1/19/81
TOXICS INTEGRATION WORKPLAN '
This workplan describes a set of activities related to develop-
ment of an EPA-wide strategy for toxics control. The plan covers
the remainder of FY 1981. It is based on the work to date of the
Toxics Integration Strategy Committee and the concept paper pre-
pared by the DAA's serving on the committee. The plan leads to
initial design"of an integrated toxics strategy that can be fleshed
out and refined (along with initial implementation steps) in FY '82»
It reflects commitments made to OMB in £?A's reply to the .budget
passback :
1. Design of operational mechanisms to coordinate regulation,
data gathering, and analysis of toxic substances.
2. Design and testing of prototype geographic._and industry-
wide approaches to toxic pollutant problems. .''" ' •'
3. Identification of legislative changes needed to effec-
tively integrate toxics control.
4. Organizational changes needed to implement the Agency's
integrated toxics strategy.
5. Resource allocation recommendations for FY '82 and FY '83. ..:
In the second year/ we will complete the analysis of integration
strategies, and begin implementation.
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GOALS
The goals of EPA's toxics integration strategy will be:
0 to set priorities for regulation of toxic sub-
stances in a manner that is logically consistent
across programs and based on coordinated re-
search and analysis of scientific, health, and
economic data.
4
0 to develop a systematic agency process for identifying
and responding to toxic substances so that the combined
effect of Agency actions on specific areas and industries
achieves the ir.ost important environmental objectives
at reasonable costs.
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w w w C .1. .*. * J C C* w C wi*C £*i_W^C*. i.wj.C3 v^4. u r^rx Ud^rttsa
quarters, SPA regions, and state/local
governments in dealing with toxi.c problems.
The rationale for developing a strategy is simply that the
worst threats to health and environment should be controlled first;
that this needs to be done, as much as possible, on an Agency-wide
*»
basis; and that limited resources are most likely to make a, signi-
ficant .impact if used as part of a well thought out Agency-wide
strategy.
ACTIVITIES
The FY 1981 workplan consists of six activities:
1. Analysis of Toxics Control in Different Agency Programs
2. Analysis of Exposure and Risk Assessments
3. Analysis of Integration Based on Specific Pollutants
4. Analysis of Integration Based on Industrial Categories
5. Analysis of Integration by Geographic Area
6. Preparation of Recommendations to the Administrator
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Activity 1;Analysis of Toxics Control in DifferentAgency Programs
This is an analysis of how different EPA programs deal with
toxic substances. Seven programs will be analyzed: air'quality,
water quality, drinking water, hazardous waste, toxic substances
control, pesticides, and radiation.
The objective of this study is to identify similarities and
differences in" procedures which programs use to regulate-toxics and
ascertain how .these can help or hinder Agency efforts to develop
an agency-wide toxics, strategy. The analysis will include evalua-
tion of each program's completed regulatory action, its current
work in progress, and longer term plans for toxics control.
Program-specific regulatory schedules, timetables, and priority
activities will be identified in order to determine compatibility
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with other .program plans.
As part of the study, the Office of General Counsel will pro-
vide a quick analysis of the enabling statutes to determine legis-
lative differences and opportunities for toxics integration.
The task will lead to identification of problems and oppor-
tunities and recommendations for legislative, organizational,
and procedural changes which will be used in Activity 6.
Issues to be addressed in this activity include:
0 what are the major procedural differences among programs
in controlling toxic substances?
e what has been each program's regulatory record to date in
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controlling toxic substances, what activities are currently
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underway, and what is planned beyond FY 81?
0 to what extent have different programs developed non-
regulatory approaches to the control of toxic sub-
stances?
0 which program activities are mandated or discretionary
and what flexibility does the agency have in this regard?
*
0 what are the implications for changing the Steering
Committee process?
c are toxic or hazardous substances defined differently
in the enabling statutes?
0 do the statutes give different weights to consideration
of health, welfare and economic concerns including benefits
and costs in dealing with toxic substances?
0 to what extent are programs reacting .to emergency situ-
ations or able to take anticipatory action?
--~° how are the conclusions to be integrated with legislative
reauthorization studies?
0 how do different programs involve EPA regions and state
and local governments?
Activities 1 and 2 need to work closely together since both
deal with scientific and economic data collection and analysis.
Details will be worked out in the workplan for each activity.
Schedule:
— ""• o
Task 1 Analyze current EPA approaches to toxic
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pollutant control in the various programs.
Based on OTI work currently undervay analyzing
toxics decisionmaking in major SPA programs.
Interim report by 3/15/81; Final Report, by 4/30/81.
Task 2 Analyze major EPA legislation to identify
and compare legislative mandates for toxics
control, based on OTI-OGC evaluation
of EPA legislation related to toxics issues.
Complete by 3/15/81, revised by 5/15/81.
Task 3 Identify constraints to integration and
features that facilitate or promote inte-
•
gration. Complete by4/15/81.
Task 4 Identify the organizational, procedural,
resource allocation/ and legislative changes
that could eliminate or reduce th.e
constraints. Complete by 6/1/81.
Task 4 Review and revision of report.
' Complete by .7/1/81.
" • ''
Staff Requirements: Full time leader from OTI (24 work-mos.)
One half-time person from OPE '(4 work-mos.)
One person for one months each
from seven program offices (7 work-mos.)
One work-month from OGC (1 work-mos.)
Total: 36 work-months
* • * * %
Contract Resources: $80,000 • ' •
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Activity 2: Analysis of Exposure and Risk Assessments Employed
to Determine Adverse Health and Ecological Effects
Program offices have developed different approaches in
assessing health and environmental dangers and economic benefit-cost
impacts as a step in preparing regulatory decisions. The program's
also differ in their use of outside experts for reviewing data and
assessments.
The goal of this activity is to review existing approaches to
the conduct of science, health, and risk and economic assessments,
risk reduction efforts, document differences and their causesf
identify possible changes to promote integration, and prepare
recommendations that will be used in tne output of Activity 6.
Issues to be addressed in this activity include:
*• what are the methods used by different program offices
•
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8 are there meaningful differences in methods used to measure
* » i
or estimate dose,
0 are there meaningful differences in methods used to interpret
and extrapolate results of bioassays,
0 are there significant differences in methods used to interpret
and extrapolate results of long-term whole animal tests,
0 are there significant differences in methods used to interpret
and extrapolate acute toxicity data,
0 are there significant differences in methods used to collect
.and interpret clinical and epidemiological data. (Examples
of interpretative issues are: the use of such concepts as
the lowest observed effect level (LOEL); the treatment of
negative results as compared to positive results; "and the
discrimination made among populations according to age,
sex, susceptibility and life-stype £h identifying effects
and estimating risks.)/ ' •"
0 are there significant differences in models used to translate
emissions- into exposure estimates,
e- are there differences in methods used to translate exposure
to dose,
0 how are results of assessments used for information to .
regions, states, and the public?
0 how should the agency be organized to prepare short-term
risk assessments which are needed in support of regional
responses to environmental .incidents? can we prepare a
model for this purpose?
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0 could acceptable criteria be proposed for determining
the level of acceptable quality for risk assessments?
0 should formal risk assessments be prepared for all toxics
programs?
0 should assessments be done in more than one office, and
if so, how do we ensure consistency and credibility?
0 what risk assessment methodologies are acceptable; are
relative- risk analyses acceptable?
0 could acceptable criteria be proposed for determining the
level cf acceptable quality for risk assessments?
Schedule :
— « .
collecting effects data. Complete by 3/15/81.
Task 2 Analysis of the reasons for differences in
approaches to risk assessment. Complete by 4/15/81.
Task 3 Analysis of needs for changes. Interim
report by 5/15/81. Complete by 8/1/81.
••"-"•"" _ •••'
Task 4 Analysis of approaches used by FDA, CPSC, OSHA
and NCI. Complete by 5/15/81.
Task 5 Recommendations for organizational, procedural
and resource allocation changes that would
facilitate consistency, integration and
efficiency. Complete by "6/1/81.
«
Task 6 Submission of final report. Complete by 8/1/81.
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Staff Requirements: One full-time leader from OPE (9 work-mos.)
One full-time person from ORD (9 work-mos.)
One quarter-time person from
OANR, OTS, OWwM, SAB (9 work-mos. )
Total: 27 work-months
Activity 3: Analysis of Integration Based on Specific Pollutants
The agency has in the past made decisions on what chemicals to
control on an uncoordinated basis,, with each program reacting to a
different set of pressures, constraints, and environmental insults.
It is therefore not surprising that instances can be cited in--which
EPA action has merely transfered pollutants from one environmental
medium to another/ in which minor emissions of a chemical are
stringently contrplled while major emissions are untouched, in which
the lact envircr.me.itai medium to be regulated receives a waste,
etc. A symptom of this problem is that the programs' priority lists
for new regulatory actions show unexplained variations.
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The focus of this activity will be on development of a mechanism
to identify gaps and inconsistencies among the actions of the programs
with, respect to particular chemicals. Once these are identified,
the Agency will heed an issue resolution process to ensure consistent
non-duplicative Agency action.
The focus of this activity is on consistent priority setting,
regulation, enforcement, and information on a chemical by chemical
basis. The effort will attempt to define: (1) the decision criteria
for selecting priority chemicals (or groups of chemicals);
(2) the feasibility of developing agencywide regulatory strategies
for individual chemicals, (3) what kinds of gaps and inconsistencies -
among control action we wish to detect and how they, can be found,
• .
(4) what internal institutional mechanism should perform the analysis.
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(5) the role of external review and public participation in the process
being developed, (6) the role of non-regulatory control mechanises such
as the setting of action levels, and (7) the potential for coordination
of information gathering and analysis (especially contracted work)
functions among program offices.
To start this process, EPA has set up several working groups to
develop an intermedia analysis for particular substances. The DAA
Toxics Integration Strategy Committee, in addition, is working on an
interim list of about 20 chemical substances on which it will prepare
chemical support documents, primarily for use by programs and regions
for FY '.82. The FY 1982 "guidance package will reflect the coordinated
approach toxic substances across EPA. Other current Toxic Substances
Priorities Committee "(TSCP) projects (control options analyses, dioxin
coordination) under this activity, such as the respective program
treatment of substitutes and volatility of solvents.
Issues to be addressed in this activity include:
.- ° how should "new" chemicals be identified? .. , ..,. ..
0 what has been the experience to date with priority listing
of individual .chemicals?
0 what should be the relative weight of various criteria for
priority ranking, such as toxicity, exposure, health risk, or
economic benefits and costs of regulation?
* how can priority ranking established either by interagency or
agency-wide groups be meshed with program-specific activities?
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0 should groups of chemicals, rather than individual sub-
stances, be identified for priority action?
e what information on priority chemicals should be passed on
to EPA regions and state and local governments?
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0 how does the chemical-by-chemical -approach relate to
alternative strategies, such as those discussed under
Activities 4 and 5?
Schedule:
Task 1 Assess current practices for identifying
and ranking of priority chemicals by EPA and
other federal.agencies. Complete by 3/15/81•
Task 2 Finish current work on recommendations"for
agency cancer policy criteria for priority-
set-ting and regulation (based on considera-
; tion of toxicity, risk, exposure and eco-
nomic impact), but scoped to cover sll
effects (not just carcinogens).
Complete by 4/1/81. . ^
Task 3 Complete first round of agency-wide work group
process for developing strategies for chemicals
-~ and chemical, categories. Complete by 5/1/81.
Additional work groups to complete their assess-
ments by 10/1/81.
Task 4 Develop chemical support documents identifying
health and environmental effects of selected
priority chemicals and Agency-wide as well as
program-specific regulatory actions and plans.
Complete first two model documents by 2/1/81.
Prepare additional chemical support documents by
8/1/81..
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Task 5 Based on experience of Tasks 3 and 4 make recora-
/
mendations on whether and how'EPA should develop
Agency-wide strategies for specific pollutants
and a suggested approach to selecting and
scheduling them. As part of this assessment
alternatives to matrix and work group approaches
for integrating agency actions on chemicals
will be considered-. Complete interim report by
6/1/81. Final report by 8/1/81.
Staff Requirements': (OTT staff requirement does not include
CTI sraff cevcrec re TPSC manageroer.r. and
• work groups.) .
"Full-time task leader/support (36 work-mos.]
staff from OTI
Full-time person from OAQRT (9 work-mos.}
6 months from other offices
(0PM, OTS, OWWM, ORD) (6 work-mos.}
Total: 51 work-months
Contract Resources: $150,000. '*
• . - * ' ^ • - *
Activity 4: Analysis of Integration Based on Specific Industrial
Categories
*'"" This activity will attempt to develop an approach to priori—
* ' •*..•-.-
tizing multi-pollutant, multi-program concerns for given industries'
to assure that the most important waste stream or chemical problems
are dealt with first in limited resource situations and to ensure
consistent regulation across programs. 'One or two approaches to
assessing the combined effects of multiple current and future ' ' •
•
regulations on an industry will be designed and applied to two '
sample industries (organic chemicals and copper smelters). They
will draw on the experience of the alternate Fuels Group in dealing
with multi-program guidelines for controlling pollution from synfuel
plants.
