties.
3. Conduct a series of interviews with representatives of
state, regional, and local government agencies, and
environmental and industry groups concerned with toxics
-------
4-5
management in Santa Clara County. Solicit input from other
interested and involved parties through letters and written
questionnaires.
4. Based on the above, describe existing institutions and laws
for managing toxics in Santa Clara County.
5. Based on the interviews, the review of materials, and the
responses from mailed questionnaires, develop a list of
"key issues" that identify specific problems or areas of
concern with regard to toxics management in the County;
rank the key issues based on a weighting by members of the
subcommittee.
6. Describe three general institutional alternatives—
maintaining the status quo, improving coordination,
centralizing/decentralizing some or all functions—and
evaluate them, with emphasis on how well they address the
key issues.
SUMMARY OF THE INSTITUTIONAL ANALYSIS
Agencies and Groups Active in Toxics Management in
Santa Clara County
As Table 4-2 illustrates, there are numerous groups active
in toxics management in Santa Clara County: federal agencies,
state and regional agencies, local agencies, and interest
groups such as environmental, industry and community groups.
The relevant factors for each group analyzed in the report
are the following: 1) its major responsibilities and activities,
2) any gaps or overlaps in its activities with those of other
groups, 3) its coordination with other agencies and groups, and
4) the resources available for toxics management and the adequacy
of those resources.
The laws and regulations under which the agencies operate
may be characterized as primarily related to prevention of
toxic contamination, protection against harmful effects of
toxics, or cleanup of toxic contamination.
Key Issues
As part of the problem definition stage of the analysis,
twenty key issues were identified from the eleven interviews,
reviews of existing materials, and responses received on mailed
questionnaires. The key issues were then used in evaluating
the alternative approaches to toxics management.
-------
4-6
Table 4-2
AGENCIES AND GROUPS ACTIVE IN TOXICS MANAGEMENT
IN SANTA CLARA COUNTY
Federal Agencies
Environmental Protection Agency
Department of Transportation
State and Regional Agencies
California Air Resources Board
Bay Area Air Quality Management District
State Water Resources Control Board
Regional Water Quality Control Board
California Department of Health Services
California Highway Patrol
California Department of Transportation
California Department of Motor Vehicles
Solid Waste Management Board
Office of Emergency Services
Department of Food and Agriculture
Hazardous Substance Cleanup Arbitration Panel
Attorney General
Association of Bay Area Governments
Local Agencies
County of Santa Clara (Executive's Office,
Health Department, Department of
Agriculture, Office of Emergency Services,
and District Attorney's Office)
Fifteen cities in Santa Clara County
Santa Clara Valley Water District
Publicly Owned Treatment Works
Water Purveyors
Groups
South Bay Groundwater Contamination Task Force
Toxics Work Group
Safe Water Council
IEMP Committees
Industry Clean Water Task Force
Santa Clara County Inter-Governmental Council
Citizens for a Better Environment
Central Labor Council of Santa Clara County
Silicon Valley Toxics Coalition
League of Women Voters
-------
4-7
As noted, issue identification was based upon the input of
individuals with experience and expertise in toxics management
in Santa Clara County. While this approach provides a clear
reflection of the institutional concerns of those most active
in toxics management, the list generated in this way results in
a mixture of broadly and narrowly defined issues (compare issues
nos. 1, 2, and 7 with 5, 13, and 15), and even some apparent
inconsistencies (compare issue no. 20 with most others).
Note also that the key issues listed below were identified
in the context of institutional issues in toxics management and
do not constitute a comprehensive ranking of toxics problems by
risk or other criteria. Thus, the issues analyzed and discussed
in the Air and Drinking Water chapters of this report were also
identified as priority management issues, although not all fall
under one of the key issues categories below.
The key institutional issues have been ranked based on a
weighting by the subcommittee. The top two issues were clearly
weighted as highest by the subcommittee members and were mentioned
most frequently by interviewees as being of concern.
Several interviewees and subcommittee members noted that
many of the twenty issues fall completely or partly in the
category of state-level problems with toxics management. The
single asterisk denotes those issues for which state (or federal)
government has primary responsibility to address and resolve.
The double asterisk denotes those issues that may require state
(or federal) action, but which also contain elements that can
and should be addressed by local government. For the "state-level"
problems, local decision-makers can either elect to step in and
develop creative local solutions if the state is unresponsive
in fulfilling its responsibilities, or they can try to inform
and influence state legislators and administrators through the
political process. As a result, one of the factors considered
in the analysis was whether the alternative approach provided a
mechanism for determining what the local role will be in such
"state" issues.
The twenty key issues are as follows:
* 1. Definition of cleanup levels (i.e., "how clean is
clean") and setting of air, groundwater and drinking
water standards generally;
2. Need for public education and information on toxics
risk and risk management;
** 3. Source reduction, waste minimization, and creative
toxics solutions;
** 4. Timeliness of cleanup and other programs;
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4-8
* 5. Concerns with staffing at the RWQCB;
6. Implementation of the local hazardous materials
storage ordinances;
** 7. Problems with legislation;
** 8. Gaps in agency activities or authorities;
9. Need for agency accountability, enforcement;
10. Need for data management systems;
* 11. Need for coordination improvements, particularly
between state and local agencies;
12. Comprehensive management of groundwater/drinking
water supplies;
* 13. Differences between DOHS and RWQCB standards for
cleanup;
** 14. Simplification of interactions between regulators
and regulated;
15. Need for "economic reality check";
* 16. Concerns with the staffing and responsiveness of
the DOHS;
** 17. Conflicts between agencies;
** 18. Overlap in agency activities and authorities;
19. Lack of people qualified in hazardous materials
management;
20. Overemphasis on toxics problems.
Alternative Approaches to Toxics Management in Santa Clara
County
The three alternative approaches for toxics management in
Santa Clara County analyzed in the report are 1) maintaining
the status quo, 2) improving coordination and communication,
and 3) centralizing/decentralizing some or all toxics functions
in the County. As mentioned above, the report does not provide
a detailed blueprint of a specific institutional structure, nor
does it recommend the adoption of any general alternative. The
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4-9
analysis is designed to provide information and a framework for
local decision-makers to use in recommending institutional
measures.
Alternative 1. Maintaining the Status Quo
Table 4-3 shows the status quo in toxics management in Santa
Clara County (as of January, 1987; partially updated in June,
1987), as well as some anticipated future programs. The overall
impression is of a wide range of preventive, protective, and
cleanup programs handled by various agencies with thirteen
groups or mechanisms aimed at coordinating the programs. The
following elements of the status quo alternative are particularly
worthy of note:
o Current efforts at public education and involvement are
fragmented and considered ineffective.
o Current mechanisms for county-wide toxics management
and coordination are almost all advisory; the groups
cannot adopt or enforce policy.
o The County, and the Santa Clara County Health Department
(SCCHD) Toxics Unit in particular, has significantly
increased its responsibility for toxics management and
data collection with the implementation of several new
state-mandated programs. Implementation of the Tanner
process provides the authority and framework for county-
wide hazardous waste management while implementation of
Waters and LaFollette serves, at least in part, as
county-wide management of hazardous materials.
A primary advantage of maintaining the status quo is that
it is working fairly well. Most of the key issues are being at
least partly addressed. As illustrated in Table 4-3, agencies
and groups have established coordination mechanisms and informal
methods for reaching decisions. Consciousness about toxics
issues is high and agencies are undertaking new programs in a
concerted fashion at the local level. In addition, the status
quo is not immutable; it is constantly evolving, particularly
at the local level. Some issues that were identified during
the course of this study were resolved by the local agencies
during the study period. Change is also occurring at the
state level, although not as rapidly or effectively as at the
local level. In sum, maintaining the status quo means that
processes and coordination procedures may continue to evolve
toward more complete and effective toxics management.
