JEPA Region VIII
November 30, 1990

-------


0 11I

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
999 18th STREET - SUITE 500
DENVER, COLORADO 80202-2405
NOV 3 0 1990
Ref: 8RA
MEMORANDUM
TO:
F. Henry Habicht II
De	' tinistrator
/ /)
—	—	
Ja	Qfterer
FROM:
Regional Administrator
SUBJECT: Region VIII Strategic Planning Initiative
I am pleased to forward the results from the first chase nf
Region VIII's strategic planning initiative. This package (see
Enclosure) contains the products of our Comparative Risk Proiert
and a list of areas under consideration for regional investment
and reduced investment. In the coming months my staff will
continue to develop these areas of consideration, culminating in
a risk reduction plan for the region that I will present at thl
Annual Planning Meeting in February. Regional and state efforts
during the last eight months clearly indicate significant
RegionSVIIIVard successfuiIy implementing strategic planning in
Results of Region VIII's Comparative Risk Project
The Region VIII Comparative Risk Project produced hnm*n
health-based and ecologically-based rankings for tventy-th?2e
environmental problem areas. Several high ranking areis may
provide risk reduction opportunities for the region in
hS'ra^TotS"" Preventi0n °£	degradation of
The process also highlighted important differences hetw^r,
risk rankings within individual states and a ranking for the
region as a whole. Attachment A, "Ranking of Environmental
^r®as'" Presents the regional rankings completed by EPA
staff. I have also included a second set nf	f"
B, "Final Rankings of Environmental Areas » that	h nt
to the regional ranking based on Input b?'th. "x"«Jo£ v???B9eS
states. Some of the significant differences in ?he ?w s^s of
rankings address state specific concerns about criteri! "r
and comments^ron^eaci^state^^presented^n^Attachme^t^
Initiative.^scusslons Comparative Risk and Strategic Planning

-------
Comparative Risk Project Process
Last April Region VIII "kicked-off" its comparative risk
process by forming a Comparative Risk Advisory Council (CRAC)
made up of managers and key staff representing each division and
office in the region. The group defined the issues to be
analyzed, approved the analytical approach, reviewed the results
of the analysis and, ultimately, developed a preliminary set of
risk rankings.
Members were asked to draw from their own professional
judgment, extensive discussions within the group and additional
input from program division staff in making ranking decisions.
Data from a regionally funded technical study was also provided
to assist in the ranking process. The study, which received
extensive review and comment by EPA staff, provided CRAC members
with health, ecological and welfare risk assessments for each
problem area, a description of uncertainties associated with each
analysis, and supporting data on a state-by-state basis. The
region also funded a study of regional and national economic and
demographic trends in order to identify emerging issues.
The resulting regional risk rankings clustered the problem
areas into five categories with "Category 1 '• representing the
highest level of risk. Issues were not ranked within each
category.
The state environmental directors were advised of the
process throughout the summer. During the last two months of the
project, the Region VIII comparative risk director and one member
of the senior staff visited each state to discuss differences
between state rankings and the regional rankings.
This effort culminated at the State Directors Meeting held
in early November. The meeting was attended by EPA senior staff
and state environmental program directors. During the meeting
the results of the individual state visits were discussed and a
second risk ranking was produced to incorporate state input.
Attachment D, "Comparative Risk Project Summary Report,"
contains a comprehensive description of the comparative risk
process which I have briefly described.
Strategic Criteria and Investment/Reduced Investment
Opportunities
In addition to comparative risk, Region VIII has identified
several other strategic criteria which we believe are fundamental
to successful development of our overall strategic plan. The six
criteria — Comparative Risk, Technical Assistance/Education,
Pollution Prevention, Enforcement, State/Local/Tribal/EPA
2