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Both of the industry studies will identify the nature and
magnitude of the toxic pollutant problems specific to-.the industry,
*
identify available information on exposure and risk from these
pollutants, assess the environmental and, particularly, the economic
impact of various levels of regulation, and attempt to draw conclusions
on the need for priority-setting among media and pollutants. Each
industry study should lead to design of a sample intermedia strategy
for the particular industry. The most important use of the case
studies will b'e to assess the utility of the approach taken and to
decide whether EPA should develop a general strategy for coordination
of and priority-setting among multiple regulations affecting an
industry- and, if so, to suggest an approach for doing so. A special
effort will be made to explore the industry-by-industry approach
with representatives from industry.
&
Issues to be addressed in this activity include:
•a-
0 what are meaningful industry categories for the purpose
of this approach?
-_ « can effective industry prioritization be carried out on the
*
basis of available information?
0 how can the industry-specific approach be made consistent
with the pollutant-specific and geographic-specific
approaches?
« what data requirements limit the applicability of this
approach? how can those data deficiencies be overcome,
and at what cost to industry and the Agency?
0 can the agency identify industries which cannot afford all
the toxic and non-toxic requirements we migh.t place an them
and concentrate on the'most important? How should EPA
deal with industries in order to make these assessments.
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0 how would the industry strategy relate to OSHA, CPSC, FDA
or other regulations? -t
«
0 does the industry strategy provide a vehicle for com-
bining media-, effluent-, and product-oriented controls?
0 do we need more emphasis on research and development
efforts .on ways to reduce toxics problems through
changed industrial processes or materials?
0 what roles would EPA regional offices play in implementing
the industry strategy?
0 how can the industry-wide strategy be best advanced in
consultation with industry representatives and organizations?
0 which Industries should be selected for second-round studies
(during FY '82)?
Schedule;
Task 1 Define data needs and conceptual" approaches
to industry-by-industry strategy. Assess
i
experience of alternate fuels group. Initial
analysis complete by 2/1/81.
Task 2 Design .and conduct industry assessment studies,
including benefits and costs of current and
likely future environmental requirements for the- -
organic chemicals industry and the copper smelting
industry. Complete study designs by 2/15/81.
Interim report by 6/1/81.. Complete studies by
8/11/81.
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Task 3 Organize industry consultation's on the con-
cept and implementation plan for industry-
wide control strategies. On-going with
other tasks.
Task 4 Assess potential of industry-wide approach and
design appropriate strategy. Develop addi- .
tional study program for FY '82.
Complete by 8/15/81.
(9 work-mos.)
(.9 work-mos.}
(9 work-mos.}
(4 work-mos.)
Staff Requirements: Full-time leader from'0PM
Full-rinis person fro- a pro-
gram office staff
: (OAQPS)
Full-time technical person
from another major pro-
gram office (OE?)
Two months of time from two
other relevant program
offices (ORD & OTS?)
Total: 31 work-months
Contract Resources: ?450,000 ($225,000 for each of
two studies)
Activity 5: Analysis of Integration by Geographic Area -
•
Attacking toxics problems nationally substance-by-substance,
program-by-program may not resolve many of the problems posed "by
local concentrations of toxics and toxic exposures. Control of
toxics problems in specific geographical areas— and by regional,
state and local governments located in those areas— can provide
another alternative to national regulatory action. The working
•
hypothesis underlying this Activity is that many toxic problems
are not amenable to solution via national regulations. "National
perspectives and priorities may overlook localized problems and
solutions.
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One approach to geographic control is to determine the
distribution loadings and locations of critical redlaws of toxic
pollutants in specific geographical areas and evaluate the likely
benefits of national regulatory programs now in place or currently
under development. Several geographic toxics assessments are
currently underway and will be useful in developing the approach.
We would then determine whether further action is needed, looking
at the full range of federal, state, and local actions such as
regulation, monitoring, data collection, and public awareness.
Under what conditions and how this approach might work will be
explored by conducting two pilot studies. Each study will assess
the nature and magnitude of the toxics problem in the area selected
for study, the scientific data base currently- available, and the
options for further cleah-up if necessary. The pilot studies will
be used to develop a general strategy for the geographic approach.
Different models need to be identified, both for a general use of
the geographic approach and its use in response to contamination
incidents.
The main purpose of this activity is to conceptualize and
evaluate the geographic approach and determine its utility and
feasibility. Subsequently, we must determine if the approach
should be routinely applied to a number of.areas or held in reserve
for use when clear problems arise.
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Other issues to be addressed in this, activity include:
0 to what extent are regional and local toxics problems
regulated nationally but not controlled locally? what
are the reasons for this?
0 alternatively, are localized regulations necessary to deal
with special situations? what role should EPA assume?
0 what are the roles of EPA headquarters, regional offices,
other federal agencies, and state and local governments in
response to different situations, such as toxics incidents
o'f known nat:ur.e. incidents that are not understood, for
their principal causes, and high concentrations of media or
effluent toxic pollutants due to particular local
circumstances?
*
0 what is the agency's policy for preparation and release of
information to the public with regard to local toxics . "...
problems?
~ ° what data exists for "desk top" studies at the Federal,
" • - -i^ .....
'"•"'"'"""' State, and local levels? " J-• - ,.:..
Schedule:
Task 1 Explore concept and approach to geographic
regulation with regional, state and local
representatives. On-going with other tasks. :
Task 2 Design and conduct two pilot studies of
specific geographical areas. Coordinate with
ongoing geographic pilot studies, such as
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Great Lakes, Chesapeake Bay, and Kanawha
•i
Valley projects. Design completed by 3/1/81,_
interim reports complete by 6/15/81, 2 pilots
complete by 8/1/81.
Task 3 Develop a catalog of regional, state and local •
approaches that don't require national regula-
tion. Complete by 7/1/81.
Task 4 Analyze success of the 2 pilot studies"and
design general strategy. Complete by 8/31/81.
Task 5 Complete the analysis of ncxic "5ci. Spors"
in the aquatic environment and integrate with
output from Task 2. Interim report by 5/15/51.
Revised report by 8/1/81.
Task 6 Analyze several case studies of emergency toxic
. -a. :-_.
problems to determine where Agency responses
were integrated and where they were not.
Identify the factors that contributed to both - "" -
integrated efforts and failure to integrate. "--;-.:
Recommend approach to integrated emergency response,
Complete by 8/1/80. .
*
Staff Requirements: Full-time leader from OWWM (9 work-mos.)
Full-time person from Region
III (9 work-mos.)
Full-time person from ORD (9 work-mos.}
Half-time person.from OPM (4 work-mos.)
Total: 31 work-months
e
Contract Resources: $450,000 ($225,000 for each of
two studies)
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Activity 6: Recommendations to the Administrator
The various activities listed above will be used in developing
a report on toxics integration for the Administrator. This will be
the central document which discusses the concept of toxics integra-
tion, its applicability to the mandate, of the Agency, and various
approaches to implement the strategy. The report will recommend
* • <»
an agency-wide strategy and steps 'for its implementation. ' ^'"addi-
tion, a workplan and resource allocation plan for the next two
fiscal y-ears will be prepared. OPS/OPM will assist tne project
manager in preparing resource allocation estimates and operating
plans for ail activities. The report will be based on the results
of Activities 1 through 5 above and will require a strong effort
to weave together the various study results and to identify clearly
the legislative, organizational, and procedural changes that will
lead to the new strategy. The direction of the report, as well as
the goals of the agency's integrated toxics strategy, will be
developed in close consultation with the DAA's committeeVr
Schedule;
Task 1 Work on key issues jointly with other task
forces. January thru September 1981.
Task 2 Explore key concepts and approaches to toxics
integration with outside experts. Ongoing
with other tasks.
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Task 3 Develop strategy and prepare report to the
Administrator. The timetable for this task
is as follows:
February 15 Complete outline of report. Revise
workprograms for activities 1-5 as
necessary to bring them in line with
development of central strategy.
April 1 Revise outline of report. Incor-
porate progress reports from
Activities 1-5. ._/
May 1 Drafting of report begins
•
July 15 draft report submitted to the Toxic
Integration Strategy Committee
August 1 work begins on final draft of the
report.
Sept. 15 Toxics Integration Committee forwards
report to the Administrator. Agency
and regional briefings. -
. -a r-_ :.
Task 4 Resources Allocation plan for FYs '82 and '83.
Work on components ongoing with other tasks.
Comprehensive plan' due September 1. ..-;. .. -.-;•••
.Task 5 Preparation of workplan on toxics integration . - J
for. FY'f.82. To be completed September 1, 1981.
Staff requirements: Project manager (9 work-mos.)
Full-time (or equivalent) _- ~
person from OTI (9 work-mos.)
Full-time person from OPS • (9 work-mos.).
One-half person from ORM \ (4 work-mos.)
Full-time secretary (OE?) (9 work-mos.)
Total: 40 work months
Contract Resources: $150,000
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Resources and Management Plan;
(a) Staff and Contract. Resources requirements are as follows:
Activity 1 36 work-months $80/000
Activity 2 27 work-months •
Activity 3 51 work-months 150,000
Activity 4 31 work-months 450,000
Activity 5 31 work-months 450,000
* h™
Activity 6 40 work-months (in- ... 150JQOO
eludes project mgr.)
TOTAL 216 work-months • $1,280,000
»
(b) Project Manager: The project manager will oversee the develop-
ment and imp lenient at ion of the workplan. He will serve as execu-
tive secretary of the Toxics Integration Strategy Committee and
will direct the staff working on toxics integration.
?
(b ) Toxics Integration Strategy Committee:* --—
The Committee, with representation at the DAA level from all
program offices and one DRA, will act as the steering committee
for the various activities related to toxics integration. In
oarticular, the committee will approve the workplan, review the
reports prepared by the different task forces, and approve the
final report on toxics integration to the Administrator.
(c) Task Forces;
For each of the six activities listed above a task force will
be established, consisting of a task force leader and staff, as
necessary. Task force leaders will spend full time on their assign-
ment. They will be part of the central group in charge of work on
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t
toxics integration. Other staff members will join the core group
or will remain attached to their individual program offices. Each
task force will develop a detailed workplan.
(d) Consultants and Contract Work;
Each task force will develop plans for the use of- outside
advisers and consultants. Use of expert advice in defining dif-
ferent approaches to toxics integration is encouraged. In particu
lar, new strategies for industry-wide and geographical controls
will be discussed with industrial and state and local government
reresentatives .
( e ) Management and Integration Mechanisms.
ive anticipate holding monthly meetings of uhe Toxics Integra-
tion Committee from January through June, and bi-weekly meeting's
from July through September. Marilyn Bracken, Roy Gamse, and .the
. ^ 7~J.1I! - -
project manager will meet with the Task Force leaders at a
regularly scheduled weekly meeting. The project manager will work
on a._daily basis with the Task Forces and as needed with the TISC
members. " •
(f) Update of Workplan;
Once the various activities described in the workplan are
fully staffed, the project manager and the task force leaders will
review the workplan and make changes as necessary. The Toxics
Integration Committee will be kept fully informed.
(g) Scheduling Problem;
How to develop FY '83 resource needs in time to affect the
o
Z3B process this summer. May need to assume a continuation of
FY '82 levels if we can't solve this problem.
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INTEGRATED TOXICS STRATEGY
Workplan for Activity 1;
L£._2l Toxic Substances in Agency Programs
Statement of Objectives
One focus of the Integrated Toxic Strategy workplan is
determining a means to integrate Agency activities pertaining to,
toxic substances given the current environmental statutes and EPA
organization; therefore a comprehensive analysis of current toxic
substances activities within Agency programs is a requisite first
step. The specific objective of Activity 1 is to identify
similarities and differences in procedures used to regulate toxic
substances and to ascertain how these can help or hinder efforts
to develop an Agency-wide toxics strategy.
The analysis will evaluate the completed regulatory action of
each program, current work in progress, and longer term plans for
toxics control. Program-specific regulatory schedules and
priority activities will be identified in order to determine
compatibility with other program plans. Activity 1 will identify
various constraints and opportunities in toxic substances
activities and will suggest legislative, organizational,
programmatic, and procedural changes pursuant •_. _he preparation
of recommendations to the Administrator in ^Activity 6.
GENERAL SCHEDULE:
interim drafts
final drafts
finished report
GENERAL STAFFING:
Full time Leader from OTI
OTI staff support
One half-time person from OPE
One person for one month each
from seven program offices *
One work-month from OGC *
Total: 36 work-months
CONTRACT RESOURCES: $80,000
* Wot currently being used.
9
18
4/30
6/1
7/1
work-months
work-months
4 work-months
7 work-months
1 work-month
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TASK 1:_ AHALYZE CURRENT APPROACHES .
Analyze current EPA approaches to toxic pollutant control in the
various programs.