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TABLE 4-3
TOXICS-RELATED PROGRAMS AND IMPLEMENTING AGENCIES
IN SANTA CLARA COUNTY
PROGRAM
IMPLEMENTING AGENCY
PREVENTIVE PROGRAMS
Existing Programs
HMSOs and HMSO Data Bases
HMSO Groundwater Monitoring
Guidelines
Waters Bill (AB 2185/2187)
Business Plans
- Area Emergency Response Plan
LaFollette Bill (AB 3777)
Industrial Pretreatment Program
NPDES/Waste Discharge Requirements
RCRA TSDFs (39 permitted)
Stationary Source Air Permits
Tanner Toxic Air Contaminants
HazMat Transport
Pesticide Permits, Registrations
Source Reduction/Waste
Minimization (informal and
just starting)
Household Hazardous Waste
Collection
Hazardous Waste Generator
Inspections (under MOD)
City Fire Departments, SCCHD
HazMat Unit, Central Fire
Protection District
SCVWD
SCCHD Toxics Unit
SCC OES
SCCHD Toxics Unit
POTWs
RWQCB
DOHS-TSCD
BAAOMD
ARE and BAAOMD
CHP, DOHS, DMV, Caltrans
CDFA, SCCDA
Safe Water Council
Some Cities
SCCHD Toxics Unit
Source: Draft Institutional Analysis, (CH2M-Hill, January 22, 1987
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Table 4-3 (continued)
PROGRAM
IMPLEMENTING AGENCY
Future Programs
Toxic Gas Storage Ordinances
Roberti Bill (SB 1500)
Proposition 65
Source Reduction/Waste
Minimization Programs
(formalized as outgrowth
of Tanner AB 2948)
Hazardous Materials Recycling
and Reuse Programs (as
outgrowth of Tanner AB 2948)
Household and Small Generator
HazWaste Collection Program
(as outgrowth of Tanner
AB 2948)
PROTECTIVE PROGRAMS
Existing Programs
Drinking Water Systems
- large public systems
- small public systems
- pilot program: limited
monitoring in private wells
and 2-4 connections
1st round (171 wells)
2nd round (1,200 wells)
- Monitoring for organics
(AB 1803)
Trihalomethane Reduction
Health Effects Studies
Standard Setting
- drinking water standards
- ambient air quality standards
- surface and groundwater
quality standards
HMSO implementing agencies
DOHS
SCCHD Toxics Unit
Unknown as yet
Unknown as yet
Unknown as yet
DOHS-SEB
SCCHD, Water Ouality Unit
SCCHD with RWQCB funds
SCCHD with DOHS funds
DOHS-SEB, SCCHD
SCVWD, SFWD,
Water Purveyors
DOHS Epidemiology Section,
with SCCHD involvement
DOHS-SEB
ARB, EPA
SWRCB and RWQCB
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Table 4-3 (continued)
PROGRAM
IMPLEMENTING AGENCY
Ambient Air Quality Monitoring
Groundwater Monitoring
Well Construction/destruction
guidelines/permits and
well registration
Well Closures (if MCLs exceeded)
Well closures (by choice)
Well Sealing (no authority to
compel)
Idenification of Potential
Conduit Wells
Emergency Response Programs
BAAOMD
RWOCB/SCVWD/Gavilan WCD
SCVWD
DOHS-SEB or SCCHD
Water Purveyors
SCVWD
RWQCB, SCVWD
SCC, OES, City Fire Depart-
ments, Special Districts
Future Programs (Potential)
Ongoing regulation of private
wells/systems w/2-4
connections
Unknown as yet; probably
SCCHD Water Quality Unit
CLEANUP PROGRAMS
Existing Programs
Cleanup of sites by Responsible
Parties and of Federal
Superfund/NPL Sites under
MSCA/Enforcement Agmt.
RCRA Site Cleanups
State Superfund
AB 1803 Followup—Investigation
of Sources of Well Pollution
Groundwater Discharge Guidelines
Site Ranking (205(j) Study)
RWQCB as lead; DOHS and EPA
participating
EPA/DOHS-TSCD
DOHS-TSCD
RWQCB
RWQCB
RWQCB, SCVWD
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Table 4-3 (continued)
PROGRAM
Cleanups of Chaboya Transit
District and Almaden/
Quicksilver Park Sites
IMPLEMENTING AGENCY
SCC as Responsible Party
Future Programs
Fuel Leak Cleanup under MOU
or another agreement with
RWQCB
Calderon (AB 3374) on air and
water monitoring around landfills
SCVWD
SWRCB, ARE, RWOCB, BAAQMD
COUNTY-WIDE TOXICS MANAGEMENT
Existing Programs
IEMP and SCVP Risk Assessment
and Risk Management
Planning for Vadose Monitoring
Data Base
Toxics Data Base Planning for
Nine Counties
Data Base Planning
Future Programs
Tanner Bill (AB 2948): County-wide
Hazardous Waste Management
Planning and Facility Siting
EPA and Advisory Committees
SCVWD
BAAQMD/ABAG
SCCHD, SCC Executive's Office
SCC office of County Relations
with active involvement of
cities
COORDINATION MECHANISMS
PARTICIPANTS
Existing Mechanisms
Enforcement Agreement (quarterly
meetings)
South Bay Groundwater Contam-
ination Task Force (meets
quarterly)
EPA, RWOCB, DOHS-TSCD
Administrators of EPA, DOHS
(TSCD and SEB), RWOCB, SCC,
SCVWD, CMA
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Table 4-3 (continued)
COORDINATION MECHANISMS
PARTICIPANTS
Intergovernmental Council & IGC
Environmental Safety Committee
(meets monthly)
Safe Water Council
(meets monthly)
IEMP Intergovernmental Coor-
dinating Committee (meets
monthly to quarterly)
IEMP Public Advisory Committee
(meets monthly to quarterly)
IEMP Subcommittees (each meets
approximately monthly)
City Managers Association (meets
monthly)
Fire Chiefs Association and its
subcommittees (meets monthly)
Emergency Managers Association
Working Group on Area Plans
(AB 2185-2187)
Toxics Work Group (meets
quarterly)
Hazardous Waste Enforcement
Task Force (meets monthly)
IGC Task Force for coordination
of inspections
Elected Officials of SCC,
all cities and special
districts
Local governments, industry,
environmental groups
Elected officials of SCC,
local cities, SCVWD, RWOCB,
ABAC, BAAQMD
Representatives of state
regional, and local
regulatory agencies, industr
environmental and citizens'
groups, and universities.
Same general membership as
ICC and PAC
SCC and all city managers
Representatives of fire
departments and fire
districts. Also attended
by SCVWD and RWOCB
SCC OES and cities' emergency
managers
SCC OES, Fire Chiefs Assoc.,
Emergency Managers Assoc.,
IGC Environmental Safety
Committee
Managers of state and local
governments
SCC District Attorney and
representatives of cities
Representatives of county anc
cities HazMat Units
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Table 4-3 (continued)
COORDINATION MECHANISMS
PARTICIPANTS
Future Mechanisms (Potential)
Santa Clara Valley Project
(or other follow-up to the IEMP)
Same membership as ICC, PAC,
and Subcommittees
COMMUNITY INVOLVEMENT AND PUBLIC EDUCATION EFFORTS
Existing Efforts
Public meetings and hearings
(formal)
Public meetings (informal)
Interagency Community Involvement
Team (ICIT) (area-wide community
involvement efforts)
Site-specific community involve-
ment during investigation and
cleanup of contaminated sites
Publication of documents and
general public mailings of
information
Notification to well/water users
RWQCB, BAAOMD, Board of
Supervisors, City Councils,
SCVWD and other special
districts.
All meetings listed under
coordination are open to
the public.
Members of the SBTF (not all
yet have representatives).
Lead Agency for investigation
and cleanup.
EPA, IEMP, RWQCB, BAAQMD,
State Superfund, SCVWD, SCC
Executive's Office, some
cities; industry (CWTF);
LWV, environmental groups
(limited by lack of funding)
DOHS-SEB, SCCHD, SCVWD,
water purveyors
Future Efforts
New public hearing process for
decision-making
Possible joint public hearings
on site cleanups
DOHS-TSCD
RWOCB and DOHS-TSCD
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4-16
There are, however, disadvantages to maintaining the
status quo. Important issues such as establishing a compre-
hensive public education program, undertaking comprehensive
aquifer management (to the extent it differs from current
efforts of the Santa Clara Valley Water District [SCVWD]), or
adopting needed new legislation or programs at the local level
may be addressed very slowly and ineffectively or not at all.
Because the processes for making decisions to undertake new
activities at the local level are not formalized or well-defined,
and because no agency or group is responsible for ensuring that
decisions are made, some issues may simply not be addressed.
Such issues will tend to be those that require the most creative
thought; unfortunately, they may also be those that could be
most valuable in achieving effective toxics management.
Similarly, without a formalized, well-defined process for
toxic management decision-making, local actors are often forced
to operate in a crisis mode-forming ad hoc groups to address
unanticipated problems. The result has been a proliferation of
groups and meetings, a corresponding decrease in time available
to the managers to conduct programs and planning and, generally,
less efficient resolution of issues.