-------
Relations and Multi-Media Projects — have been endorsed by
regional senior management and the state directors. A further
description of each area is provided in Attachment E, "Strategic
Criteria and Evaluation Matrix." As we prepare our strategic
plan, we will use the matrix to evaluate investments and reduced
investments against each criteria to ensure that these important
regional goals are met.
Included in attachment F, "Project/Issue Areas Under
Consideration," is a list of areas which the region is examining
for resource reallocation during the strategic planning process.
During the coming months my staff will work to develop these
proposals into an integrated regional strategy. We look forward
to continuing this process and to the environmental improvements
which it will allow us to achieve. Thank you for your continued
support of this important initiative.
Enclosure: EPA Region VIII Strategic Planning Initiative Phase I
Attachment A
Attachment B
Attachment C
Attachment D
Attachment E
Attachment F
-	Ranking of Environmental Problem Areas
-	Final Rankings of Environmental Problem Areas
-	State/EPA Discussions on Comparative Risk and
Strategic Planning Initiative
-	Comparative Risk Project Summary Report
-	Strategic Criteria and Evaluation Matrix
-	Project/Issue Areas Under Consideration
cc: Jack McGraw
J. Clarence Davies
Ralph R. Bauer
Stanley Laskowski
Robert Currie
Kerrigan Clough
Nola Cooke
Irwin Dickstein
Max Dodson
Robert Duprey
Tom Speicher
John Wardell
Jon Yeagley
Deb Janik
Don Patton
3

-------
Attachment A
REGION VIII COMPARATIVE RISK PROJECT
RANKING OF ENVIRONMENTAL PROBLEM AREAS
HUMAN HEALTH RISK
Category 1
Indoor Air Pollution
Indoor Radon
Pesticides
Category 2
Criteria Air Pollutants
Lead from all Sources
Category 3
Drinking Water Contamination
Hazardous/Toxic Air Pollutants
Radiation other than Radon
Storage Tanks
Ozone Depletion & Climate Change
Category 4
Abandoned/Superfund Waste Sites
RCRA Hazardous Waste
Groundwater Contamination
Accidental Releases
Mining Wastes
Ind. Discharges to Surface Water
Category 5
Nonpoint Surface Water Pollution
Industrial Solid Waste
Municipal Solid Waste
Municipal Wastewater Discharges
ECOLOGICAL RISK
Category 1
Nonpoint Surface Water Pollution
Ozone Depletion & Climate Change
Physical Degradation of
Terrestrial Habitats
Physical Degradation of Wetlands
and Aquatic Habitats
Category 2
Pesticides
Mining Wastes
Category 3
Abandoned/Superfund Waste Sites
Ind. Discharges to Surface Water
Municipal Wastewater Discharges
Category 4
Criteria Air Pollutants
Acid Deposition & Visibility Deg.
Accidental Releases
RCRA Hazardous Waste
Storage Tanks
Municipal Solid Waste
Industrial Solid Waste
Category 5
Groundwater Contamination
Radiation other than Radon
Lead from all Sources
Hazardous/Toxic Air Pollutants

-------
Attachment B
FINAL RANKINGS OF ENVIRONMENTAL PROBLEM AREAS
(Includes State Input)
HUMAN HEALTH RISK
Category 1
Indoor Air Pollution and Radon
Criteria Air Pollutants
Pesticides
Category 2
Drinking Water Contamination
Groundwater Contamination
Lead from all Sources
Category 3
Ozone Depletion & Climate Change
Hazardous/Toxic Air Pollutants
Radiation other than Radon
Storage Tanks
Category 4
Abandoned/Superfund Waste Sites
Mining Wastes
RCRA Hazardous Waste
Municipal Solid Waste
Industrial Solid Waste
Accidental Releases
Ind. Discharges to Surface Water
Category 5
Nonpoint Surface Water Pollution
Municipal Wastewater Discharges
ECOLOGICAL RISK
Category 1
Nonpoint Surface Water Pollution
Ozone Depletion & Climate Change
Physical Degradation of Wetlands
and Aquatic Habitats
Category 2
Physical Degradation of
Terrestrial Habitats
Pesticides
Mining Wastes
Groundwater Contamination
Category 3
Abandoned/Superfund Waste Sites
Ind. Discharges to Surface Water
Municipal Wastewater Discharges
Municipal Solid Waste
Industrial Solid Waste
Category 4
Criteria Air Pollutants
Acid Deposition & Visibility Deg.
Accidental Releases
RCRA Hazardous Waste
Storage Tanks
Category 5
Radiation other than Radon
Lead from all Sources
Hazardous/Toxic Air Pollutants