Task 1-A: Analyze Toxic Substances, Assessment and Control
Processes
Address past allegations of ineffective policy and procedures in
each sub-task. Notable among these alleged shortcomings are:
lack of consensus on health and environmental risk, inconsistent
response to risk, overlapping pre-regulatory assessment
activities, differences in weighing costs and benefits of
regulation, missed opportunities for integrated enforcement,
uncoordinated monitoring strategies, and a tendency to respond to
the first exposure route encountered rather than the most
significant one.
Develop program-specific profiles (for the air, water quality,
drinking water, solid waste, pesticides and toxic substances
programs) and conduct item-specific comparisons of key program
activities. The general focus of these profiles will be:
regulatory history, selection of chemicals for regulation,
selection of control options, regulatory strategy, and analysis
of risk. The emphasis of this task will be to identify
inconsistent and overlapping activities within EPA. Specific
areas of examination include:
0 Procedures for Setting Priorities "* 7~~
Compare the priority setting processes used by each
major program. Distinguish between priority setting for
assessment and for control action. Identify
opportunities for improving consistency across programs.
0 Assessment Processes
Identify consistencies/inconsistencies. This sub-task
must be coordinated with Activities 2 and 3.
8 Procedures for Economic Analyses
Examine various types of economic analyses performed
during assessment and control processes, and the weight
placed on analysis of costs and benefits during
regulatory decision-making.
o Toxic Substances Control Processes
Examine the following areas:
- the regulatory development processes
- non-regulatory alternatives (e.g., incentives,
information bulletins, etc.)
- incident response processes
- implementation mechanisms/processes
- inter-program coordination efforts
- fate of chemicals or problems dropped from the
regulatory queues.
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- 3 -
° Status of Control Activities
Examine the current status of toxic substances control -
activities in major EPA programs. Specify:
- progress made toward regulation of toxic substances
- regulatory plans
- -scope of future of remaining problems
° Agency Monitoring Systems
Compare monitoring and other related problem
identification processes across EPA programs; use the
Integrated Monitoring Strategy as a primary resource.
0 EPA Enforcement Programs
Compare toxic substances enforcement processes across
media. Examine the program office/Office of Enforcement
relationship in setting priorities for enforcement under
each statute.
This .information will be developed from interviews of senior
management in each program office. The interview material will
be developed into progam profiles, which will be the information
base for Tasks 3 and 4. Furthermore, information and ideas from
the interviews will be used to refine the areas of analysis to be
conducted in Tasks 3 and 4.
SCHEDULE: draft prof iles _.,3/15
final report ' 4/30 •
Task 1-B: Intergovernmental" Coordination'
Examine in each major EPA program current and possible roles of
EPA Regional Offices, State governments and local governments in
problem identification, assessment, development and
implementation of controls,.and enforcement. Input should be
solicited from Regional Offices, State government and local
government sources. Describe involvement of headquarters offices
in regional or other activities involving toxi.c substances
integration. Describe and critique plans of current regional
integration efforts. Review and summarize the National
Governors' Association report on state toxics integration
activities. Discuss possible models for integration progress.
propose ways of coordinating the ongoing toxics integration
efforts with Regional, State, and local authorities, and identify
expected problems in doing so.
SCHEDULE: draft report 3/30
final report 4/30
Task 1-C: Current Integration Mechanisms^
Identify and analyze basic mechanisms in-place within EPA to
integrate regulatorv .development activities. Present
programmatic-perspectives on the success of such integration
.mechanisms.
Examine the role of the Work Group/Steering Committee/Red Border
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- 4 -
process as an integration mechanism. Identify weaknesses and
strengths of the process, and opportunities for improving the
process.
Examine the Toxic Substances Priorities Committee (TSPC) as an
integration mechanism. Identify strengths, weaknesses and
opportunities for improvement. Describe and analyze the
Integrated Waste Management (OWPO) and Integrated Risk Assessment
(OHEA) initiatives and examine their relationship to the
integrated toxics strategy.
SCHEDULE: draft report 3/15
final report 4/30
Task 1-D: Enhanced EPACASR— Developing an Industry File
The Chemical Activity Status Report (EPACASR) is an interactive
data base, accessible by chemical name/CAS number, containing a
description of each Agency activity relating to chemical
substances.' The types of activities listed include:
regulations, technical assistance information, preregulatory
assessments, chemical and biological testing and monitoring
programs arid labeling requirements - both completed and
ongoing. Making this data base accessible by industrial cross-
reference would provide valuable assistance in assessing impacts
of industry-specific regulations.
The task manager will identify, develop,.and select means of
accessing EPACASR by industry and will subsequently begin
compilation of necessary information.
SCHEDULE: preliminary reports 4/81
begin compilation 5/81
- no completion date identified
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- 5 -
TASK 2; ANALYZE EPA LEGISLATION
Analyze major EPA legislation to identify and compare legislative
mandates for toxics control. Survey toxic substances control
mechanisms available to the Agency and describe definitions of
toxic substances as .established by statute and as interpreted by
the Agency. This analysis will identify constraints to and
opportunities for integration in the statutes EPA implements.
Control mechanisms and their bases will be described for each
statutory provision as follows:
purpose of the provision
- control mechanism employed
criteria for development of the control mechanism
the point at which the control mechanism is applied in
the life cycle of the toxic chemical
- deadlines imposed by statute.
The definition of a toxic substance will be described:
in the language of the statutes
as interpreted by the' agency
SCHEDULE: interim draft 3/30
final report 5/15
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- 6 -
TASK 3: IDENTIFY LEGAL AND ADMINISTRATIVE CONSTRAINTS/
OPPORTUNITIES
Identify legal and administrative constraints to integration as
well as opportunities to facilitate or promote integration in the
Agency programs pertaining to toxic substances. This analysis
will cut across Agency procedures for setting priorities,
assessment processes, procedures for economic analyses, control
processes, agency monitoring systems, and enforcement programs.
The specific analyses to be performed in this task are based in
part upon the information gathering of Tasks 1 and 2 and will
therefore be developed in parallel with them. A dialectical
comparison of procedural and statutory aspects identified in
preceeding tasks will serve as the basis for the recommendations
of Task 4. Because the candidates for analysis are expected to
be numerically unmanageable, a subset will be chosen for
immediate attention based upon: 1) potential for near-term impact
on Agency activities, 2) relevance to other parts of the
Integrated Toxics Strategy, and 3) managability given current
resources.
SCHEDULE: compare and contrast
profiles to identify
issues 3/30
selection of analyses 4/6
draft analyses ', 1
final report • 6/1
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- 7 -
TASK 4: IDENTIFY DESIRABLE MODIFICATIONS
Identify changes in organization, procedures, resource
allocation, and legislation that could lead to improved
integration of toxic substances assessment and control
activities. Analyze Tasks 1-3 to develop recommendations for
changes to improve Agency integration efforts involving toxic
substances. These recommendations will be developed in concert
with Activities 2, 3, 4, and 5.
SCHEDULE: draft report 6/1
final report - 7/1
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i
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
8 0 FEB 1931
RESEARCH AND DEVELOPMENT
SUBJECT: Draft Work Plan for Activity 2 Under the Toxic Integration Program
FROM: James W. Falco, Director
Exposure Assessment Group (RD-689)
TO: See Below
Attached is a draft work plan for activity 2 of the Toxic Integration
Program. Please review this draft in preparation for a work group meeting to
be held on Monday, February 23, 1981 at 9:30 am in Room 3802. At this meeting
I would like to receive any recommendations for changes you wish to offer. I
have also attached a copy of the overall program work plan for your
information. I look forward to working with you on this project.
Please contact me if you have any questions.
Attachment s)
Addressees:
Allen Hirsh (RD-682)
Daphne Kamely (PM-223)
Jack Fowle (RD-689)
Bob McGaughy {RD-689)
Peter Yoytek { RD-689)
Courtney Riordan (RD-680)
rDan Beards! ey (PM-208)
Ted Just (RD-674)
Charlie Ris {RD-689)
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Detailed Work Plan for Acccxnpl ishment of Activity 2 Under
the Toxics Integration Work: Plan
To accomplish the objectives of activity 2 of the Toxics Integration
Project, the following work plan is proposed. The time and resources
allocated for the accomplishment of these goals require that the exposure and
risk assessment activities conducted by each operating program within the
Agency be aggregated into fairly broadly defined categories. These categories
of assessment activities can be evaluated and compared with similar activities
in other operating programs. In addition to evaluating the Agency's exposure
and risk assessment activities in a manner that is consistant with the
Agency's resources, the aggregation of activities in to broad categories
should provide a reasonable number of recommendations that have a significant
impact on improving the quality and efficiency of the Agency's operation.
We propose that a separate report be written for each of the tasks
outlined in the Toxics Integration Work Plan under Activity 2. Each of these
. ^. :-
reports would be written in a style and format such that at the end of the
project one final report could be published by assembling each task report as
a chapter and adding a summary chapter.
We propose to address the following issues in task reports.
Task 1 Report - EPA's Approach to Exposure and Risk Assessment
This report will contain a brief description of the requirements for
exposure and risk assessment specified by each major legislative act. Major
operating programs involved in the implementation of exposure and risk
assessments will be identified.
-------
The report will also contain as individual sections a description of the
implementation strategy employed to satisfy regulations. Specific topics
included for each major exposure and risk assessment category are:
1. Description of procedures for conducting cancer risk assessments.
2. Description of procedures for conducting mutagenicity risk
assessments.
3. Description of procedures far conducting risk assessments for other
health effects.
4. Description of procedures for conducting exposure assessments.
5. Description of procedures for conducting environmental risk
assessments.
6. Description of procedures for independent review of assessments and
quality assurance of data.
This report will also identify the program offices that collect and
analyze economic data and that assess benefits and costs. Methods used to
perform economic evaluations will also be described'.* "~
Task_2 - Analysis of the Reasons for Differences in Approaches to Exposure and
Risk Assessments '
This report will highlight the differences in management and technical
approaches for conducting exposure and risk assessments. Specific topics will
i nclude:
1. Description of differences in reliance on outside experts and weight
given to their testimony and statement of reasons for differences.
2. Description of differences in methods used to measure or estimate
exposure based on monitoring data and statement of reasons for
differences.
-------
3. Description of differences in methods used to measure or estimate dose
and statement of reasons for differences.
4. Description of differences in methods used to interpret and
extrapolate results of bioassays and statement of reasons for
differences.
5. Description of differences in methods used to interpret and
extrapolate results of long-term whole animal tests and statement of
reasons for differences.
6. Description of differences in methods used to interpret and
extrapolate acute toxicity data and statement of reasons for
differences.
7. Description of differences in methods used to collect and interpret
clinical and epidemiological data and statement of reasons for
differences.
8. Description of differences in models used to translate emissions into
exposure estimates and statement of reasons'for differences.
9. Description of differences in other methods used in exposure and risk
assessments and economic evaluations discovered during task 1 and-
statements of reasons for these differences.
Task 3 - Analysis of Needs for Changes
This report will briefly describe how each major category of exposure and
t
risk assessments is used by the Agency. It will also define needs for
administrative and technical changes. Specific topics to be discussed
i nclude:
1. Description of use of exposure and risk assessments by each program
-------
office highlighting needed changes related to this use.
2. Description of use of exposure and risk assessments by regions
highlighting needed changes related to this use.
3. Description of use of exposure and risk assessments by states
highlighting needed changes related to this use.
4. Description of use of exposure and risk assessments by the public
highlighting needed changes related to this use.
5. Description of other needed changes that become apparent during task 1
and task 2.
Task 4 -,Report Analysis of Approaches Used by FDA, CPSC, OSHA, and NCI
This report will briefly describe the legislative requirements for
exposure and risk requirements for exposure and risk assessment that must be
addressed by FDA, CPSC, OSHA, ad MCI. Guidelines and procedures used by each
Agency will be described. Specific topics addressed will include:
- 4- --—
1. Description of procedures for conducing cancer assessments
2. Description of procedures for conducting mutagenicity assessments
3-. Description of procedures for conducting risk assessments for other
... health effects.
4. Description of procedures fo conducting exposure-assessments.
5. Description of procedures for independent review and quality
assurance of data.
6. Description of economic analyses performed.
This report would highlight similarity and differences in management and
technical approaches among agencies and the reasons for those differences.
-------
Feb. 23 March Z3 I April 23 May 23 June 30 Aug 1
Task 2 j
• Task 3
Task 4
Task 5
j Task 6
FIGURE 1. SCHEDULE OF COMPLETION OF ACTIVITY
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Task 5 -.Recommendations for Changes
This report will suggest changes in organizational, procedural and
resource allocations that v.-ould improve consistency, integration and
efficiency, of exposure and risk assessments conducted by the Agency. Specific
issues that will be addressed in this report are as follows:
1. Organization to prepare short-term risk asseessnents that are needed
to support regional responses to environmental incidents.
2. Development of criteria to determine the level of acceptable quality
for exposure and risk assessment.
3. Organization and management of program office (offices) involved in
exposure and risk assessment to insure consistency and credibility
4. Recommenced chages to minimize legislative barriers to consistency of
assessment and efficiency of conducting assessments.