An additional disadvantage to maintaining the status quo
is that there will be no defined mechanism for determining the
appropriate local role in "state" issues, whether that means
identifying or designing a local program or working for changes
at the state level. Therefore, those issues identified above
that require state action or are the state's responsibility may
be addressed more slowly or not at all. Local agencies may
feel powerless as a result, and the public may continue to
believe that no agency is taking effective action.
Alternative 2. Coordination and Communication Improvements
Interagency coordination and communication between
agencies and interest groups in Santa Clara County has improved
over the past few years. The various task forces and work
groups have served as useful forums for discussion and as an
approach to resolution of key issues. Coordination works
fairly well in the County and the current system creates checks
and balances.
Despite a certain level of success, however, there is room
for improvement. Improvements in coordination and communication
could serve as a middle ground between maintaining the status
quo (alternative 1) and pursuing more significant reorganization
(alternative 3). Improvements could involve more formalized
and structured mechanisms for coordination and communication
including institutionalizing existing forums or creating new
ones, holding more public hearings, clarifying agency procedures,
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publishing agency progress reports, and the like. A number of
very specific improvements suggested in the course of the
interviews are discussed more fully in the report.
In the past, improved interagency coordination, communica-
tion, and issue resolution about toxics management have been
attempted by establishing committees, task forces, and work
groups. This has been a valuable mechanism and many of the ad
hoc groups have successfully accomplished their missions or
have made significant strides ahead. However, as is illustrated
in Table 4-3, the result is thirteen different groups, all of which
have periodic meetings on various aspects of the toxics problem.
These group meetings are in addition to the usual meetings of
the various boards, councils, and commissions in the County and
the public hearings that are held to discuss investigation and
cleanup of contaminated sites. Many of the same people are
involved in all of these meetings; the result is that they have
increasingly less time that they can devote to carrying out
toxics management or planning or other activities. The answer
to achieving improved coordination and communication is not
necessarily to establish new workgroups or task forces to
address each issue. It is first important to decide when, why
and for whom improved coordination and communication is needed,
and then to decide how it can best be achieved.
The need for more coordination and communication about a
given activity can be analyzed in the following context (with a
more complete discussion and analysis provided in the report):
o Why is more coordination and communication needed?
o Who is affected by the activity and how are they affected?
o Who will benefit from improvements in coordination and
communications?
o When is coordination and communication needed and what
level of coordination is necessary?
o Who can undertake the improvements?
One activity in particular—communication with and dis-
semination of information to the public—was singled out by local
participants and interviewees as needing substantial improvement.
One way to make such efforts more effective is for one agency
or group to have the lead in public education rather than
continuing with fragmented efforts as under the status quo.
A comprehensive public education effort would need to be spear-
headed by an agency or group with the following characteristics:
1) the capability to conduct an education program given the
technical, legal, and scientific nature of much of the informa-
tion; 2) the credibility to speak objectively to the public on
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4-18
such issues; and 3) the resources (staff and money) to develop
educational materials and disseminate them to the public. No
group or agency with these characteristics exists under the
status quo, although some existing groups might be modified or
restructured to fit the criteria.
Compared to the status quo, improving coordination and
communication could make improvements in terms of addressing
the key issues identified earlier. Such changes could improve
the responsiveness and accountability of agencies, help make
program implementation more uniform, and help prevent conflicts
between agencies. Most important would be the potential for
establishing a comprehensive public education program.
On the other hand, improving coordination does not address
the need for a coordinated process for decisions and action on
"state" issues and does no better at addressing many issues
than does the status quo approach.
Alternative 3. Centralization/Decentralization of
Toxics Management Activities
Historically, toxics management activities in Santa Clara
County have been spread among a number of agencies. Recent
decisions about how to implement new legislation will result in
a more centralized structure: the County will be the administering
agency for both Waters and LaFollette and will implement the
Tanner planning process and the hazardous waste MOU.
During the interviews, centralization of certain toxics
activities was both advocated and opposed, depending on the
activity involved. Placing responsibility for all toxics
management in the hands of one agency is always an attractive
option because then, in theory, no other agency would have to
worry about managing toxics. However, not all activities
related to toxics can equally well be placed in the hands of
one agency. Some activities are better done by a specialized
agency; for example, fire departments are a logical first
response team for emergencies. Before deciding to centralize
some or all toxics related activities, it is important to
characterize the activities and the agencies to determine if
centralization is necessary and desirable.
The desirability of the centralization or decentralization
of an activity can be analyzed in two steps: first, should the
activity be handled by state or local agencies, and if by local
agencies, should it be done by a county-wide agency or by
cities or other smaller entities? A prevailing attitude
expressed by the interviewees is that many activities should be
centered at the lowest level of government possible, because
local governments are more accountable than the state and in
many cases more effective.
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Whether a toxics management activity should be centralized
or decentralized can be analyzed by addressing the following
questions (with a more complete discussion and analysis provided
in the report):
o Would centralization or decentralization of
the activity increase the effectivenesss with
which it is done?
o Is there an agency with particular interest
in ensuring that the activity is conducted
effectively and/or with particular expertise
to conduct it?
o Who would benefit and who would be adversely
affected by centralizing or decentralizing
the activity?
o Does the activity require specialized technical
knowledge and/or equipment beyond the capabilities
of local agencies?
o Does the activity deal with situations typically
extending beyond local jurisdictions?
o Is the activity similar to historic or typical
activities of local agencies?
o Are county-wide decisions and activities dependent
on the activity?
o Does the activity require resources (money, staff)
beyond the capabilities of local agencies?
o Does the activity involve liability beyond the
capabilities of local agencies?
o Is the activity ongoing or is it a one-time effort?
o Does the activity require immediate or emergency
response?
o Does the activity or its results need to be
integrated with similar activities throughout
the state?
If it is decided, based on this type of analysis, that an
activity should be centralized, then the appropriate agency
must be selected or even created if one does not exist. The
characteristics of the appropriate agency should be defined
based on the analysis of the activity. Existing agencies
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should be evaluated to see how well they fit the characteristics
necessary and whether they could be restructured for a better
fit. An essential element in this evaluation is the resources
and funding capability of the agency. Assigning an activity to
an agency that has insufficient staff and budget and no way of
raising money ensures that the activity will be done poorly if
at all.
If no single agency can be selected, then several agencies
might choose to combine forces or a new entity might be created.
If several agencies combine, the combination should be evaluated
for the characteristics required based on the analysis of the
activities. The group could operate under a Joint Powers
Agreement that defines the roles of each agency and the
decision-making process within the group. If a new entity is
created, it could be specifically designed to meet the
characteristics required.
Centralizing some or all toxics activities could offer
some advantages over the status quo. Consider the most extreme
example: reorganization into a new county-wide toxics management
agency. Such reorganization could be the first step toward
coordinated and comprehensive solutions to local problems. The
agency could conduct all aspects of toxics management, relieving
many agencies of their current responsibilities. Operations
could be streamlined and duplication among agency activities
could be reduced. Unlike the other alternative approaches,
centralization could provide a lead agency for comprehensive
aquifer management and for decisions and actions on "state"
issues.
However, there are risks and disadvantages to such massive
reorganization. The agency runs the risk of being seen as
controlling and running programs without the benefit of
meaningful involvement and advice of other local agencies. It
could be seen as less accountable than existing local agencies
(unless, perhaps, it had a locally elected board that held
public hearings and made decisions publicly). The agency might
have some of the information and expertise necessary for conducting
a public education program, but it would not necessarily have
the credibility; it could be perceived as self-serving because
it would also be conducting programs such as permitting and
groundwater management. Finally, reorganization at the local
level to create a single toxics agency may be unacceptable to the
cities in Santa Clara County given the strong historic role
they have played in managing activities within their boundaries.
It would be essential that there be consensus among local
agencies on what level of reorganization or centralization is
advisable and desirable.
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INSTITUTIONAL ACTION PLAN
Evaluation of Institutional Needs
Based on the CH2M-H111 Institutional Analysis report, as
well as the experience and expertise of its participants, the
IEMP evaluated the institutional needs of the County and
developed a set of conclusions and recommendations with regard
to institutional management in Santa Clara County. The "key
issues" identified in the report and ranked by the subcommittee
members played a central role in shaping the lEMP's
deliberations and conclusions. The following summarizes the
issues that were raised in the course of the subcommittee work
and the conclusions reached.
The IEMP found that the current institutional arrangement
for toxics management in Santa Clara County has specific problems
and areas of concern that need to be addressed, although the
status quo is working fairly well. The "key issues" point out
many of these specific problems or areas of concern with regard
to the current system.