-------
ATTACHMENT C
EPA REGION VIII
STATE/EPA DISCUSSIONS ON COMPARATIVE RISK
AND STRATEGIC PLANNING INITIATIVE
North Dakota
October 22,
1990
South Dakota
October 23,
1 990
Utah
October 24,
1 990
Montana
November 1,
1 990
Wyoming
November 2,
1 990
Colorado
November 6,
1 990

-------
BACKGROUND
EPA's comparative risk and strategic planning initiative is
a nationwide effort designed to focus the agency's efforts on
today's most serious environmental issues and to generate
strategies that will most effectively address these issues. For
EPA's regional offices, the first phase of this effort was to
conduct an analysis of the risks associated with a wide range of
environmental issues and to rank the issues based on relative
levels of risk.
EPA Region VIII's participation in this agency-wide
initiative began in earnest in April 1990 with the formation of
the Region VIII Comparative Risk Advisory Council consisting of
12 Region VIII employees representing each division and office in
the region. With contractor assistance, the Advisory Council
examined the risks associated with 23 environmental issues.
After reviewing the information gathered through the analysis,
the Advisory Council completed two rankings - a human health risk
ranking and an ecological risk ranking. These rankings are
included here as Attachment 1, and a complete summary of the work
of the Advisory Council can be found in their final report.
From the beginning of this initiative in Region Vlii, the
Regional and Deputy Regional Administrators, as well as the rest
of the senior staff, have emphasized the importance of involving
the state environmental program offices. The first big step
towards making the states partners in this effort will take place
at the state directors' meeting to be held November 8-9, 1990 in
Keystone, Colorado. At this meeting, the state directors and EPA
senior staff will work to clarify the major goals that the region
should pursue through strategic planning.
In preparation for this meeting, a member of the senior
staff and the project director visited each of the six states in
the region to discuss the background and current status of Region
VIII strategic planning. Specifically, state and EPA
representatives discussed how the risks in each state differ from
the Advisory Council's risk rankings and preliminary suggestions
on goals and strategies that the states would like to see the
region pursue through the strategic planning process.
This document presents in bullet format a summary of each
state visit. The suggestions made in each state will be
synthesized and used as the starting point for discussion at the
state directors' meeting.

-------
NORTH DAKOTA
ATTENDEES
Francis Schwindt, Chief, Environmental Health Section
Dana Mount, Director, Division of Environmental Engineering
Dennis Fewless, Director, Div. of Water Supply & Pollution Cntrl.
Martin Shock, Director, Div. of Environmental Waste Management
Chuck Riddell, Environmental Health Section
Teri Lunde, Environmental Health Section
Jack Hidinger, Deputy Director, Region VIII Air & Toxics Division
Patrick Cummins, Region VIII Comparative Risk Project Director
RISK RANKINGS
Problem areas ranked higher for human health risk by North Dakota
than by the Region VIII Comparative Risk Advisory Council:
— Groundwater and Drinking Hater Contamination; relatively
high due to natural contamination and contamination from
agricultural activities, underground storage tanks, and
waste management activities. Many residents use untreated
groundwater from wells as their source of drinking water.
Industrial Solid Waste; problems with disposal of fly ash,
oil and gas exploration wastes, importation of wastes from
other states and Canada, and wastes from gas plants.
Nonpoint Source Surface Water Pollution; pesticide,
nutrient, and sediment contamination from agricultural
activity may lead to increased direct human exposure as well
as bioaccumulation of toxics.
Problem areas ranked lower for human health risk by North Dakota
than by the Region VIII Comparative Risk Advisory Council:
Criteria Air Pollutants; North Dakota is in attainment for
all ambient air quality standards.
Indoor Air Pollutants; this problem has received little
attention in North Dakota.
Lead from all Sources; few major sources of lead pollution.
Radiation other than Radon; limited sources.
Climate Change and Ozone Depletion; information to conclude
that this is a serious problem for North Dakota is lacking.