5. Definition of changes to improve and expand economic evaluations.
6. Definition of changes needed to address other problems discovered in
tasks 1 through 4. .*••=-_..."
Task 6 will involve review and editing of each task report to form an
integrated final report.
table 1 lists the responsibilities for completion of each task. The
assignment of responsibilities reflect the need to organize work to maximize
efficient execution of the tasks and to retain responsibility for decisions
within the Agency. Figure 1 shows the schedule of completion of tasks.
Although this schedule shows tasks completion dates for individual tasks later
than originally proposed, it indicates a final report delivery date of August
1, 1981. Thus, completion of activity 2 will occur on target if this schedule
is approved.
-------
• ' ' TABLE 1. ASSIGNMENT OF RESPONSIBILITIES
Task 1 - This task will be'done by Clement Associates. In-house activity
2 team will review and comment on this report and offer technical information
in their areas of expertise.
»
Task 2 - This task will be the responsibility of the in-house team.
Clement Associates will assist the team by summarizing team opinions into a
report and providing professional technical consultation in,their areas of
expertise. • .
Task 3 - This task will be the responsibility of the in-house team.
Clement Associates will assist the team by summarizing team opinions into a
report and providing professional technical consultation in their areas of
expertise.
•
Task 4 - This task will be done by Clement Associates. The in-house team
will review and comment on this report and offer technical information in
their arees of expertise.
Task 5 - Thi-s task will be the responsibility of the in-house team.
Clement Associates will assist the team by summarizing team opinions into a
report and providing professional technical consultation in their areas of
expertise.
Task 6 - The in-house team and Clement Associates will be jointly
responsible for editing the five task reports to form the final report.
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2-/IX/— ll
INTEGRATED TOXICS STRATEGY
Analysis of the
Cneraical Approach to Toxics Integration/Control
:TIVITY 3 — WOHKPLAN
ie intent of this activity is to- evaluate EPA's optiaal
:nenucal" approach (including chemical "classes") *o
-ope-S^i-CS^^^RS Jo*1"' Particularly with'r^ard to the
.ope, Tni., wi uh ouher feasible integration aoproacn.es *ince
his activity is especially intertwined with the sCb^cts oT
ctiviries one and two, there should be a considerabl^ amount of
ubswantive interchange among then. «nounw o,
:. Evaluation of Traditional Agency Practices
e
..,= inzent of this section is zo assess to scse degre-" the •
:ro-.i£-SLrAs iaportant
to. note that the Solvents work group is the first coordinated "
Agency-wide effort to develop an Agency Control Strat-egy for a
whole use class of najcr chesicals. Likewise, the I?? process is
the" first tiae the Agency has integrated its -s'sjor activities and
resolved- outstanding issues on the Agency's 20 egreeG-upon
priority cheaicals.
III. Recommendations for FY 1SS2 and Beyond
This will be the major section of the final report. The first
two sections will support the development of options for
improving the Agency's present toxics-related progress. Options
wili-.be developed that range frcs incremental isprovevents to
present procedures ro'cajor charges to the Agency's policies,
laws, and organization.
-------
7IVITY 3 -- TASK OUTLINE
^^^^^^^^^^^^^^^™*^^^^^"^^*^^™^^^^^
»
-K- ^ — Evaluation of present chemical oriority settinz
aczice-s or £?A - SL
•
_ intent, of this task is to H) describe how -?A srogrsni
fices presently set their toxic chenical priorities, (2)
lalyze differences in their priority- setting and (3) define the
itegration problems that have arisen as a result of these
fforts. The following subtasks are intended to provide base-
ine information on- rsajor areas requiring greater* Integration
ttention.
ASK 1A -- Priority List Developaent Evaluation CThis task will
e closely coordinated with Activity T)
'his task will address how the
TASK '\3. -- Analysis for consistency of ell -•a.'ior Hger-cy documents
cr. whrea cher.i calls (cadniiuia. arsenic. ~.r ichlorethylene) ,
This .subtask is being conducted by Elaine 3ild anc .John
Gevertz. . The first draft will be completed by March 15th. Ail
•ca.jor support documents have been gathered, and a-= being reviewed
to Identify specific a-nd generic redundancies and Inconsistencies
aniong program offices. This analysis will be provided to the
Activity 2 leader to assist in the overall risk assessment reiev.
TASK'1C — Consistency of Cost ?er Unit of Pollution/Risk .-••-..
Reduction . . .
• '
"Vs subtask will assess the cross-program, cr-css-aedis
consistency of costs iraposed by EPA program office regulations on
cheaica'is of concern. Realizing the critical constraints (such
as different exposure pathways, risks, and legai^suthorities), we
will t;
Thi:
ooiicv rccccaendations if the consistency is less unan
appropriate. Bollis Call of OTI will lead this contract study.
Schedule/Cost
c=-sleted by
-------
TASK -ID -.-
get Populations
This subtask addresses issue of whether or not I?A offices are
consistent in defining the "target populations" (populations st
risk) that they are intended to protect (e.g., in teras of aaount
of food and water intake, adult and child weight classes,
etc.). Tnis subtask will identify any inappropriate
inconsistencies and policy needs. The completed task will
provide a 3sjor input to Task 2. Sar.di lee and Avis Robinson, of
OTI will conduct -this analysis. The initial craft should be
completed by March 15th.
TASK 2 — Agency Cancer Policy (and other health effects).
This task was initiated as -a ccansittee effort in 1980 under the
auspices of the TSPC, and is addresseing aajor cancer-r^ ateci
issues, including: • ' : ' c-ei-c«
Should the Agency have a generally agreed upon
- , carcinogen risk "ceiling" and "floor" to assist s»tHrg
priorities ssong chemicals?
Should- the Agency set toxics priorities based on
individual or aggrgate population risk?
Since this is a rsajcr, ongoing task vith high level Agency staff
participating. and lies conceptually soaevh«re between activities
2 and 3, it will in fact function as an autonomous activity
"feeding .into" activities 2 and 3 .
TASK' 5 — TS?C Task Group Pilot . • : .
3 A --. "S?C Solvents Task Group . . ..; :. _ _?
* '- » • ~ '
The TSPC Solvents Task Group, chaired*by Arnie Zdelaan of OTl,:r is
c. pilot effort initiated in August, 1950 to. assess the cross—
Agency integration issues involved vith these 5 organic solvent
degreasers. After the task group's initial issue/status report
to the TSPC in December, the work group was charged to develop an
Agency control strategy for these checicais and to act as a
"sini-steering cosaittee" to ensure that any related, regulations
are consistent with the developing control strategy. The
solvents work group will also act a as a. sounding board in
reviewing/assisting OTI .analyses of (1) intentional and
unintentional intermedia transfer of chesicals, especially
volatiles; and- (2) the effect of £?A controls on the use of
chemical substitutes that r.sy be cf equal or greater risk.
The TSPC Solvents task group is a -ajor, pilot attempt .to
-------
r01"*-^0 ,regUlat°ry and ^"-regulatory approach. ..
wi'th the mc aUen5pt t0 coordinste its activities
Schedule
The^solvents.vork group's draft work plan entails $100 X in Oil
nn^n!n/U??0rtTJ!£ an. additional -$190 K in needs. The schedule
is Dependent on TSPC approval and funding. If tasks are not
-n^la^ 1D Msrch> fin£l work Sroup results will not be unt
-------
n* these c^< ^ c^rscteristics. .regulatory, and action levels
?iS-?"^ i°-ls.t0 aSS1St £?A *€Sions to set prograo
xi!l%U;es.an? lo infora ^e public how EPA is responding to •
^n^-?"10;1 r*Sks' In a«ition, 071 will identify ^ajo^
.:!:!?•:?;i'fnd ?°\ic>' issues f°r the Integrated Toxics Strategy
.0001 u-ee to resolve, assign program.office responsibilities for
•esolving, or establish additional 7S?C work group(s) to resolve.
The overall 1?? process will be evaluated in terras of its
effectiveness, in promoting greater toxics integration and -
potential "stronger" variants of the process that could be aore
effective.
Staffing
071 — 2 workyears plus'$115 K in 071 contract support
Support in identifying and abstracting infonaat*oA" on
tne 20 chemicals from CAQrS, On:?.S, ODW, CSV. "ORD O7S"
and Or?
Schecu'l e- ( s c h e.c u 1 e a t z a c h e d)
The benzene and arsenic cocusents are in draft fs.-3 and
should be in final by the e.r:c of February
7he regaining packages will be completed by Augus-t.
7ASK 5 —. Potions for Better Integration of Agency 7oxics
Aetivj-ties
The previous four tasks will provide a basis* for 'assessing (1) :
where and to what extent the Agency.-is not properly integrating,
its toxics-related . activities, and (2) the utility of the '". "~'-V
ongoing, pilot integration efforts (or modifications cf these
pil"bts5 for broader application in FY 1982 and beyond. '. : ;,:, ,
^
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3- Intermedia priority pollutant process' for additional
chemicals of concern.
C. Require control options analvses on all toxics
regulations prior to AN??,M
D Keiew and evaluate agency toxics-related contracts for
overlap and potential inconsistencies
E. Require each program to rcaintsin its toxics-reacted
activities up-to-date in a central data systes~(a la
Pro
Besults in least distrubance to present programs
Con •• "JL
Suffers frcns sever* -eckr. esses of Agency vork
groups (regulatory or ~S?C); lack of interest and
'attention frora other I?A offices.
Increased Integration Authorities
A. Develop detailed guidance for all materials balance,
exposure, health, and risk cssessr-er.ts cone by £?A.
.•
• •
One central office to reviev/approve. sll such
'"
on
• _,*""
B. fora 2 series of standing, -ork groups (based
chesicsl "classes" and/or industries) responsible for •
all reguiation-developaent in that, category. _ • ...
* Incorporate responsibilities as z aajor cos-ponent.
•'*?•--- of perforsance stand-arcs »* . '•"•""" •."-:'- • •
C. - Hecuire sore specific and directed analyses "of
• ' interaeois iopsct of regulations prior to their
proposal and prosulgation. ..' - .
P_ ' • • ."••- •
• O • • - ; .- '-
Provides enhanced capability for integration
Con
5T.iil does not ensure integration among work
groups or supporting prcgra." offices
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I!. .Cent, -feii^u toxics integration Function
• . •
.'A. Toxics priorities for entire Agency set by one office
(probably Oil) '
Individual prograa offices then assigned specific
or lead responsibilities
3. All toxics-related assessment activity conducted by one
office (probably -in ORD)
C. All toxics-related analyses conducted by one office
(probably in OPE)
D. Standing control work groups using products of 3. and
C. ' ."
• **. • ~ ~ *
Each work group to develop s control options •
analysis for rsview/evsluaticn/cpprovsi by A.
before developing an Agency-wics control strategy
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DRAFT WORK PLAN FC? ACTIVITY 4:
NALYSIS OF TOXICS INTEGRATION BASED ON INDUSTRY-SPECIFIC APPROACHES
This activity will attempt tc develop industry-specific
trategies fcr control of conventional and toxic pollutants.
he goal^of these strategies is to identify the most cost-effective
ay to minimize health and environmental risks associated with
ndustrial discharges. The FY 81 focus of this activity will be
wo case studies, one dealing with a portion of 1±e organic
hemicals industry and the other with a subsector of nonferrous
etals. •
Each of these studies will characterize the nature and
acnitude of the pollution problems specific to the given industry,
centify available information on exposure and risk from the
ollutants, assess the combined environmental and economic impact
f various levels of regulation, and attempt to' craw conclusions
n the need for priority-setting among environmental media and
ollutants. Each study will lead-to the development of a sample
nternecia strategy. Together, they should enable EPA to design
preliminary strategy fcr coordination and priority-setting
none the various regulations that could be imposed on any industry.
*
A. -- .
^f —•—
ASK 1 Select Appropriate Subsectors for Analysis
Criteria for selecting the subsectors will include:
«»~~ Availability of data on-the economics of manufacturing
operations and data on environmental loadings, exposure,
• 'and effects;
8 Existence of intermedia tradeoffs;
0 Existence of interpollutant tradeoffs;
0 Possible tradeoffs among different parts of the subsector
(e.g., "big" versus "little guys"); and
0 'Locical factors that make the candidate subsectors either
particularly coherent or interesting.
Staffinc: All members of the project team plus delegates of
each of the major program offices (Air, Water,
Solid Waste, Hazardous Kaste, Tcxics, and
Drinking Water).
-------
' Schedule:
0 Separate meetings will be held on February 18
for organic chemicals and nonferrous metals.
3y February 23, a memo providing analysis of
options and recommendations will be sent to
Dan Beardsley, Roy Ga~.se, and K-arilyn SracXen.
0 3y February 27, the selection of subsectors
will be finalized.
['ASK 2 Collect Data for Each Selected Subsector
Both the data for the risk assessment and the economic analysis
should be developed according to three scenarios:
0 Assume that no Federal pollution controls vere mandated.
0 Assume that only controls already installed are required
in the future. ,
0 Assume that all Federally-required controls are installed
according to schedule.