The IEMP found that a primary disadvantage of the current
institutional situation is that there is no formalized, well-
defined process for toxics management decision-making within
Santa Clara County. As a result (as noted in the report), in
some cases issues are addressed slowly and ineffectively, or
not at all. In other cases, issues arise that force local
managers to operate in crisis mode—forming ad hoc groups to
address unanticipated problems. Many of these ad hoc groups have
successfully accomplished their missions or have made significant
strides ahead, but the result has been a proliferation of
groups without a clear structure or process for decision-making,
and meetings without coordinated agendas. The added meetings
involve a corresponding decrease in time available to managers
to conduct planning and implement programs.
Another problem related to the lack of a formalized
management structure and process is that no entity is formally
responsible for a number of activities such as coordinating
toxics activities in the County, monitoring and evaluating
programs, conducting long-term planning, developing or promoting
creative solutions to problems, or organizing a comprehensive
public education or involvement effort. Public involvement
will be particularly crucial in upcoming decisions on "how
clean is clean," hazardous waste management planning and facility
siting, and toxic gas control. The lack of a visible, defined
entity or process with such responsibilities reinforces the
public perception that government is not addressing toxics
issues in a comprehensive, concerted fashion and leaves members
of the public wondering whom to turn to with questions and concerns,
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Finally, the lack of a formalized decision-making
structure makes it difficult for the cities and county entities
to interact with regional, state, and federal entities in a
concerted fashion. Many of the key issues identified problems
that the state (or federal) government is partly or fully
responsible for addressing. For such "state-level" problems,
local decision-makers can either elect to step in and develop
creative local solutions if the state is unresponsive in
fulfilling its responsibilities, or they can try to inform and
influence state legislators and administrators through the
political process. The status quo does not provide a formal,
coordinated mechanism for determining what the local role will
be in such "state" issues and promoting that role.
Despite the identified need for improvement, the
IEMP did not conclude that there is a need for massive
reorganization. In fact, the sense is that massive reorgani-
zation may not be desirable or feasible, particularly in the
short run.
Therefore, based on the above evaluation of the current
situation, the subcommittee focused its effort on institu-
tionalizing and improving that which already exists rather than
on creating new layers of bureaucracy. To the extent that new
mechanisms are needed, an effort was made to suggest the
elimination of existing, duplicative and less effective
mechanisms. The focus of subcommittee discussions was on
creating an institutional management structure for Santa Clara
Valley- Questions regarding service delivery were not addressed
directly, nor was there an attempt to "solve" specific toxics
problems; the thrust has been to create a management structure
and a process that can raise, address, and resolve specific
issues—those that exist now (such as those identified as key
issues in the report) and those that will arise in the future.
The following sections describe the institutional management
structure designed by the IEMP participants. The IEMP
emphasizes that the plan outlined below will succeed only with
the cooperation and involvement of all cities and relevant
County entities in Santa Clara County.
Institutional Management Structure
Tables 4-4 through 4-8 depict the institutional management
structure designed by the IEMP to address toxics issues in
Santa Clara County. Table 4-4 identifies the components of the
structure and how they will relate to one another. The structure
consists of a Toxics Policy Council, Toxics Coordination Staff,
and Advisory Toxics Task Forces. The Policy Council will
develop and recommend county-wide policy on toxics with the
assistance of full-time staff. The Task Forces will work on
the details of specific issues in support of the Council. Each
of these entities is described in greater detail below.
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TABLE 4-4
PROPOSED INSTITUTIONAL MANAGEMENT STRUCTURE
FOR TOXICS MANAGEMENT IN SANTA CLARA COUNTY
SANTA CLARA COUNTY
TOXICS POLICY COUNCIL
members are elected
officials fran cities,
the County, and special
districts in the County
TOXICS ADVISORY
TASK FORCES
members are drawn
from a wide array
of local, regional,
state, and federal
agencies as well as
frcm environmental,
industry, and community
interest groups.
TOXICS
COORDINATING
STAFF
minimum of two
full-time
professional
staff plus
clerical support
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4-24
Santa Clara County Toxics Policy Council
The mission of the Santa Clara County Toxics Policy Council
is to promote the efficient and effective protection of the
environment and human health from toxic pollution in Santa
Clara County by providing leadership; by coordinating, monitoring,
and evaluating programs and policies; by providing public and
interagency communication; and by developing and recommending
programs and policies for both short- and long-term toxics
management.
The function of the Policy Council is to be a central
forum for county-wide toxics decision making. As noted in
Table 4-5, it will develop and recommend policies and programs to
the County, cities and special districts within the County, and
regional, state and federal entities. The option of having the
Council actually set policy and enforce decisions within the
County was rejected by the IEMP because it was considered
infeasible: existing jurisdictions were unlikely or unable to
turn over their authority, particularly to a new and unproven
entity. Instead, the Policy Council will promote consistent
and coordinated implementation of a multitude of toxics programs
being carried out by local member agencies, and will strive to
provide a unified voice for local input to regional, state, and
federal entities. Determining the local position on regional,
state and federal issues and promoting that position with a
unified voice is a critical function since many of the key
issues in the Institutional Analysis report identified problems
with toxics management that the state (or federal) government,
rather than local government, is partly or fully responsible
for addressing.
The Council will be assisted by full-time staff working
under its direction and by task forces in its effort to monitor
and evaluate programs and activities, anticipate and plan for
new legislation, provide public and interagency communication,
and develop new programs and policies to manage toxics both in
the short- and long-term. The Council will structure the
advisory task forces with assistance from the staff.
The Policy Council will set priorities, including its own
agenda. However, the IEMP participants recommend that the Council
consider the "key issues" presented in the Institutional Analysis
report as initial agenda items requiring priority treatment.
In particular, the IEMP has identified the following
issues as requiring immediate attention and action (these
issues are described more fully in the Institutional Analysis
report): 1) definition of cleanup levels (i.e., "how clean is
clean") and setting of air, groundwater, and drinking water
standards generally; 2) the need for public education and
information on toxics risk and risk management; 3) source
-------
TABLE 4-5: SANTA CLARA COUNTY TOXICS POLICY COUNCIL
FUNCTIONS
CHARACTERISTICS
MEMBERS
o Develop and recommend
county-wide policy and
programs for short- and
long-term toxics
management
(Recommendations to
cities, the County,
special districts,
state, regional, and
federal agencies)
o Set priorities
o Monitor and evaluate
programs and activities
o Anticipate and plan for
new legislation
o Provide public
and interagency
communication
o Build consensus on
policy decisions
among political
community
o Hold regular
public hearings
o Direct Toxics
Coordination Staff
(If possible, fund
and hire staff)
o Structure Advisory
Task Forces
o Is accountable to
the public
o Is credible
o Has access to legal
and technical expertise
o Is able to interact
with regional, state,
and federal agencies
o Has commitment to and
interest in toxics issues
o Is open to public input
o Has adequate, qualified
staff
o Is dedicated to toxics
issues
o If possible, has its
own source of funding
and is a permanent body
o Elected officials
from cities and
county
o Representatives of
special districts
in the County
i
K)
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4-26
reduction, waste minimization, and creative toxics solutions;
and 4) the timeliness of cleanup and other toxics programs. In
addition to these specific issues and the additional key issues
identified in the report, the Council should consider the
recommendations of the IEMP regarding air and water issues
as priority agenda items.
The membership of the Policy Council will consist of
elected officials from cities, the County, and special districts
within the County. Members are limited to elected officials in
order to make the Council as accountable to the public as
possible; even if Council members are not elected directly to
the Council by voters, they are still ultimately subject to
voter scrutiny of their record, including actions taken on
toxics issues. The issue of accountability was identified as
an important one in the Institutional Analysis report and was
identified by the IEMP as a necessary characteristic of the
Council.
Another notable characteristic of the Policy Council is
that it will be "dedicated to toxics" so that its members are
particularly committed to, interested in, and knowledgeable
about the issues. The Council will be an independent, permanent
body that cannot simply self-destruct if controversial issues
arise. However, these characteristics may depend on the way
in which the Council is formed. Finally, in order to be
effective, the Council needs staff. The Council's independence
and effectiveness would probably be enhanced if it is able to
hire and fund the staff directly; however, staffing may also
depend on the way in which the Council is created and funded.
Given the functions, members, and characteristics of the
Council, and the desire to avoid the proliferation of groups
within the County, the IEMP has noted that once the Council is
formed, some existing groups could be disbanded and folded into
this structure.