-------
NORTH DAKOTA (cont.)
Problem areas ranked higher for ecological risk by North Dakota
than by the Region VIII Comparative Risk Advisory Council:
Groundwater Contamination; concern over impacts of
groundwater contamination on ecosystems, particularly
through bioaccumulation of toxics from agriculture.
Accidental Chemical Releases; several major accidents in the
recent past that have led to significant commitment of
department resources, and have posed potentially serious
problems.
Problem areas ranked lover for ecological risk by North Dakota
than by the Region VIII Comparative Risk Advisory Council:
Physical Degradation of Wetlands and Aquatic Habitats and
Physical Degradation of Terrestrial Habitats; perception of
the ecological risks from these issues is different in an
agricultural state like North Dakota. Responsibility/
authority does not rest with Environmental Health Section.
Mining Wastes; limited activity in North Dakota
Climate Change and Ozone Depletion? information to conclude
that this is a serious problem for North Dakota is lacking.
GOALS AND STRATEGIES
The following ideas were suggested as possible goals or
strategies for Region VIII to pursue through the strategic
planning initiative.
Attempt to secure additional discretionary funds that could
be used on high priority projects.
A continuous effort between EPA and the states to develop
more of a partnership approach. Relationship is constantly
changing - new laws, new staff, etc. More of a problem at
the staff level- Could be addressed through informal
interaction among staff (i.e., more visits to states or
state staff visit EPA offices). Staff exchanges, IPAs would
also help.
Less duplication by EPA.
Less oversight of enforcement, actions. Don't get bogged
down in the little stuff.
Increased training and technical assistance, particularly
laboratory assistance.

-------
NORTH DAKOTA (cont.)
"Automatic" delegation once state has demonstrated
capability. Eliminate redundant and burdensome
requirements. Give state flexibility to demonstrate
capability in different ways that lead to the same end.
Put emphasis on compliance not enforcement. Enforcement
actions create an adversarial relationship between EPA and
state.
Increase EPA's commitment to improving environmental
management on Indian reservations. States filling in for
EPA when we don't do the job.
At the national level, EPA cannot continue to impose
regulations without resources to help implement them.
Increased communication between those writing the laws and
those implementing the laws. Example - Agency ranks solid
waste sites low for risk but imposes strict, costly
regulations.
Address uncertainty in risk assessments through increased
data collection and better science. Target potentially high
risk areas first.
Incentives and regulatory flexibility to pursue pollution
prevention strategies.

-------
SOUTH DAKOTA
ATTENDEES
Reese Peck, Deputy Secretary, Dept. of Water & Natural Resources
Steve Pirner, Director, Division of Environmental Regulation
Mark Steichen, Director, Division of Water Resources Management
John Hatch, Director, Division of Water Rights
Pat Rice, Director, Division of Technical and Support Services
Annie Hollenbeck, Division of Technical and Support Services
Steve Tuber, Comptroller, EPA Region VIII
Patrick Cummins, Region VIII Comparative Risk Project Director
RISK RANKINGS
There were considerable differences between the South Dakota
human health risk ranking and the ranking completed by the Region
Vlii Comparative Risk Advisory Council. In general, problem
areas associated with water and land pollution were ranked higher
for human health risk in South Dakota, and problem areas related
to air pollution were ranked lower.
Drinking Water Contamination, Groundwater Contamination, and
Storage Tanks were ranked 1st, 2nd, and 3rd respectively.
There is significant overlap between these issues, and,
along with Pesticides (ranked 4th), they are thought to be
relatively serious problems in South Dakota.
Industrial and Municipal Wastewater Discharges and Nonpoint
Source Surface Water Pollution were ranked considerable
higher. Major industrial dischargers include mining, meat
packing, and feed lots. Agricultural activity leads to much
of the nonpoint source surface water pollution.
Outdoor air pollution is not a serious problem in South
Dakota, and therefore, Criteria Air Pollutants and Hazardous
and Toxic Air Pollutants were ranked lower. These issues
have received more attention lately because of a proposed
incinerator that would burn wastes from out of state.
Indoor Air Pollution and Indoor Radon, have received little
attention in South Dakota, and state officials do not
perceive them to be serious problems. Uncertainty in the
risk estimates was also cited as an important factor for
ranking these issues low.
There was much more agreement between the South Dakota and
regional rankings for ecological risks. In fact, the only area
where there was a large difference between the two was Climate
Change and Ozone Depletion which was ranked at the top of the
regional ranking and near the bottom of the state ranking. This
difference is largely due to different perceptions regarding the
validity of the information on these problems. Waste importation
was also mentioned as an emerging problem in South Dakota.