0 Assume that (for organics) that generic controls replace
chemical-by-cheniical controls in the. air media..
To the extent they -may te relevant, the study teams should
also "consider the environmental .effects of other Federal programs
(such as OSKA regulations) .
scenarios will enable the study team to determine:
e :What "baseline" emissions would be in the absence of
JFederal pollution control regulations;
The magnitude of current untreated pollution or
residuals; and
The magnitude of pollution problems in the- future"
according to a "business as usual" scenario.
The maonitude of the air pollution problem if generic
controls replace cheraical-by-cheiaical controls on the
organics industry.
3y assessing the cost implications for these scenarios, it will
oe oossible to determine the "economic burden" of current and
projected pollution controls that might be shifted to more
V.-ortant health and environmental problems without increasing
Iv£ ,ni,-r-< sated level of control-related expenditures.
-------
, «iven that the various subsectcrs of the nonferrous metals
ndustry are less diverse (fever plants, products, and ollutants)
a- z.ie suosectors o
erse fever plants, products, and pollut
f the organic chemicals incustrv, analysis
. zhe former will probably deal with specific facilities while
r,a lysis o* tne latter will probably focus on surrocates, such
s "generalized plant configurations":
Staffing: 1. The following EPA offices will develop
information on environmental loadings for
. each of the above scenarios:
— For air emissions: . Office of Quality Planning
and Standards (OANR) .
— For effluents: Effluent Guidelines Division
(OWNM) . ' ' -.
--For drinking water quality: Office of Drinking
'water (OV7WJ5) .
--For solid waste: Office of Solid Waste (OWWM) .
--For hazardous waste: Office of Enforcement.
2. Health effects date, and information on
population exposure will be provided primarily
by the Office of Research and Development and
the Office of Pesticides and Toxic Substances.
. JQ- r~L-M - -
3. Co.st data will be provided by the individual
program offices-.and will be further refined
by Putnam, Hayes, and Bartlett, Inc. and
appropriate subcontractors. Fred Talcott •
.-- and Jim Titus, both of 0PM, • will supervise
the economics effort for organic chemicals .
and nonferrous metals, respectively.
Schedule:
1. Complete the environmental assessment by April 1
2. Compile basic health effects data by April 15.
3. Develop baseline manufacturing costs for the
nonferrous metals subsector by April 21. To
the extent possible, provide information
specific to individual facilities.
4. Develop "generalized plant configurations" for
the selected subsector of the organic chemicals
industry by April 1.
5. Develop-' .the cost inforrr.atior. on the other three
regulatory scenarios by late .-.pril.
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"3 Calculate and Prioritize the P.isks to Public Health and
other -nv iron-en tal Values for Each Pcllutar.t Stream
This effort will build on the data collected
-------
jrcen" and a possibly higher level of resource constraints,
ttecks-_the worst public health and other environmental problems
rrst, (b) treats public health threats consistently between
vircn-ental media, (c) considers economic impacts'on both the
rosperous and less prosperous, segments of the" industry, and
c) reflects the differences in environ-.ental risks associated
•ith different plants due to their individual locations. This
:2sX is meant to pull together Tasks 1 through 3. It will require
merging the risk assessment with the economic analysis, and will
•rr.phasize concepts such as cost-effectiveness and trade offs
Between various pollutants. This will be a major focus cf the
discussions with industry and the individual program offices.
To be.most useful, it should clearly articulate all major
assumptions, alternatives, and caveats.
Designing the sample intermedia strategies (including process
changes that could be ordered under the Toxic Substances Control
Act) may require the development of new control cost, estimates.
To the extent this is cone, it rr.ay be necessary to use crude
ccorcxima tior.s, rely on the experience cf other industries, or
r-ake orders of .magnitude, judgments. The basis for such estimates
should be clearly articulated.
Staffing: This aspect of the study will involve the whole
work group. The managers and consultants
responsible for the risk assessments and economic
analyses will be particularly important in this
exercise, as will George Proverzsno of the Office
of Research and Development, who will provide
guidance on how best to merge"*the tvo types of
assessments for each industry.
Schedule: This activity will produce s. draft report by
mid-June and a final report by late July.
^ •
T*SK-5" "Evaluate the .-.pblicability of the .-.pproach.es Taken and
Develop Recc-umendations for a General Industry-wide Approach
Based on the preceeding tasks,.it should be possible to: .
• Identify industries that should be studied in FY32 to
•continue this research effort, and
• Develop general conclusions about toxics integration that
will be useful.
-„ *var- -incustrv case studies should be more representative of the
to'alranc'eo" industries and provide a better basis for generalizing
about needed changes in regulatory, statutory, or analytical
-^roachls. The coal of such studies will be to develop well-
suooorted conclusions for improved integration of toxic control
strategies in FY 83.
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3y .Vcgust 1981, however, it should be possible to offer
relir.ir.ary conclusions for consideration by senior management
at e?.~. and tr e Office of Management and Budget. For exair.ple,
for the industries studied, it should be possible to state
whether control of conventional pollutants should be de-emphasized
to free up resources for better control of toxic pollutants in
certain circumstances. It should also be possible to identify
ctat gaps that prevent analyses of this sort from being as
complete as one might like for regulatory purposes; analyze
whether toxics problems can adequately be addressed through a
multi-media regulatory development approach; and shed light en
resource and other implications of adopting such an approach
across other industries.
Staffing: the whole project team and the consultants.
Schedule :
• 1. Develop a draft report su--,arizing, the
results this task and the preceedirg ones
by late July.
2. Issue a final version of the report by
August 11, 1981.
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Os
TOXICS INTEGRATION PROJECT
Geographic study: Workplan
I. General- Goals of the Geographic Approach
The general goal of the geographic approach is to define and test a
methodology whereby geographic studies could be made a prime means through
which the agency's toxics control activities are carried out.
Both the pollutant-by-pollutant and the industrial approach to integ-
ration seek internally consistent and nationally appropriate systems of
regulations. The geographic approach looks at the issues from the opposite
direction, seeking unique and locally appropriate solutions to toxics problems.
These solutions may or may not depend on the existing national control pro-
.grarns to achieve their goals: certain aspects of existing programs may be...
either irrelevant or even counterproductive in responding to local problems"
cS defined by this approach.
This activity wi 11 therefore develop a methodology through which state
end local participation—and control authority—night be enlisted nore
effectively to serve national pollution control goals. It will seek ways
to integrate the federal and non-federal resources in such a way as to ir;aximize
public health benefits locally, and minimize costs to all participants {industry
as well as all levels of government).
In the current year, the project will be concerned both with the general
methodology for organizing and administering a geographic study, and with
the analytical tools necessary to conduct them. Methodological studies will
concentrate on administrative, political and legal designs of geographic
studies— how intra- and intergovernmental roles and responsibilities can be
defined, how administrative and political ties with states can be tightened,
how state and local laws can be utilized to support national public health and
environmental goals. Analytical studies will concentrate on the task of
producing cost-effective tools for analyzing local toxics problems accurately,
and for. defining efficient controls. These are discussed in turn below.
Kethodological Studies
EXHIBIT A shows our prototype methodology in schematic form. Absent
from this flow diagram is any discussion of technical assessment issues:
these are presented in the following section under "Analytical Studies."
The key here is to define the interrelationships of EPA with the states and
local governments, and in the later stages of strategy development, with
industry and the public.
Since toxics problems are known to be usually most severe in metropolitan
industrialized areas, where concentrations of industries discharge effluents
into confined ecosystems near concentrations of population, testing of the
methodolgical approach will emphasize urban situations— both in terms of meth-
odology development and analytical techniques. But ultimately the methodology
should be generally applicable, even to contexts where toxics problems .are
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minimal .and existing control programs (perhaps) excessively stringent..
Costs are discussed as a methodological issue because of the crucial role
,hey play in allocating emphasis, and responsibility, between seoments of this
methodology. Cost estimates for most elements of a geographic study will come
from the analytical studies (pilot studies) conducted, but the overall method-
ology must offer strategic guidance on how to allocate limited resources between
activities. Overall estimates of costs are also critical in determining a
general strategy for when and where to do geographic studies (Step A) and
how often. It may be that such studies could become a regular part—even a
predominant part—of agency activities, or it may be that they would be
employed very seldom.
The following sections briefly discuss the methodological and study issues
involved in each of the prototypical steps listed on EXHIBIT A,
STEP A
Before geographic studies can be routinely conducted as part of a toxics
control- program, a methodology or procedure for identification of potential
problem areas will need to be devised. THe methodology would essentially
consist of a procedure that would, through the use of existing data, screen
out. those geographic areas that are likely to have sub-population groups ex-
posed to higher than tolerable levels of toxics (however defined) in one
or more medi a.
Sone constraints on formulation of the methodology would be:
o it should not require collection of new data, i.e., should utilize
existing data bases.
o potential problems should be quantified such that priority lists
can be developed.
o in view of the fact that the selection methodology will be applied
in a large number of cases, it should be relatively simple and
non resource intensive.
*
• -^
Study Issues for FY 81:
o Study technical factors to be used in formulating the selection
criteria
o • Examine the adequacy of existing data bases for making site selections
o Define the role of federal agencies (EPA and others), states and
locals in the sites selection process. (Should the selection process
be left to the states with EPA and other federal agencies merely
providing technical support and input?)
STEP B
Following selection of a site (using procedures in Step A), the next
step would attempt a preliminary analysis of existing data designed to show
probably sources, pathways and exposure levels for a selected group of
-------
toxics. The group or list of chemicals to be subjected to further studies
should be identified in this step, and will likely be taken from the list
of 20 intermedia priority pollutants and any other local chemicals of interest.
hese table-top" analyses should also provide indications of the problem
inedia around which field sampling and data collection efforts would be
designed.
While it would seem logical for EPA to take the lead in the development
of standardized modeling and forecasting techniques, the role t>f local and
state governments would probably be greater in actual application of the
techniques and the ensuing analysis of data and results. States could
concievably take the responsibility for performing these analyses (as they
presently do for water-quality based effluent limitations) with technical
support from EPA.
Study Issues for FY 81:
o To the extent possible, define the most efficient allocation
of responsibiliteis for this task among the federal agencies,
states, end local governments.
o ., Assess the adeqaucy of existing techniques and data bases to
perform- such desk-top analyses, identify deficiencies and rem-
edial measures, and their costs.
o What are the costs of the studies to EPA and the states?
o What are appropriate sources of funding to support these
activities?
STEP- C
It is likely that in many cases, existing data are insufficient to
adequately assess and define local problems.. Presumably, the table-top
analyses will show up these deficiencies and also provide information on
areas/media requiring more study and/or data.
This step should produce, through a cooperative effort between federal,
state, -and local entities, a field sampling program designed to fill data
caps revealed in the previous step. Methodological questions will include
examination of appropriate divisions of effort between participating parties,
estimates of unit costs for various types of studies conducted, establishment
of standard sampling protocols in various media, and so forth. Political
questions may arise as to public involvement in this phase, particularly if
media to.be sampled are publically conspicuous and may arose public interest
or anxiety.
As is discussed below under Step F, this step may be iterated repeatedly
in order to arrive at conclusive evidence. Either in the first or in sub-
seouent iterations, health studies may be indicated, including direct
sampling of tissues (hair, blood, urine, adipose), or other types of epi-
demiological work. Due to the costs and legal issues involved, and the int-
erests of other agencies (CDC), analysis of the health study Tssue should
be a special sub-element of this part of the study.
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Study Issues for FY 81:
o Define types of survey or field sampling techniques that may
be useful, including standard unit costs.
o Tackle the health issue directly, determining criteria for
undertaking such studies and for not undertaking them.
0 Establish formal relationships with health organizations and other
with special authority or expertise in relation to any of the
study activities affected.
o Examine relative roles of EPA,.states, and localities.
o Define protocols for inserting obtained data into existing
EPA systems (TOXET, STORET, etc.)
STEP D
Once a plan has been developed to obtain further environmental or health
data, protocols for analysis must then be defined. At this point we assume"
that this step is a minor issue, since most tests will have to have national
uniformity, and thus EPA is expected to have sole authority in defining these
protocols or in reviewing the protocols of other federal agencies with
jurisdiction (CDC,'OSHA, etc.).
Study Issues for FY 31:
o Review availability of existing protocols for categories of
tests described in Step C.
o Commission development of protocols where gaps or technical
problems exist.
o Coordinate as necessary with other agencies involved.
Step E
"At this step, analysis of samples and interpretation of results will begin
to-yield indications of the true extent of problems tentatively identified in
Step 3. It is important that the interpretation of«test results be made in
relation to uniform risk assessment protocols, using, for example, consistent
assumptions about population sizes and distributions, consumer habits, and
other factors affecting exposure. (See also work pi an for Activity 2 of this
project.) Establishment of these protocols should presumably be solely an
EPA function, since they should be uniform across the country and based on
the most- advanced risk assessment methodologies.