Formation; After much discussion of many alternatives,
the IEMP identified the following three options for
creating the Toxics Policy Council:
1. Joint Powers Authority; This option involves creating
the Council by means of a legal document signed by all the
cities and county entities that would be represented on the
Council. In brief, some advantages of this option are that the
Council will be relatively independent and will involve a formal
commitment to participate on the part of all players. The JPA
could specify financial contributions from members so that the
Council would have its own funding mechanism and would be in a
position to hire staff. A primary disadvantage is that reaching
the level of agreement needed to create a JPA is likely to be
difficult and time-consuming at best, making the feasibility of
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this option more questionable.
2. A New County Entity: This option involves the creation
of a new County entity either by requesting that the County do
so, or by chartering it through a vote of the people. The
Intergovernmental Council (IGC) is an example of an existing
interagency group created by County charter. The primary
advantage of this option is that it may be more feasible than
the JPA. However, the commitment to a County-level Council by
non-County members may be less strong. In addition, given the
current budgetary constraints facing the County, there may be
difficulties in securing and maintaining adequate funding for
the Council. If members were requested to contribute funding,
they would likely want to formalize the requirements through an
interjurisdictional agreement, which might be no easier to
achieve than a JPA.
3. Multi-Party Agreement; This option involves creating
the Council by a formal agreement among the cities and county
entities that would be represented on the Council. The agreement
would be very specific as to the creation of the group, its
responsibilities and limitations, the currently existing
administrative agency that would agree to serve as holder of
the accounts, etc. The primary difference between this option
and the JPA is that administratively a JPA must follow all the
rules and regulations of a new government agency (such as setting
and accounting for its budget), whereas a body formed by a
multi-party agreement would not require such steps in that a
new "government" is not being formed.
Funding; The means of funding the Council may well be
determined by the way in which it is formed and require a
more detailed legal and political analysis. The IEMP identified
the following options for funding the proposed Toxics Policy
Council: ( A combination of the funding mechanisms presented
below would also be a possibility)
1. Create an interjurisdictional agreement whereby
entities represented on the Policy Council agree to contribute
funds according to some funding formula. The formula may be
based on a city's population, industrial base, or other factors
or combination of factors. The agreement could be formal and
binding, or informal and voluntary.
2. Go directly to the voters with a ballot effort. If
the Council is chartered by a vote of the people, the charter
could specify funding requirements. Otherwise, the ballot
measure could be specifically to approve funding, much as is
done for flood control, pest abatement, etc.
3. Add a surcharge to fee-based toxics-related programs
to fund the Council.
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4. Pursue funding through other sources such as AB 1587
(which proposes that a $5 annual surcharge be levied on
purchasers of state environmental license plates for the
purpose of financing comprehensive regional environmental
protection programs by councils of government).
The amount of funding needed depends almost entirely on
the desired staffing level (discussed below), although the
Council may also want to have a small budget for consultants
and may, from time to time, augment its staff by use of
in-kind services from member entities.
After considerable deliberation, the IEMP recommends that
the Toxics Policy Council be formed and funded as outlined in
the following three steps:
a. An IEMP Oversight Committee (composed of the ICC
Chair and Subcommittee Chairs) should work through the
Intergovernmental Council of Santa Clara County to
develop a multi-party consensus among the County,
cities, and appropriate Special Districts for
establishment of a Toxics Policy Council in Santa
Clara Valley.
Possible Sources of funding and/or in-kind support
include the County, cities, Special Districts,
foundations and other private entities, including
private industry.
b. The Toxics Policy Council will come into existence
under the aegis of a multi-party consensus. The
IEMP Oversight Committee will work on preparing a
ballot measure for the permanent creation of the
Toxics Policy Council through a vote of the people.
Possible sources of funding include all of those
named under (a) above, plus State and Federal agencies,
including the Environmental Protection Agency.
If enabling legislation is required, the Oversight
Committee, together with County, city, and Special
District representatives, will work toward co-
sponsorship of appropriate legislation from Santa
Clara Valley Senators and Assembly members.
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c. A ballot measure will be presented to the people of
Santa Clara County for voter approval of a permanent
Toxics Policy Council, funded according to a formula
to be determined by the County, cities, and Special
Districts.
Toxics Coordination Staff
Table 4-6 describes the Toxics Coordination Staff which
would serve the Policy Council and, to a limited extent, the
task forces. Ideally, the staff will be funded by the Council.
The idea of having participating jurisdictions provide staff on
a rotating basis was rejected by the subcommittee in favor of
full-time paid staff to ensure continuity as well as a broad
perspective and a professionalization of the positions.
Given the membership of the Policy Council, it is unlikely
that it will have the time to handle detailed aspects of toxics
management. Therefore, adequate and qualified staffing is
critical. The specific functions of the staff are listed on
Table 4-6. Notably, the staff is designed to assist in long-term
planning, coordination, evaluation and, if funding is sufficient,
public education and possibly data management. However, the
staff is described as "not being involved in actual service
delivery" so that those responsible for implementing a program
are not the ones responsible for providing an objective evaluation
of such programs.
Three levels of staffing were considered and cost estimates
were generated for two of the levels. 1) The subcommittee
recommends at least minimum staffing as follows; an executive
director, an assistant and a secretary. The executive director
should have an understanding of toxics issues; a masters degree
(or higher degree) in public policy, public administration,
government (or the like); a minimum of 5-7 years experience in
government with a demonstrated understanding of the type and
limits of local policy; and an understanding of state and
federal bureaucracies and legislative process. The assistant
would require less work experience, but more training in
environmental affairs, perhaps with a relevant advanced degree.
As for cost estimates, the executive director's salary
would be expected to be approximately $60,000/year, the assistant
$35,000/year, and the secretary $20,000/year. With 100% added
for benefits, overhead, and equipment, the annual costs would
approximate $230,000.
2) The need for a comprehensive public education effort
was raised as a critical issue in the Institutional Analysis
report. If the Council has the necessary credibility to oversee
a public education program and can direct staff in this regard,
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TABLE 4-6: TOXICS COORDINATION STAFF
FUNCTIONS
CHARACTERISTICS
MEMBERS
o Act as staff to the
Toxics Policy Council
o Coordinate toxics
programs and activities
throughout the county
o Assist in evaluation
of ongoing and proposed
programs and activities
o Identify gaps and
overlaps
o Monitor legislation
o Coordinate with and
assist advisory task
forces
o Assist in defining
task force functions
o Assist in long-term
county-wide planning
o Coordinate/conduct
public education effort*
o Coordinate with
state level agencies
o Is full-time, paid
o Is qualified
o Is not involved in actual
service delivery
o Has access to data
o Minimal staff
includes two
professionals and
clerical support
o If possible, staff
is hired and funded
by the Policy Council
i
OJ
o
* The extent of the public education effort will depend on the level of staffing and funding.
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a significant perceived gap in toxics management could be
filled by giving the Council, and through it the staff, the
responsibility for conducting a public education effort, rather
than just coordinating existing efforts. The Institutional
Analysis report describes in detail what the substance of a
public education effort might involve. Such an effort may raise
annual staff costs to $500,000 (an additional $35,000 for a
staff researcher, $35,000 for a science writer, $25,000 for a
graphics/editor staff member, $25,000 for an information manager,
and 100% for overhead costs).
3) Staffing needs and cost estimates for the added function
of data management were not generated because they would depend
upon the type of system that was desired. The Institutional
Analysis report identified a concern over data management and
the IEMP concluded that some sort of centralized systen, not
necessarily fully computerized, is needed; however, the IEMP
did not reach consensus on precisely what is needed, who would
use it, and where it should be located. The IEMP decided that
it was not in a position to resolve the issue of data management
and encourages the Data Management Systems Committee, formed as
a result of the City-County agreement, to address this issue,
ideally within the toxics management structure proposed here.
Advisory Toxics Task Forces
The Advisory Toxics Task Forces are described on Table
4-7. The general function of these task forces will be to
develop program or policy recommendations on specific issues by
drawing on the particular expertise of their members. The
specific functions and members of each would vary depending
upon the issues at hand and would be defined by the Policy
Council, with assistance and advice from the Coordination
Staff. Depending upon the purpose of the task force, it might
be short-term, formed to address a specific issue and than
disbanded upon conclusion of its task, or ongoing with multiple
functions and continuing responsibilities.
It is in the forums provided by these task forces that
much of the detailed analysis, discussions, and policy develop-
ment will take place. However, the task forces will not work
in an isolated fashion; they will interact on a regular basis
with the Council. In this way, the Council can provide input
and direction as well as lend support to task force work, which
may be particularly important when the issues are controversial.
Members for these task forces will be drawn from a wide
array of local, regional, state and federal agencies, as well
as from environmental, industry and community interest groups.