-------
SOUTH DAKOTA (cont.)
GOALS AND STRATEGIES
The following ideas were suggested as possible goals or
strategies for Region VIII to pursue through the strategic
planning initiative.
EPA staff should be working to provide state staff with
needed technical assistance and should not be duplicating
state work and engaging in continuous oversight.
Move from program implementation to comprehensive,
integrated environmental problem solving.
Small states like South Dakota need more flexibility to
spend federal dollars on their high priority problems.
Improve working relationships at the staff level. More EPA
state visits, state staff visit regional office, IPAs, etc.
States need "expert witness" assistance that they do not
have in-house. EPA should be a resource for this.
Increase public education/communication at all levels -
adults., children, businesses, etc.
At the national level, EPA cannot continue to impose
regulations without resources to help implement them.
Reconcile federal requirements that conflict with state
requirements.
Work for better coordination among EPA programs.

-------
UTAH
ATTENDEES
Ken Alkema, Director, Division of Environmental Health
Gayle Smith, Director, Bureau of Drinking Water Sanitation
Larry Anderson, Director, Bureau of Radiation
Fred Pehrson, Bureau of Water Pollution Control
Marv Maxell, Bureau of Air Quality
Rusty Lundberg, Bureau of Solid and Hazardous Waste
Brad Johnson, Bureau of Environmental Response and Remediation
Bruce Slater, Division of Environmental Health
Roger Frenette, Dep. Director, Region VIII Water Management Div.
Patrick Cummins, Region VIII Comparative Risk Project Director
RISK RANKINGS
While Utah had not completed risk rankings at the time of this
meeting, the EPA and state representatives present engaged in a
detailed discussion of human health and ecological risks in Utah
and how they compared to the ranking completed by the Region VIII
Comparative Risk Advisory Council. More information on Utah's
risk rankings should be available in the near future.
In general, the state representatives felt that the regional
rankings are fair approximations of the risks in Utah. Some
potential differences are noted below.
Indoor Radon may be ranked significantly lower in Utah based
on a lack of confidence in the methodology that the high
risk estimates are derived from.
While Criteria Air Pollutants ranked quite high in the
regional ranking, they may rank even higher in Utah because
of large populations living in areas that are not in
attainment for federal ambient air quality standards.
It was noted that the methodology used to analyze Municipal
and Industrial Solid Waste was limited to site specific
effects and does not adequately account for the risks that
would show up in a life cycle analysis. Utah may choose to
include these effects and rank these issues higher.
Drinking Water Contamination may rank higher in Utah.
Utah's ecological risk ranking may show more concern for
Abandoned/Superfund Waste Sites, Criteria Air Pollutants,
and Lead from all Sources than was reflected in the regional
rankings. These problems may pose relatively high
ecological risks due to widespread and persistent pollution
and the possibility for bioaccumulation of toxics.

-------
UTAH (cont.)
GOALS AND STRATEGIES
The following ideas were suggested as possible goals or
strategies for Region VIII to pursue through the strategic
planning initiative.
Elevate ecological concerns to the same level as health
concerns.
Target environmental issues with clearly demonstrated
problems as opposed to those with high levels of
uncertainty.
Emphasize environmental indicators instead of program
indicators (beans) to measure a program's success.
Recognize that different programs require different
management strategies - prevention v. remediation
Increase state/EPA partnership through IPAs, and other forms
of staff sharing. Promote staff level interaction on a
routine basis as opposed to in an oversight or adversarial
context.
Minimize conflicting messages from EPA HQ and Region 8.
Improve coordination of processes for state comment on EPA
regulatory development, etc. Need better and more timely
communication.
Don't try to modify SEA at mid-year based on program
guidance that comes out after the fact.
Stop using guidance to circumvent rule-making.
Put more resources into communicating with and educating the
regulated industries, public, children, etc. Also, more
"Mobilization" type efforts that leverage work of local
agencies.
Begin breaking down barriers to multi-media environmental
problem solving. Take a more holistic view of environmental
problems.
Pursue multi-media demonstration projects.
Stop using methods of economic analysis that discount future
values.
Work for better coordination between different federal
agencies.