Other methodological questions of importance here include who pays for
lab work using what funds: certain costs may be assumed by states or localities,
others may be reimbursed through federal grants (including those from non-EPA
sources). How much should these responsibilities be formalized across studies,
to what extent should they be ad hoc?
FY 81 Study Issues:
o Identify uniform risk assessment protocols
o Analyze costs of basvc analysis methods for reference use in regions
-------
o Determine requirements of quality assurance program
o - Determine approaches to equitable distribution of buirden between
participating groups
o Identify appropriate sources of grant funding (EPA, mon-EPA)
Step F
At this step, EPA and participating state and local groups would decide
whether the data gathered offer conclusive evidence one way or another about
the nature and extent of'potential toxics problems. Improved data could, if
necessary, be fed into the models used in Step B. If data are-found to be
to any extent inconclusive, the methodology would at this poirnt cycle back to
Step C, where new sampling or study techniques would be commissioned, such as
body burden or other epidemiological work on selected individuals or subpop-
ulations.
To the extent that national health standards or other external criteria
do not guide decisions to conduct more studies, how should these decisions
be made. In the absence of consensus, should EPA have the dec-ceding role, or
"the states? What weight should the opinion of other federal Agencies (e.g.
CDC) be given? How formal should this process be? What tradeoffs should be
nade between costs of additional data gathering and conclusiveniess of existing
study results? Finally, once conclusions are reached, what criteria should
be used to rank the problems identified in order importance? im order of
treatment?
FY 81 Study Issues:
•
o All above issues will be addressed empirically withiin the pilot
studies. Experience there will guide the strategy recommendations.
STEP G
Once the identity of problems is known to the desired decsree of accuracy,
control "options for correcting then can be developed- Some ccartrol options
could operate through the regular EPA problems, but we expect tthat degrees of
control above and beyond customary levels will be needed in certain cases.*
Alternative control techniques, especially those that could be imposed by
states or localities, must be considered. Generically, responses could -
include technical controls on sources, modifications of sources/receptor
relationships (from relocating sources to relocating populations, and steps
in between) and modifying receptor characteristics (treating drinking water
rather than'controlling industrial effluent into streams). Each option should
be costed out, and its benefits estimated.
At this point it may be desirable to involve the public in listing options.
It will almost certainly be necessary to consult directly with industrial
representatives where industries are identified as problem pollution sources.
Key methodological questions will revolve around the type and degree of
quidance needed in defining technical and non-technical control options, and
in estimating the efficacy of each. Should EPA be the final arbiter of
» TKP n-ilot studies, for instance, will be conducted in metropolitan areas
where unusual toxics problems will probably exist after imposition of all normal
controls.
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efficacy (enforceability as well as technical effectiveness)? To what
extent to the existing acts influence the permissable range of control options,
especially those which are alternatives to customary program controls?
Study Issues for FY 81:
o Compile a catalog of alternative control measures
o Review current legal constraints on their use (especially
in terms of laws EPA administers—see Activity 1)
o Evaluate EPA/state/local roles empirically through the pilot studies
STEP H
In the final step, a control strategy or strategies for identified problems
will be developed jointly between EPA and the affected state and locality.
At this point, cost/benefit assessments must be made, and must be balanced against
ell other relevant considerations: political acceptability; distribution of
costs among different levels of government, industry, and the public; enforce-
ability, potential adverse intermedia effects, end so forth. It will probably
not be.possible to develop detailed guidance on most of these issues; rather
the intent' will be to devise a methodology for making issues and tradeoffs
explicit, and for structuring judgments for decision. As before, we must attempt
to define appropriate relationships between the various parties affected:
who has the last word? what is the relationship between this process and the
regular administration of EPA programs?
In order to approach the issues here, we must study the relationships be-
tween EPA and state/local authorities in some detail. Where controls applicable
to toxics are concerned, are there any gaps where no authority exists to reg-
ulate a class of problem? _Are there overlaps between authority, where one
would have to choose the level of government, at which control is exerted?
Are there instances of actual interference between state and federal authorities
over a certain class of problem?
Also included in the strategy must be explicit assignments of responsibility
for monitoring and enforcement. We must include consideration of accountability
mechanisms between EPA and the states and local governments: these could
build on present SEAs, but could also include other devices (MOUs, contracts,
new state legislation or planning programs, commitment of local police powers).
These accountability mechanisms must be carefully examined to determine the
degree to which their use is consistent with EPA's legislative mandates.
Study Issues for FY 81:
o If possible, create guidelines for cost/benefit evaluations
o Investiaate types of possible accountability mechanisms, and
their legal status in relation to EPA legislative mandates
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Analytical Studies
Steps B through F involve complex analytical examinations of local
nbient environmental conditions in relation to toxics exposures and risks.
in the_past, EPA has attempted various approaches to geographic analysis of
this kind, generally in areas where under the existing programs it is unlikely
that observed or suspected toxics problems can be adequately corrected: in
such areas, local concentrations of industry and population can be expected
to lead to_undesirable levels of toxics-related health and environmental
risk, despite the application of nationally appropriate environmental
standards and controls. . In various ways, the projects previously sponsored
have sought to answers to the following questions:
(a) What are ambient levels of toxics now, and what apparent health
and environmental risks do they impose?
(b) What are the sources of these toxics?
(c) What ere the potential pathways between sources and
receptors?
(d) Wi.ll the normal application of EPA programs reduce-ambient
toxics levels to acceptable levels (are we regulating the
key toxics pathways stringently enough)?
Building on past experience with projects of this sort will directly aid the
development of a geographic strategy.
We know fro-; past experience, however, that trying to analyze geographic
areas to answer such questions is time consuming, expensive, and usually
inconclusive. Our limited aim for the first year is therefore to test the
general feasibility of existing tools and existing data. How far do these
carry us toward the requirements of Steps B'through F? What are the costs
involved? How can we overcome data gaps and- methodological problems? How
expensive will it be to gather conclusive evidence? What innovative altern-
ative techniques are available to fill gaps in our current knowledge?
'We propose to focus our first year efforts as* follows:
1) Evaluate past geographic studies
Past attempts at geographic analysis offer technical and procedural
lessons, especially on identifying avoidable problems. We will
' document these in brief case studies. (Task 5.0)
2) Commission two pilot case studies
Proposed sites are north" Philadelphia PA, and the Kanawha Valley
in West Virginia. Principal elements will be:
a. To assess sources and ambient toxics quality in the case
study areas (Task 1.0);
b. To forecast (if possible) the future effects of current.programs
in the study area (Tasks 2.0 and 3.0); and
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c. To research innovative methods for controlling discovered
toxics problems (Task 4.0).
3) Integrate the findings of these activities into the general
meinodoTogy
II. Structure of this Workplan
This workplan 'incorporates all the elements of the general toxics int-
egration project workplan, but has not yet ennuroerated more general tasks
related to dealing with all the methodological questions raised above. In
some cases the schedule has been changed: at this point it appears that the
detailed pilot study design (which now will involve considerable contractor
input) will not be complete until March 14, although the general pilot study
design will probably be approved ahead of schedule; the catalog of alternative
controls is now scheduled to be. complete two months earlier than originally
pi anned.
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TASKS
1.0 Pilot Studies
1.1 Workplan develop.
i.Z Pilots
(Status reports)
1.3 Recommendations
2.0 Air Forecast Methods
2.1 Develop methodology
2.2 Apply to sites
3.0 Hater Forecast Methods
3.1 Improve methodology
3.2 Apply to sites
4.0 Catalog of Controlj
4.1 Research and Report
5.0 Case Studies
5.1 Selection of subjects
5.2 Research
5.3 Final reports
6.0 Project Management
6.1 Budget outputs
(Status briefings)
6.2 Strategy
—X
(draft)
fl
(final)
(MTGs)
X
(ARC)
X
(draft)
X
(fin
X = briefing, informal report
B ° formal written report
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ACTION
METHODOLOGICAL QUESTIONS
Select Site.
Conduct "table top" studies, based on
secondary data and various modeling and
forecasting techniques, to determine
sources/pathways/exposures of probable
concern.
o. technical basis?
o administrative/political-
basis?
o relationships with
states?
o . EPA/State/local roles?
o definition of data items?
o role of health studies?
o costs to EPA?
o costs to States?
o sources of funds?
o modeling methods?
C.
0.
Design and conduct field sampling or other study
techniques to acquire necessary additional data:
ambient, effluent, effects data, health studies
Define analysis protocols for samples collected
o methods? ~
o costs? sources of funds?
o EPA/State/local roles?
o role of other federal
groups?
Can we assume sole EPA
responsibility?
E.
Analyze samples and interpret results in relation
to standardized risk assessment protocols for
population exposure
•Does total data conclusively define sources/ »
pathways/exposures of concern.
G.
YES
0
Define universe of possible control options:
technical controls, modifications of source/
receptor relationships, receptor modification
H.
Select preferred option, devise implementation
strategy, enforcement strategy, monitoring
strategy
o costs of analysis?
o sources of funds?
o consensus on risk
assessment protocols?
o EPA/State/local roles?
o relation to national
standards?
o Who has last word?
o EPA/State/local roles?
o catalog of alternative
control measures?
o role of industry?
o role .of public?
o relationship of EPA/
State/locals in strategy
definition?
o cost/benefit guidelines':
o who enforces, who
monitors? accountability
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TASK l.Q PILOT STUDIES
The pilot studies will have limited goals.
1. To establish how far existing data and methods can take us in
analyzing geographic areas and prescribing solutions.
2. To describe deficiencies in existing data and methods.
3. To define (as far as possible) how these deficiencies might be
remedied, and at what cost.
4. To catalog innovative and alternative approaches to control
applicable to these and other sites, especially in relation to
intermedia effects.
Many problem areas are.already visible. The following are among
the major ones; others will undoubtedly arise.
Actual "effects" information is not part of the study: it is hard
to document toxics-related health and environmental effects, esp-
ecially since these usually have long latency periods. We will
therefore have to design the study primarily around desired ambient
levels (e.g., water quality criteria) and estimated exposure-related
risk levels. We may be able to link with such groups as NIH for
limited reviews of local health effects.
It is impossible to analyze all toxic compounds of interest: even the
"short lists'1 of toxics IMESHAPS, consent decree, TIP list of 20,
• RCRA) may exhaust all available funds for analysis; some protocol for
defining substances for geographic consideration is necessary.
,»
Toxics-related ambient standards.have many problems: inconsistencies
between standards (e.g., water quality criteria vs. MCLs), poorly defined
definitions of compliance/non-compliance, uncertain numerical values.
Ambient toxics data is generally poor: the Chesapeake Bay study has
. • unusually good toxics data on water, bu,t most other ambient toxics
data, especially for air and groundwater, is sketchy at best.
. Effluent data on toxics is not much better: some estimates can be
made on the basis of permit and process data, but this is unlikely to
be hard enough use for an enforceable control strategy.
t ,
Model ing techniques have serious methodological and definitional
problems:the water dilution studies, for instance, tend to over-
estimate projected problems; methodological improvements are needed,
but corroborating monitoring is also needed.
Before committing to further work on a geographic approach in FY 82,
we must determine if problems such as the above invalidate the entire con-
cept of a geographic approach to toxics analysis. We hope that the first
year's experience will provide us with a practical methodology that can
'be fully developed over the second project year.
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- 4 -
Design of the pilot studies
- Our preliminary plan for the pilots follows. We will focus in parallel
on defining ambient quality in air, surface water, groundwater,. and soils, and
in characterizing all effluent sources contributing to these media. :Solid
waste sites — including regulated and unregulated (abandoned) sites-wriTl! be
treated as sources to these media. Once this data is explored, we will
attempt to predict changes in ambient quality due to the controls imposed by
the various environmental programs using techniques refined in Tasks 3 and 4.
Host of the technical work will be done under contract under tfes tech-
nical direction of Dr. Alvin Morris, Deputy Regional Administrator esf
Region II.
\
TASK 1.1 Develop workplan for conduct of geographic pilots
The geographic approach is to be tested through one or two pilot studies
of selected areas. These areas will be selected within Region III, a-nd will
be selected by that Region's sta
ff
Gocl s- of the. pi lots are to:
To determine the adequacy of existing data and methods far definition
of multi-media toxics problems in given geographic areas,
To describe deficiencies in existing data and methods,
To define remedies to these deficiencies and the costs of
correcting them, and
To determine the magnitude and nature of toxics problems K'-kely
to persist following the implementation of most stingent regulatory
controls (see also Tasks 2 and 3).
Major elements of the pilots studies will be:
Determination of present ambient quality* for air, water, e:nd
land/groundwater,
' Inventory of existing sources of pollution to these media,
Estimation of of likely emission rates following imposition of
regulatory controls,
Effects of these continued emission on future ambient quality, and
Development of remedial control strategies, including cost;
estimates.
In this task the contractor will be directed by the EPA project officer in
development of a detailed workplan designed to complete each major element
listed above. The workplan will include:
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- 5 -
1. Specific activities (sub-elements) needed to complete each element
. above for the selected area(s).
2. Scheduled dates of completion of each activitiy.
3. Resources to be allocated to each element and sub-element.
4. Identification of individuals/offices responsible for each
sub-element.