To the extent that task force members are drawn from agencies
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TABLE 4-7: TOXICS ADVISORY TASK FORCES
FUNCTIONS*
CHARACTERISTICS
MEMBERS**
o Develop program or
policy reccmmendations
by drawing on members'
particular expertise
o Conduct program
evaluations
o Examples of Advisory
Task Forces might
include one for
public education;
one for data manage-
ment; etc. (Table 5
details one standing
task force to be
institutionalized)
o Participation by appropriate
persons
o Able to form or disband as
needed (sane groups are
short-term, specific-problem
oriented while others are
ongoing with multiple functions)
o Has access to data
Specific functions would vary for each group
Members drawn from these groups as appropriate by the Toxics Policy Council with
Toxics Coordination Staff
o County Executive's
Office
o City Managers
o Fire Chiefs
o SCCHD
o SCVWD
o EPA
o DOHS
o RWQCBs
o BAAQMD
o POTVfe
o IWV
o Industry
o Environmentalists
o Water Companies
o Universities
o Other advocacy and
comunity groups
advice from the
I
U)
KJ
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within the County, they are likely to be responsive to the
Policy Council since, at some level, they are accountable to
those elected officials. However, the participation of other
task force members—from regional, state or federal agencies or
from interest groups—will depend on their willingness to
cooperate.
As noted in the Institutional Analysis report, as of
September 1986, at least thirteen entities already existed in
Santa Clara County to address toxics management issues. Many
of these could be brought into the process proposed here. The
advantage to bringing existing and future entities into the
process is that the Council and Staff could help ensure that
their objectives and functions are clearly defined, that they
have a full range of appropriate representation, that they do
not have overlapping agendas, that they do not outlive their
purpose, and that the results of their efforts are forwarded to
individuals and agencies with the ability to implement
recommendations or the responsibility of seeking implementation.
By clearly defining the purpose and functions of existing and
new advisory task forces and seeking the consolidation of
groups with duplicative objectives or the dissolution of those
that are no longer needed, the Council and Staff will alleviate
the historic problem of a proliferation of task forces and
overlapping agendas.
In general, the IEMP has not determined which existing
entities ought to continue, which ought to be consolidated or
disbanded, or which new ones ought to be formed; however, the
Institutional Analysis report revealed that many people and
groups active locally in toxics management have found the South
Bay Groundwater Contamination Task Force (SBTF) to be a valuable
forum, particularly for purposes of information sharing. As a
result, the IEMP recommends that a body like the SBTF should be
institutionalized as a standing task force within the structure
proposed here. This task force, currently named the Toxics
Program Development Task Force, is depicted in Table 4-8.
Since people consider the SBTF membership to be one of its
greatest strengths (it brings many of the "right people" from
the "right level of management" and critical programs together
at one time), the membership was left essentially intact: top-
level administrators of agencies and groups with responsibilities
for toxics management in Santa Clara Valley. However, the
subcommittee recommends expanding the SBTF membership to include
a representative of the Central Coast Regional Water Quality
Control Board and the Bay Area Air Quality Management District
(since the focus will no longer be exclusively on groundwater
issues). The IEMP also recommends including representatives of
industry and environmental groups and the League of Women Voters.
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TABLE 4-8: TOXICS PROGRAM DEVELOPMENT TASK FORCE
(A STANDING ADVISORY TASK FORCE)
FUNCTIONS
CHARACTERISTICS
MEMBERS
o Develop programs or
policy by drawing
on members' particular
expertise
o Respond to requests
for information or
program/policy
recommendations by
the Toxics Policy
Council
o Share information
between agencies and
organizations and with
the public
o Help coordinate programs
and activities
o Build consensus among
agency/administrative
bodies on programs
and policies
o Seek input from industrial
environmental, and other
advocacy and community
interest groups
o Participation by qualified,
appropr iate, interested,
committed persons
o Has access to data
o Has regular meetings
o County Executive's
Office
o City Managers
o SCVWD
o EPA
o DOHS-TSCD
o DOHS-SEB
o RWQCBs
o BAACMD
o Environmentalists
o Industry
o League of Women Voters
Ex Officio Members:
o ARE
o OEA
o DOHS (State level)
*»
i
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4-35
In addition, the IEMP recommends including representatives of
state agencies (shown in Table 4-8) as ex-officio members in
attempt to draw the state into local discussions and problem
solving forums.
The IEMP participants have also determined a need for task
forces to address long-term planning, to develop a public
education program to be implemented by the Council and staff
(if funding is available), and to address data management (such
a group exists). As noted above, other existing task forces
and committees could be brought within this structure.
SUMMARY OF CONCLUSIONS
The stated objective of the Institutional Analysis Subcom-
mittee is to identify institutional arrangements that can
efficiently and effectively protect the environment and human
health from toxic pollution in the outdoor air and drinking
water in the Santa Clara Valley. Using the Institutional
Analysis report as a source of information and a framework for
evaluating options, and drawing upon the experience and exper-
tise of its members, the IEMP participants have worked to
achieve the objective. This section describes, in summary, the
issues raised by the IEMP analysis and the conclusions reached.
The following is a brief restatement of the lEMP's
conclusions:
I. Evaluation of Institutional Needs
1. The current institutional arrangement for toxics
management in Santa Clara County has specific problems
and areas of concern that need to be addressed, although
the status quo is working fairly well. The institutional
problems include a) the absence of a formalized, well-
defined process for toxics management decision-making
within Santa Clara County; b) the lack of an entity
formally responsible for such things as coordinating
toxics activities in the County, monitoring and
evaluating programs, conducting long-term planning,
developing or promoting creative solutions to problems,
or organizing a comprehensive public education or
involvement effort; and c) the lack of a formal,
coordinated mechanism allowing cities and County
entities to interact with regional, state, and federal
entities in a concerted fashion.
2. Efforts to improve the status quo need not involve
massive reorganization. Rather, such efforts should
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4-36
focus on institutionalizing and improving that which
currently exists in the County.
3. In particular, there is a need to build upon existing
mechanisms so that there is a formalized and clearly-
defined structure and process for toxics management
decision-making.
II. Proposed Institutional Management Structure
4. Based upon the above findings, the IEMP recommends the
institutionalization of a management structure
consisting of a Santa Clara County Toxics Policy Council,
a Toxics Coordination Staff, and Advisory Toxics Task
Forces. The functions, characteristics and members of
each entity are depicted in Tables 4-4 through 4-8.
Santa Clara County Toxics Policy Council
5. The mission of the Toxics Policy Council is to promote
the efficient and effective protection of the environment
and human health from toxic pollution in Santa Clara
County by providing leadership; by coordinating,
monitoring, and evaluating toxics programs and policies;
by providing public and interagency communication; and
by developing and recommending toxics programs and
policies for both short- and long-term toxics management.
6. The Policy Council will consist of elected official
from cities, the County, and special districts within
the County.
7. The Policy Council's functions include coordinating,
monitoring, and evaluating toxics programs and activities;
anticipating and planning for new legislation; providing
public and interagency communication; and developing
and recommending policies and programs. The Policy
Council will also set priorities, including its own
agenda. However, the Council should consider the "key
issues" identified in the Institutional Analysis report,
the recommendations of the IEMP regarding air issues and
drinking water issues as initial agenda items warranting
priority treatment.
In particular, the following "key issues" should
receive immediate attention and action: 1) definition
of cleanup levels (i.e., "how clean is clean") and
setting of air, groundwater and drinking water standards
generally, 2) the need for public education and information
on toxics risk and risk management, 3) source reduction,
waste minimization, and creative toxics solutions, and
4) the timeliness of cleanup and other toxics programs.
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8. Once the Policy Council is formed, some existing groups
could be disbanded and folded into this structure.
9. The Policy Council could be created as a Joint Powers
Authority (JPA), by a multi-party agreement, or as a
new County entity, possibly chartered by a ballot
effort. The IEMP recommends that the Council be formed
through a vote of the people, via a ballot proposal.
10. The Policy Council requires funding, the level of which
depends on staffing requirements. The funding method
may depend upon the way in which the Council is formed.
A number of funding options are possible, including:
1) interjurisdictional funding agreement; 2) funding
approved by the voters; 3) surcharge added to fee-based
programs; and 4) funding through other sources such as
AB 1587. The IEMP recommends that the permanent Toxics
Policy Council be funded through a formula to be
determined by the County, cities, and Special Districts,
and voted upon by the people.