•
This_task must be completed in consultation with a list of EPA staff
and officials to be provided to the contractor upon commencesaent of work.
The final workplan must be explicitly approved by the Deputy Regional Admin-
istrator for Region III.
Output: Workplan document
Period of Performance: Three calendar weeks from commencement of work
Estimated level contractor effort: Five person weeks
FASK 1.2: Conduct Pilots
A. AIR'ASSESSMENTS
Produce those air assessment outputs assigned to contractor in TASK 1.1.
Under the air assessment element of the workplan, not ell sub-elements
will be assigned to the contractor. Major activities under this task will
be directed at the following:
Ambient Air Studies
a." Existing monitoring data from all sources
- ORD
- SAROAD (NAMS, SLAMS, National Air Survey Network (metals))
' - Research Triangle Institute
b. Link to health data .
- OHEA estimates of risk for chemicals identified
Air Pollution Sources •
a. Inventory all sources
- Maiors (program listings, check local data ror non-filers).
- Minors (program listings, presumed higher prob. of non-filers)
-------
b. Toxic effluent profiles
- Majors: source by source (based on permit files, process assumptions,
monitoring data as available) .
- Minors: characterize by groups if technically necessary
c. Contrast (a) and (b) against expectations--!.e., knowledge of
Regional/State permitting personnel
d. Contributions of other sources
- Area (mobile source, small retail establishments; etc.)
- Hazardous waste sites/sanitary land fills (may link to other contract)
Forecasting Program Effectiveness
a. Methodology development: contractor may consult in development of
methodology under Task 2.
b. Application to sites
The number cf hours devoted to this task and the scheduled dates of
completio'n of each output will be provided in the workplarc-
WATER ASSESSMENTS
Produce those outputs assigned to contractor in TASK 1,1.
Major activities in this task will be directed at the following:
.«•
Ambient Water Studies
a. Existing monitoring data from all sources
- Chesapeake Bay study
- STORET
- Enforcement data files »
- others as available
Water Pollution Sources
a. Inventory all sources
< - Majors (program listings, check local data for non-filers)
- Minors (program listings, presumed higher prob. of non-filers)
b. Toxic effluent profiles
- Majors: source by source (based on permit files, process assumptions,
monitoring data as available)
- Minors: characterize by groups if technically necessary
c. Contrast (a) and (b) against expectations—i .e., knowledge of
Regional/State permitting personnel
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- 7 -
d. Contributions of other sources
- Area (urban runoff study for Baltimore, application of general
soil loss equation and runoff estimates for Kanawha)
- Hazardous waste sites/sanitary land fills (may link to other contract)
Forecasting program effectiveness
a. Consult as required in Task 3.
b. Apply improved methodology to pilot study sites.
The number of hours devoted to this task and the scheduled dates of
completion of each output will be provided in the workplan.
C. SOLID WASTE /GROUNDWATER LINKAGES " "
Produce those outputs assigned to contractor in TASK 1.1.
Major activities in this task will be directed st the following:
a. Source assessment
- '-'ap known Superfund candidates
- Map known hazardous waste/sanitary landfill sites
- Review existing aerials, for other sites
- Review whatever technical data exists on all located sites
(site contents, depth to groundwater, site integrity)
- Estimate loadings to groundwater (in conjunction with next task)
*»
b. Groundwater quality assessment.
- Review monitoring data on public (private?) water supplies
- State geologic survey assessment—perhaps data on contributions
- _ to local aquifer flow, degree to which contamination from
outside local area is significant
*
c. Drinkino water assessment
- Statement on extent to which drinking water is derived locally
(contrast ambient data to MCLs, if applicable; some linkage to
project 5 is possible)
- Map against population for areas exposed
0
The nutnber of hours devoted to this task and the scheduled dates of
completion of each output will be provided in 'the workplan.
D. INVESTIGATE INTERMEDIA CONTROL RESPONSES
Produce those outputs assigned to contractor in TASK 1.1.
Major activities in this task will be directed at the following:
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a. Develop approach for using assembled data to define potential
intermedia effects.
b. Assemble catalog of models for analyzing intermedia flows,
especially after imposition of alternative abatement assump-
tions.
c.' Conduct analysis of intermedia flows under alternative abatement
assumptions.
d. Recommend selected options with most beneficial environmental
effects.
The number of hours devoted to this task and the scheduled dates of
completion of each output will be provided in the workplan.
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TASK 2.0 AIR FORECASTING KETHOOS
In this task, headquarters staff in Washington and Durham (QAQPS) will
confer on the design of methods for forecasting the effects of projected con-
trols on ambient toxics concentrations of particular localities, such as
the selected pilot study sites.
This work will build on work already under way by OAQPS, partially under
a past contract with SAI Incorporated. A new contract may be let to trans-
late exposure assessment techniques applicable to national risk assessment
studies to a local context.
Tasks for the development of this methodology have not been described
as yet. Feasibility of this effort will be studied in parallel with the
development of the workplan, with suitable input from the Task 1 contractor.
Proposed tasks sub-elements are:
Task 2.1 Develop Methodology
Task 2.2 Apply to Pilot Sites
In conjunction with Task 1 contractor.
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TASK 3.0 WATER FORECASTING METHODS
At-least one method now exists for predicting the effect of future •
controls on ambient environmental toxics levels. Developed by OWWM for
surface water studies, this method first estimates current emissions of
toxics from known sources in a given river network, using permit and
process data available in-house. It then estimates the abatement expected
for each source under BAT controls. The resulting new values for toxics
emissions are then assumed to be diluted in the known 10-year, seven day
low flow of the river system. The ambient values for toxics'thus obtained
are compared to present water quality criteria; OWWM is thereby able to
screen for stream reaches that are likely to exceed water quality criteria
values after imposition of BAT.
This task will build on work completed in the Monitoring and Data
Systems Division. It will use past "dilution study" efforts as a basis for
developing a refined method of modeling the effects of improved point-source
treatment technology on ambient toxics concentrations in receiving waters of
the pilot study sites.
Produce those outputs assigned to contractor in TASK 1.1.
Mc'jcr activities in this task will be directed at the following:
Task 3.1 Irnsrove Methodology
a. Identify deficiencies and inaccuracies in methodology.
- Does methodology attempt to account for all sources and sinks
of pollutants?
- What simplifying assumptions h'ave been used—what effect are
these assumptions likely to have on accuracy of the results?
- Can some, all, or any of these assumptions be eliminated without
overcomplication of the methodology, thus improving accuracy?
- Are data, available to replace assumptions with reliable estimates?
b. Develop improved methodology.
- Examine identified deficiencies insisting methodology, assess the
magnitude of error likely to be induced by each deficiency,
and attempt to correct or minimize it.
- Determine appropriate applications of the method.
- Based on findings of preceding steps, formulate new methodology
designed to maximize accuracy while minimizing data needs.
(Likely to involve use of EXAMS model.)
- Describe data needs for'the new methodology.
Describe simplifying assumptions used in new methodology
and the likely sources of error.
- Focus new methodology on new applications.
Task 3.2 . Apply to Sites
In conjunction with Task 1 contractor.
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TASK 4.0: EVALUATION OF PAST GEOGRAPHIC STUDIES
The agency has undertaken several "geographic" studies over the past
several years, all of which will offer significant lessons both in relation
to the pilot studies and to the more general evaluation of the potential of
the giographic approach as a whole. This task will compile uniformly formatted
case studies of at least three such instances, and will review others as
they come to light.
The most important case studies (especially Memphis, perhaps also Beau-
mont) will be done in cooperation with the contractor working on the pilot
studies, since the approach and methods used will be important to the design
of the pilots. Other cases will be addressed by in-house staff; we estimate
that approximately one person week will be necesary for each. Staff exists
to compile approximately 12 case studies; if more are needed or if compilation
time exceeds one person week per site, additional staff will be required.
Task 4.1 Identify candidate sites for examination (February 19 - 25) -
a. Call Regions for names of sites, names for interviews.
Regions divided into groups. Will call S&A lab directors and
consult HQ personnel as necessary to identify sites.
Site selection to be final by 24 Febraury.
Presume inclusion of Memphis, Beaumont, Great Lakes,
Louisville, Birmingham, Love Canal.
Task 4.2' Develop uniform data requirements, finalreport outline
(already complete in draft)
a. Uniform data plan attached (draft' 19 February).
Includes provision for primary (interview) and secondary data
(existing reports, in-house documents, etc.). Assume no travel
required. Exception may be Memphis, for general study purposes.
. •{>.' Final report outline due 25 February *
4.3" Conduct studies (February 25 through April 15)
a Preparations (review of KQ data, phone calls): identify respondents,
"' necessary reports. Estimate 1 person-day per case.
b Conduct interviews and review secondary sources
(one person per case, average 2 person-days per
case)
c. Draft report (10-20 pp. max.; keep short; 2 person-days per case)
d. Regional review, redraft in final
Prepare executive summary, general conclusions, as necessary.
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JASK 5.0 CATALOG OF ALTERNATIVE CONTROLS'
A geographic approach to toxics integration is intended to discover pro-
blems that the ordinary operation of programs may have missed, or will be
unable to correct. It follows that controls to correct these problems raav
have to rely, at least in part, on methods unavailable to the Federal
regulatory programs, specifically regional, state, or local methods that
do not require national regulation.
Much work has been done in the area of innovative and alternative controls
for environmental pollutants. This task will compile and evaluate tools that
have already been researched and.developed in some detail.
The task will be completed in-house, using staff on the toxics integration
project.
TASK 5.1 Research Available Methods and Complile Report __
a. Research avai-lable Federal-developed tools for toxics controls
- Controlled trading
- Bubble/banking
•- , ,- other innovative controls as available
b. Research available State/local tools for toxics controls
(especially those applicable for Maryland and West Virginia)
- Non-point source runoff controls
(sedimentation and erosion control ordinances, subdivision
ordinances, zoning, performance standards)
- Emergency powers
- State pollution control legislation
(assess degree that it offers more stringent control
of water pollution, air pollution, etc.)
- Locally enforceable special purpose controls
(subdivision ordinances, special purpose zoning (e.g.,
emission density zoning), performance standards, etc.)
c. (If possible) Link selected control possibilities to recommended
abatement recommendations ft-om previous task.
t report will be complete by April 15, final report one month later.
This is a considerable acceleration of the original schedule, which called
for completion of this task effort by July 1.
The level of effort for this task has not been assigned; in order to
comolete it by the date stated, additional staff are likely to be necessary.
No contract support is now contemplated, but could conceivably be used if
time constraints require it.
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TASK 6.0 PROJECT MANAGEMENT
This general task will produce two main products: (1) budget reports
and briefings (as necessary) to both the media task groups and the Agency
Ranking Committee, and (2) the strategy itself.
Task 6.1 Budget Outputs
In coordination with TIP Activity 6, budget memos and briefings will
be prepared as necessary to allow the Agency to:
a. Assess current resources being expended on activities related
to geographic assessments.
b. Cost out options being developed under this Activity.
c. Integrate (to the extent possible) the developed strategy....
into the FY 33 budget request.
These materials will be compiled by the TI? staff in-house. No level
of effort has been assigned. MTG briefing materials will be available by
mid-May, ARC materials by the end of July.
Task 5.2 STRATEGY
The final strategy document will summarize the findings of all tasks
of this Activity, and include at least the following elements in relation to
the pilot studies:
a. Statement on link's between sources and ambient quality
b. Identification of sources
- Unregulated
- Underregulated
c. Statement on further data needs
• d. Statement on desired spot monitoring/other desirable analysis
e. Specify FY 32 workplan for two sites, if recommended:
- Development of further analytic tools, potentially including:
(1) Aerial surveys (use of Enviro-pods, remote scanning, overflights)
"Purpose: dump site location, remote scanning for all types of
visible and invisible plumes in all media, etc.
Sources.of expertise: NEIC, Las Vegas lab and other ORD sources,
Regions, contractors, other agencies, States.
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(2) Existing monitoring networks (air and water ambient monitors on
State and locallevels; effluent monitoring}
Purpose: general data review
(3) Existing data bases (SAROAD, STORE!, TOXET, Toxics Inventory, etc.}
Purpose: detailed ambient quality and exposure estimates
• (4) Original sampling and monitoring (dumps, abandoned sites, air
and water quality, groundwater, water supply, sludge quality,
federal facilities, human and animal tissues)
Purpose: multiple
(5) Epidemiological studies
Purpose: estimate effects of identified local exposures
(6) Mathematical models (SEAS, air diffusion oodels, etc.)
Purpose: multiple
- Development of cost estimates for all of above.
Any other documents or reports required under Activity 6 will also
be-'prpduced.
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TASK 4 ATTACHMENTS
Evalution of Past Geographic Studies
Background information for respondents
EPA is investigating the possibility of using a geographic approaoch to
integrating its toxics programs: this would involve any number of techniques
.aimed at investigating localized problems with toxics in the ambient environ-
ment, rather then only applying^nationally appropriate regulations and controls
to "local problems. Over the past several years, EPA has sponsored various
studies of local toxics problems (often emergencies). In our current
investigation of the geographic approach to integration, we want to use as much
experience from past studies as possible.
If any version of a geographic approach to controlling toxics is to be-
come institionalized, it is important to be thorough in identifying the
costs-and benefits of such past studies. The following questions are in-
tended to elicit information related to the costs of previous studies, as well
as to assess the relative success or failure of past efforts.
In this exercise of looking into past studies we want to identify
what led to each study—was it a particular health problem, odor problem,
citizens' complaints, or the Agency's independant concern about a potential
problem? What were the actual problems found (if any), and could they be
documented well? What were the benefits of thg effort? If problems
were identified but not resolved, what prevented application of suitable
controls: was there insufficant data to define the problem, were there
questions about the interpretation of the data, were there institutional
or cost problems related to cleaning up the problem? Or were there no
standards, no criteria, or no legislation or regulatory support for actions?
Your assistance in providing the following information is appreciated.
Please recommend the names of others who might assist us in obtaining nec-
essary information.
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INFORMATION WORK SHEET
SITE
NAMES AND TITLES OF RESPONDENTS (Phone)
(1)
(2)"
(3)'
etc.
SECONDARY SOURCE MATERIAL
(1)
(3) •
etcT ~ ~~ '
A. What was study area: town or city, county, state?
B. When was study conducted?
C; What caused the study to take place?
1. • Did a specific,problem exist, if so what?
2. When was the first indication that a problem existed? '
3. Were local and state agencies aware o£ potential problems and how early?
4. Were citizens aware that problems existed and how was 'this expressed?
,5. Why did EPA undertake study?
D. What activities did the study involve?
' 1 What actions did local agencies take? ( increased monitoring,
increased inspections, described situation to public, other.)
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2. What actions could have been taken by local agencies but were not?
3. What actions did state agencies take? (increased monitoring increased
inspections, described situation to public, other)
4. What actions could have been taken by state agencies but were not?
5. What were EPA's actions?
6. Which offices in EPA became involved: Regions, ORD, others?
£. What were the technical/scientific issues?
1. What was technical nature of problem?
- 2. Were,data adequate to define problems?
3. Did EPA have adequate expertise to assess the significance of the
problem in terns of risks or exposure? Explain.
4. In general, what did the environmental data show?
5. If data was*inadequate, what were the inadequacies?
data quality unknown?
disagreement on the interpretation of the data?
insufficient n°umber of stations?
unsatisfactory distribution of monitoring stations?
*
how was adequacy or inadequacy of data determined?
'•6 What other information was used (could have been used) to define
problem (e.g., aerial photographs, ground photos, site investigations,
etc.)
9
7. What were the recommendations for correcting problems?
f what were the political issues? (with public, with local government,
• with state government)
-------
. What were the administrative/institutional issues?
1. Why couldn't local agencies respond? (lack of expertise funds
authorization, etc.) ' '
2. Why couldn't state agencies respond? (lack of expertise funds
authorization, etc.) ' ' '
3. Did public accurately understand the problem bei-ng addressed?
If not, how did they perceive it?
4. How could communications with the public have been improved?
5. Was there adequate time to design the study?
How much time was there?
What was the driving force behind the study?
5. Were adequate funds available for the study?
* i •
;-;.. What were the costs of the study?
1. Cost to local agencies in work years?
Z. Cost to state agencies in work years?
• 3. Cost to EPA in terms of work years and contracts? (fill in table)
Work years" dollars_
in-house contracts
ORGANIZATION
Regions
ORD
. MEIC
Other (list)
'ACTIVITIES
Planning
Sampling
Data analysis
Quality assurance
General analysis
Source inspections
Enforcement action
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4. if funds were inadequate, what is the estimate of how much an
adequate study would cost?
-5. What type of work would be done with additional funds?
5. What type of control actions could possibly result from the
. additional effort?
I. What were the results of the study?
1. Did problem actually exist?
2. Was there a concensus between agencies of exactly what the problem
or problems were? Explain.
3. Were any controls or remedial actions taken to correct problems?
What type of actions or controls?
Who provided the funding for the corrective action?
If cgntrol actions were taken by private industries -did they do it
voluntarily?
Was legal action considered before action taken by industry?
Was action taken by industry after legal action initiated?
4. Was problem actually corrected?
• J. General Conclusions
1. What recommendations would you make to someone conducting similar
study?
2 What from your perspective, were the weaknesses of this study?
' ' ' How would you would advise people initiating similar studies in
order to avoid these problems?
'3 Even if the problem was corrected as a result of this study, could a
' similar result have been obtained through some other means, such as
the routine operation of existing EPA or state control programs?
t
4 Has the Region developed a general plan or procedure to follow
for future studies/responses?
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TOXICS INTEGRATION; OUTLINE OF THE REPORT TO THE ADMINISTRATOR
In addition to an Executive Summary, the report will
contain .an Introduction and sections or. Information Collection
and Analysis, Control Strategies, and Recommendations . This
outline identifies major features in each of those sections-
we cannot at this point, of course, detail conclusions.
The Introduction will discuss past and on-going efforts at
toxics integration, such as development of risk-assessment
methodologies and intra-agency work groups on pollutants.
Also, we will identify the important assumptions and goals of
the current study: the need to set collective agency priorities
on the worst threats to the environment; the need to focus better
EPA's limited resources; the need to factor economic impacts
more directly into the regulatory development process."-
A. EPA Must Make Its Data Collection and Analysis Procedures
" Consistent for all Programs
EPA can never achieve an integrated and efficient regulatory
process as long as its programs have individualized
procedures for identifying problems, acquiring information,
and analyzing risk and economics data. We need to improve
consistency and prevent duplication. No matter what
integration strategy — and what speed of implementation —
is chosen, this project will review with the expectation of
standardizing such basic procedures as: • *- "—
o more directed and coordina'ted priorities
for information collection on pollutants
and industries;
o an agency -wide cancer policy; ^
o agency-wide risk assessment methodologies;
b review procedures by independent experts;
o as much as possible, economic impact and cost-
effectiveness analytic procedures.
In trvina to establish these agency-wide procedures,
EPA will be making a number of difficult technical and
choices. A cancer policy, for instance, will
balancing of .economic criteria as well as risk
oai anc ^ . apprOpriateness and extent of
~ Si- *«ly \ny a9tn=y-vide poXicies .bout
anS costs imply iwXing judgments on the basis of .
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Report Outline
Page Two
imperfect data and not fully tested analytic tools. Methods
for applying the standardized tools developed under this
section will be elaborated in Section C of the report.
3. Toxics Integration Project'(TIP) Studied Three Strategic
Approaches Which Could be Used to Guide Future Integration
Common sense suggested that any eventual integration
strategy will consist of parts of all the approaches
considered in this study: regulation by pollutant, by •
industry, and by geographic area. Given the great number
of toxic chemicals, it is likely that selected compounds-- "
nay require in-depth analysis or intermedia review.- It is
also likely that controlling such pollutants may be most
ecorxsrnical.ly feasible if approached on an industry-wide
basis. Finally, there is an important potential role for
Geographic analyses to play in stucturing responses to
specialised intermedia toxics problems.
Nevertheless, each of these three strategic approaches
is being developed as though it were the single, dominant
integrative force upon which the agency would, in the
future, depend. Each approach will be evaluated in isolation.
What would be the strengths and weaknesses of that
method of integration? What is the catalogue of "issues
with which that integrative methodology would need to deal? -
What are the immediate problems — such as availability of
-""data — in testing the usefulness of the strategy? What
are the resource, organizational, and legislative impacts of
•• using this approach? This section of the report will
oresent findings of those kinds of questions for each. ..,
strategy.
1. Integration by Chemical Pollutant.
This approach has been dominant historically in EPA
r-lv because of legislative mandate and partly because
lv is of health and environmental risks must begin with.
&n^iific pollutants. Two overriding difficulties of the
S?7i,- = r,-f control model have been 1) the vast numbers of
P°i lutlnts to be controlled, and 2} the difficulty in
*^'na aoency-wide toxics priorities given the variety
•^requirements of each program's differing legislation.
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Report Outline
Page Three
o
o
The current strategy proposes to:
o strengthen the agency-wide chemical priority rankina
process; ^
o standardize the methodology for calculating pollution
control costs and comparing control costs for each
chemical across media;
consider the effectiveness of the work group format
for developing agency-wide control strategies;
develop support documents which consolidate exposure,
risk, chemical characteristics, regulatory action
level, and cost-related information on selected
priority pollutants;
o develop a strategy for analyzing and taking
regulatory, or non-regulatory, action for each
priority chemical.
2. Integration by Industry.
Toxics integration by industry would force regulators
to consider assessment and control technologies front an
intermedia perspective; and would increase the visibility of
economic considerations. This strategy will describe the
total pollution problem created by a specific industry,
then assess the health and environmental risks of that
pollution. Traditional and innovative control options -
'will be priced. Finally, this approach will compare risk
data- with control costs for each option ^nd recommend a :,
'regulatory decision tailored to that industry and to the
population exposed.
. Critical factors in developing the strategy are:
o proposing criteria for. industry selection, such as
nature of intermedia pollution discharges, technical
feasibility of control options, and economic
condition of the industry;
o modeling the extent of a selected industry's toxics
emissions;
o estimating economic impacts;
o developing methods for intermedia risk assessment
for a given industry (based on other 71? work) and
a means for selecting regulatory priorities;
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Report Outline
Page Four
o developing industry analytic work groups or other
.organizational devices to implement this approach.
The report to the Administrator will summarize findings
of the industry case studies which are testing this approach.
3. Integration by Geography.
Toxic pollution problems vary in severity across -the
country. A geographic approach will examine the feasibility
of applying intermedia analytic and control strategies
(particularly non-regulatory devices) to the unique problems.
of particular geographic areas.' _
This year the project will identify and develop tne
primary components of a geographic approach to toxics
control. This approach will include such elements as
site selection and planning procedures, development of
analytic tools, and definition of control strategies
appropriate to the special problems of a particular area.
Control strategies which are cost-effective and suitable
for a given geographic area must be devised on the basis of
defensible and fairly comprehensive descriptive information.
Analytic tools currently available lackjihe necessary
sophistication to "provide such information. Therefore, in ' ..
addition to describing basic requirements of a geographic -
approach, this project will focus on developing the requisite
analytic techniques, using to the maximum degree data which is
'already available. Testing these analytic tools will be
. an important function of- several case studies to be • :
conducted in sites suspected of having unusually severe
toxic problems. . • •' - -
The final report will summarize the utility of the
geographic approach, drawing from past geographic analyses
and the two case studies in addition to answering questions
such as the following:
-How adequate are available data bases for routine
geographic analyses?
-What are the appropriate roles of Federal, state
and local Governments in targeting analyses, in developing,
and finally in implementing control options?
-How feasible is implementation of such an approach
within EPA?
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Report Outline
Page. Five
C. TIP Will Recommend Changes in a Kurrber of Areas
1. The Most Promising Strategic Approach
The report will recommend criteria for when, based on
our current knowledge, each strategy can best be used
(e.g. when a particular chemical is of compelling "health
concern and to which there is wide exposure; when an industry
emits many toxic pollutants whose regulation can most
effectively and cheaply be accomplished collectively; where
a localized pollution problem exists for which a national
regulatory control would be inappropriate). If possible,
. the report will also suggest idea's for combining parts of
two or all three strategies (e.g., an industry based
regulatory strategy, but with intermedia work groups on top
priority pollutants on the assumption that all of an
industry's waste streams cannot be regulated cost-
effectively; and with alternative control measures for high
priority geographic problems.)
2. Implications of Strategy Cnoice.
This section of the report is perhaps the most important
because it will articulate the management decisions and
orocedural changes necessary to implement the preferred
integration strategy. This portion of the report will
define 'an array of possible changes in stairute, in
organization, and in "decision-making process. It will
suggest criteria for applying the tools and making the policy
judgments raised in earlier sections of the report, including
such considerations as:
V
o what rules to develop and when £hey should be
• "" issued;
o what standards to use which consider cost or
risk trade-offs and against which regulations
should be evaluated;
o how and when to evaluate intermedia effects and
relationships.
The organizational implications of changes such as these
mioht range from expanding the number of pollutant-specific
and industrial workgroups, to creation of offices of specific
industry regulation empowered to initiate all controls
affecting that industry. The summary of legislative issues
will hiahlight obstacles to implementation of the strategy.
m
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Report Outline
Page Six •
3. -Time Table
The report will present a timetable with options
related to speed of implementation of the selected strategy
or strategy elements. Gaps in necessary information will
exist when the final report is prepared, and we will need
more time before we understand 'the full implications of
each strategic approach: that knowledge shortfall will
brake immediate implementation. The Administrator, however,
will be presented choices for EPA resource allocation and
focus, legislative initiatives, allocations of authority,
etc., which could determine the pace of integration activity.
D. The Report Will Present a Draft FY82 Toxics Integration'•
Project Workplan.
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