Toxics Coordination Staff
11. The Toxics Coordination Staff will be full-time profes-
sional staff serving the Policy Council and, to a
limited extent, the Advisory Task Forces.
12. Staff functions will include assisting in long-term
planning, coordination, evaluation, and, if funding is
sufficient, public education and perhaps also data
management. Staff will not be involved in service
delivery.
13. Minimal staffing includes an executive director, an
assistant and a secretary. Estimated annual costs for
this level of staffing approximate $230,000. Additional
staffing to conduct public education (as opposed to
coordinate) would include a researcher, a science
writer, a graphics/editor staff, and an information
manager and would increase annual costs to approximately
$500,000. Staffing needs and costs for data management
are uncertain, depending on the data management system
desired. Staff might be augmented from time to time by
in-kind services and consultants.
Advisory Toxics Task Forces
14. The Advisory Toxics Task Forces will develop program
or policy recommendations for the Policy Council,
drawing upon the particular expertise of their members.
Their specific functions and members will be defined by
the Council.
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4-38
15. The Task Forces may be short-terra or ongoing; the
Council (with advice from the staff) will recommend
their creation, consolidation, or dissolution.
16. The Task Forces will interact directly and regularly
with the Policy Council.
17. The Task Force members will be drawn from a wide array
of local, regional, state, and federal agencies, as
well as from environmental, industry, and community
interest groups.
18. Some Task Forces will need to be formed or institu-
tionalized within this structure; in particular, the
South Bay Groundwater Contamination Task Force (SBTF)
should be modified and institutionalized as a standing
task force to serve the purpose of coordinating programs,
sharing information, and other functions defined by the
Policy Council. The modifications to the SBTF include
adding a top-level representative from the Bay Area Air
Quality Management District (BAAQMD) and from the
Central Coast Regional Water Quality Control Board;
adding representatives from industry, environmental
groups, and the League of Women Voters; expanding
representation to include state agencies (as ex-officio
members); and changing the entity's name to reflect the
inclusion of all toxics issues, not just groundwater.
In addition, there is a need for task forces on
public education, on long-term planning, and on data
management (which currently exists and could be brought
into this structure). Other existing entities could be
brought into this structure.
VI. Implementation
The IEMP recommends that implementation of the toxics
coordination and management framework outlined above be done
under the auspices of the Intergovernmental Council of Santa
Clara County. The IEMP submits the following proposed timeline
for formation of the Toxics Policy Council to the IGC for its
consideration:
a. September '87 to January '88
An IEMP Oversight Committee (composed of the ICC
Chair and Subcommittee Chairs) should work through
the Intergovernmental Council of Santa Clara County
to develop a multi-party consensus among the County,
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4-39
cities, and appropriate Special Districts, for the
establishment of a Toxics Policy Council in Santa
Clara Valley.
Possible sources of funding and/or in-kind support
during this period include the County, cities, Special
Districts, foundations and other private entities,
including private industry.
b. February'88 to November '88
The Toxics Policy council will come into existence
under the aegis of a multi-party consensus. During
this period, the IEMP oversight Committee will work
on the preparation of a ballot measure for permanent
institutionalization of the Toxics Policy Council
through a vote of the people.
Possible sources of funding during this period include
all those named under (a) above, plus State and
Federal agencies, including the Environmental Protection
Agency.
If enabling legislation is required, the Oversight
Committee, together with County, city, and Special
District representatives, will work toward co-
sponsorship of appropriate legislation from Santa Clara
Valley Senators and Assembly members.
c. November '88
A ballot measure will be presented to the people of
Santa Clara County for voter approval of a permanent
Toxics Policy Council, funded according to a special
formula to be determined by the County, cities, and
Special Districts. The permanent source of funding
will commence July 1, 1989.
These conclusions and recommendations were designed to
address the problems in toxics management in Santa Clara Valley
identified in the IEMP Institutional Analysis and by the
Institutional Subcommittee. The proposed structure provides a
mechanism for promoting the implementation of Stage II
recommendations for risk reduction in air and drinking water.
In addition, it provides a vehicle for the continued assessment
and resolution of environmental issues in Santa Clara County.
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CHAPTER FIVE
CONCLUSIONS
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5-1
CHAPTER FIVE:
CONCLUSIONS
With IEMP Completion, Consider Accomplishments
This report marks the culmination of three and a half years'
worth of effort by EPA and local IEMP participants. The project
has required a great deal of time and effort from a large number
of people. While the primary results of the project are docu-
mented in this report and in the Revised Stage One Report, a
full understanding of the project's analytic findings requires
the review of several dozen technical reports that have been
generated over the course of the IEMP. Similarly, an apprecia-
tion of the vitality of local participants' discussion of
issues, and the diversity of views expressed, would be impossible
without a review of the minutes of the IEMP committee and
subcommittee meetings.
Measured in investment of time and treasure, the IEMP has
not been an insignificant undertaking. At this point it is
appropriate to ask how successful the project has been in
attaining its objectives.
The IEMP was intended to be both a pilot effort for develop-
ing better methods of environmental risk management and a
practical vehicle for decision-making on environmental issues.
The IEMP attempted to provide good analysis to support priority-
setting and decision-making; to provide an effective forum for
risk communication, discussion and consensus-building on issues;
and to lay the groundwork for implementation of risk management
decisions and, ideally, continued integrated environmental and
risk management.
Analysis to Support Decision-making
EPA believes that the IEMP has successfully synthesized
and analyzed a great deal of data about a wide range of problems
in ways that assist in comparing problems, identifying risk
management priorities, and clarifying trade-offs involved in
risk management decision-making.
In terms of Santa Clara Valley risk management issues,
Stage I of IEMP helped to clarify the nature and magnitude of
risks from groundwater and drinking water contamination, high-
lighted the risks from trihalomethanes and the vulnerability of
private wells, and stressed the importance of groundwater
resource issues. Through analysis of risks from airborne
pollutants, the IEMP has provided further evidence of the
importance of this exposure pathway, analyzed the potential
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5-2
health effects of toxic pollutants, stressed the importance
of area sources (particularly motor vehicles), and pointed to
the potential importance of particular sources, such as
sterilizers emitting ethylene oxide.
Stage II analyses, summarized in the body of this report,
have examined the risks, costs, and effectiveness of programs
to address many of the above-identified issues. Stage II
research analyzed the cost-effectiveness of controls to reduce
air toxics emissions, and examined local land use control as
a means of mitigating risk. Stage II monitoring confirmed
the importance of organic particulates and examined potential
health risks from criteria pollutants, providing a broader
perspective on risks from airborne contaminants.
Research oriented at groundwater and drinking water risk
management included an evaluation, with recommendations for
improvement, of local Hazardous Materials Storage Ordinances
(HMSOs); HMSOs are the primary local program to prevent
groundwater contamination, and form the core of local hazardous
materials management efforts. Programs to protect high-risk
private wells were designed and assessed. Strategies for
overall groundwater management were developed, and the basin-wide
health and natural resource impacts of different groundwater
cleanup levels assessed. The cost-effectiveness of trihalomethane
reduction alternatives was examined.
Finally, existing institutional arrangements for managing
environmental toxins were reviewed, and institutional alterna-
tives for improving and coordinating local toxics control
efforts were studied.
All of the research efforts summarized above provided
information useful to local risk management efforts, and IEMP
subcommittees developed recommendations for action, detailed
in this report, in each of these areas.
From the national perspective, the Santa Clara Valley IEMP
has served to develop further the methods of risk assessment and
risk management in some key respects, and has generated results
and insights useful to national programs. Methods developed or
refined in the Santa Clara Valley IEMP have been used in an
analysis of air toxics issues in Contra Costa County, in the
newly-begun Denver IEMP, in national and regional "comparative
risk" projects, and elsewhere. Specific results useful to
developing programs include identification of the importance of
chemical and biological transformation of key constituents in
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5-3
assessing underground tank problems, practical lessons learned
from local hazardous materials storage ordinance implementation,
and others. Most of the analytic findings of Stage II are
too new to have been evaluated fully in terms of their practical
import for EPA programs.
Interestingly, and somewhat contrary to initial expectations,
the IEMP analysis identified few instances of cross-media
pollutant transfer that were important in terms of health risk.
Cross-media transfers may be important for ecological effects,
however. Also, comparisons of pollutant risks across media
were found to be enlightening and useful.
Some of the more important contributions to national prior-
ities were the result of problems encountered in the IEMP. The
identification of scientific and data uncertainties has led to
efforts to expand the scope of this type of assessment (by
including criteria air pollutants and indoor air exposures, for
example), to scale back expectations of a "comprehensive" risk
assessment in other cross-media projects to a realistic level,
and to improve health effects information on chemicals such as
1,1,1-trichloroethane and glycol ethers. Perhaps most importantly,
the project has helped to focus the need for EPA to develop
better methods for the evaluation of non-cancer, toxic health
effects.
Public Participation and Risk Communication
One of the lEMP's more significant areas of success has been
in communicating risk and in fostering public participation and
agency coordination. Many of Santa Clara Valley's elected
officials and community leaders (including members of the news
media, industry groups, and public interest groups) today
possess a sounder and more consistent view of environmental
problems than they had prior to the IEMP. Discussions of
environmental issues by local Santa Clara Valley leaders employ
a common language of health risk, and display an unusual level
of sophistication. These positive effects are at least partly
due to the educational and information-exchange functions of
the IEMP. One of the most positive impacts of the IEMP has
been the forum it has provided for spirited, in-depth discussion
of issues among agencies, elected officials, and community
groups. The benefits of these exchanges have carried over to
activities and areas only tangentially related to the IEMP
itself, such as improved coordination between the participants
on other issues. Despite the lEMP's success in promoting risk
communication and dialogue, much remains to be done. In this
report, the IEMP has identified public education as a priority
risk management activity.
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Impact on Regulatory Action
Although the IEMP was designed to be a practical aid to
risk management priority-setting and decision-making, it is
difficult to determine what effects it has had, since it
has operated in a milieu of active regulatory agencies and
other entities involved in environmental management. Most of
these groups are continually identifying and trying to solve
environmental problems, and are in frequent communication with
one another. Thus, the influence of one non-regulatory body,
such as the IEMP, on regulatory action is difficult to distin-
guish with confidence.
Nevertheless, it is clear that the IEMP has already had
some influence on management activities. It has, for example,
focused management attention on drinking water disinfection
issues, private well risks, and basin-wide management of ground-
water resources, as well on the importance of ethylene oxide,
organic particulates, and metals in the air. The IEMP has
reinforced the importance for public health of seeking
further improvements in the concentrations of airborne
criteria pollutants.
In addition, this report contains a number of thoughtful
recommendations on actions needed to improve management of
environmental problems in air and water, and to improve the
process of overall management and coordination in the future.
Some proposals, such as improvements to local hazardous materials
ordinances and programs to protect private wells, are fairly
likely to be implemented, at least in part. The future of more
ambitious recommendations, such as those for aquifer-wide
management using basin-wide groundwater modeling and for
integrated hazardous materials data management linking all
programs, is more difficult to forecast.
Finally, IEMP participants have forwarded detailed and
specific recommendations on institutionalization of coordinated
environmental and risk management. Implementation of the
proposed central Toxics Policy Council would provide a valuable,
formal mechanism for coordinating environmental policies and
activities. However, even without such a body, the efforts of
IEMP participants have improved the coordination of the many
aspects of environmental management in Santa Clara County.
In sum, while the IEMP has already affected local risk
management actions, a final judgement on its practical impact
must be deferred several years, when it will be possible to see
how the specific recommendations and overall direction of the
IEMP have been carried forward.
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5-5
For its part, EPA has found the project to be a valuable
experience that has provided practical results useful to programs,
helped to refine its technical ability to perform risk assess-
ment/risk management analysis, and provided valuable knowledge
about working with local leaders on sensitive environmental
issues. EPA hopes that IEMP participants have found the project
to be an equally valuable experience from their perspective.
EPA would like to thank the many persons who have contributed
their time, knowledge and enthusiasm to this project, and to
express its admiration for the quality and commitment of local
participation in the IEMP.
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5-6
BIBLIOGRAPHY
Air Issues
Radian Corporation, Air Toxics Controllability Analysis,
Volume I, Santa Clara County Integrated Environmental Manage-
ment Project, Final Report, May 27, 1987. (161 pp)
Radian Corporation, Air Toxics Controllability Analysis,
Volume II (Technical Documentation), Santa Clara County
Integrated Environmental Management Project, Final Report,
May 29, 1987. (280 pp)
Energy and Resource Consultants, Santa Clara Criteria Air
Pollutant Benefit Analysis. Final Report, May 20, 1987.
(112 pp)
Flessel Peter; Wang, Yi; Kim, In-Suk, Sampling and Analysis
of Polycyclic Aromatic Hydrocarbons in Santa Clara Valley,
California Department of Health Services & California
Public Health Foundation, Draft, June 26, 1987. (22 pp)
Drinking Water Issues
ICF Technology, Inc., Groundwater Contamination and Private
Wells in the Santa Clara Valley, Final Report, April 28, 1987.
(137 pp)
ICF Technology, Inc., Assessment of Administrative Costs and
Authorities Necessary to Institute Proposed Private Well Pro-
gram, " Memorandum from Rod Lorang and Jim Long to Keith Hinman.
EPA, May 4, 1987. (21 pp)
EGA, Inc., Evaluation of Implementation Effectiveness of
Hazardous Materials Storage Ordinances in Santa Clara County,
Final Report, May 1987. (181 pp)
EOA, Inc., ICF, Inc., Evaluation of Alternative Groundwater
Cleanup Policies, Revised Draft Report, July 1, 1987. (350 pp)
(Final Report anticipated Sept. 30, 1987).
EOA, Inc., ICF, Inc., Aquifer Management Project; Santa Clara
Valley Integrated Environmental Management Project, Draft,
January 1987. (24 pp) (Final Report anticipated Sept. 30, 1987)
David Keith Todd Engineers, Groundwater Management in Santa
Clara Valley.- Final Report, June 26, 1987.
Kennedy/Jenks/Chilton, Trihalomethane Control Alternatives
Investigation, Santa Clara Valley Water District, Final Draft
Report, May 1986.
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Drinking Water Issues, Continued.
Steckel, Andrew, Background on Trihalomethanes in Santa Clara
County, Memorandum to the IEMP Drinking Water Subcommittee,
Steckel, Andrew, Further Analysis of the Results at SCVWD's
Trihalomethane Control Alternatives Investigation, Memorandum
to the IEMP Drinking Water Subcommittee, March, 1987. (7 pp)
Institutional Issues
CH2M Hill, Integrated Environmental Management Institutional
Analysis, Final Report, July 1, 1987. (200 pp)
Other
Froines, John R., Ph.D., Occupational Exposures in Santa Clara
County, Santa Clara County Integrated Environmental Management
Project, July, 1986. (508 pp)
Hinman, Keith; Schwartz, Don; and Soffer, Eileen, Santa Clara
Valley Integrated Environmental Management Project: Revised
Stage One Report, Office of Policy Analysis, USEPA, May 30,
1986. (349 pp)
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Partial List of Acronyms Used in IEMP Stage II Report
ABAC - Association of Bay Area Governments
ARE - California Air Resources Board
BAAQMD - Bay Area Air Quality Management District
BaP - Benzo(a)Pyrene
BAR - Bureau of Automotive Repair
CAG - Cancer Assessment Group
CFC - Chlorofluorocarbon
CO - Carbon Monoxide
COHB - Carboxyhemoglobin
DOHS - California Department of Health Services
DWR - Department of Water Resources
EPA - Environmental Protection Agency
HMSO - Hazardous Materials Storage Ordinance
IEMP - Integrated Environmental Management Project
HMMPs - Hazardous Materials Management Plans
ICC - Intergovernmental Coordinating Committee
IGC - Santa Clara County Intergovernmental Council
MCL - Maximum Contaminant Level
MTC - Metropolitan Transportation Commission
NCI - National Cancer Institute
NESHAP - National Emissions Standards for Hazardous Air Pollutants
NHANES - National Health and Nutrition Examination Survey
ODW - EPA's Office of Drinking Water
PAC - Public Advisory Committee
PAH - Polycyclic Aromatic Hydrocarbons
PM-10 - Particulate Matter smaller than 10 microns in diameter
RWC - Residential Wood Combustion
RWQCB - Regional Water Quality Control Board
SARA - Superfund Amendment and Reauthorization Act
SBTF - South Bay Groundwater Contamination Task Force
SCCHD - Santa Clara County Health Department
SCVWD - Santa Clara Valley Water District
SFWD - San Francisco Water Department
SWDA - Safe Drinking Water Act
SWRCB - State Water Resources Control Board
TAG - Toxic Air contaminants
TCA - 1,1,1-Trichloroethane
TCE - Trichloroethylene
THM - Trihalomethane
TSM - Transit System Management
TSP - Total Suspended Particulates
UST - Underground Storage Tank
VMT - Vehicle Miles Traveled
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