-------
MONTANA
ATTENDEES
Steve Pilcher, Administrator, Environmental Sciences Division
Tom Ellerhoff, Administrative Officer
Loren Bahls, Acting Chief, Water Quality Bureau
Jeff Chaffee, Chief, Air Quality Bureau
Duane Robertson, Chief, Solid and Hazardous Waste Bureau
Vic Andersen, Superfund Section Supervisor
Roger Thorvilson, Solid and Hazardous Waste Section Supervisor
John Geach, UST/LUST Section Supervisor
Irv Dickstein, Director, Region VIII Air and Toxics Division
Patrick Cummins, Region VIII Comparative Risk Project Director
RISK RANKINGS
The following are notable differences between the Montana human
health risk ranking and the regional ranking.
Drinking Water Contamination and Groundwater Contamination
were ranked highest for human health risk.
Lead from all Sources was ranked relatively low overall,
although there are some hot spots in Montana as a result of
smelting and mining activities. Arsenic and copper may
present a greater health risk than lead in Montana.
Abandoned/Superfund Hazardous Waste Sites was ranked third
for health risk in Montana, which is much higher than in the
regional ranking. Many of the Superfund sites in Montana
are mining related.
Indoor Air Pollution was ranked much lower than in the
regional ranking.
The following are notable differences between the Montana
ecological risk ranking and the regional ranking.
Mining Wastes and Abandoned/Superfund Hazardous Waste Sites
were both ranked 1st for ecological risk in Montana. This
is due to the fact that many old mining sites are now
Superfund sites and current mining activity presents a high
ecological risk, especially cyanide operations.
Industrial Discharges to Surface Water was ranked higher by
Montana. Major sources are the pulp and paper industry, oil
refineries, and mining.
Groundwater Contamination was ranked higher due to the
interrelationship with surface water quality

-------
MONTANA (cont.)
GOALS AND STRATEGIES
The following ideas were suggested as possible goals or
strategies for Region VIII to pursue through the strategic
planning initiative.
Emphasize ecological protection in EPA programs. One aspect
is that tourism and recreation are increasingly important
industries that can be severely impacted by ecological
degradation.
More flexibility from EPA so that states can address their
priorities.
Increase cooperation at the staff level. Work to improve
relationship between EPA and state staff.
Work to improve accountability measures. "Beans" and EPA
staff performance standards drive too many decisions.
Incorporate cross-regional and international issues into
Region 8 planning.
There is a need for better communication/coordination among
different program offices in Region 8.
Work to address water quality	problems that are due to
changes in water quantity.
Work with states to deal with	new federal regulations that
are being imposed without any	resources to implement them.
More attention to emergency response needs of small
communities. They currently lack expertise and equipment,
and long response times pose a serious threat.
Work to improve environmental education at all levels -
industry, politicians, children, etc. Focus on issues that
may pose high risk but public is unaware of (i.e., indoor
air pollution).
Better coordination of tribal environmental management.
Work to overcome turf, issues and get down to solving
problems.

-------
WYOMING
ATTENDEES
Dennis Hemmer, Director, Department of Environmental Quality
Chuck Collins, Administrator, Air Quality Division
Bill Garland, Administrator, Water Quality Division
David Finley, Supervisor, Solid Waste Program
Larry Robinson, Water Quality Division
Mike Hackett, Water Quality Division, Construction Grants
Beth Pratt, Water Quality Division, Nonpoint Sources
John Wagner, Water Quality Division, NPDES
Pat Godsil, Dep. Director, Region VIII Hazardous Waste Mgmt. Div.
David Wann, Region VIII Policy Office
Patrick Cummins, Region VIII Comparative Risk Project Director
RISK RANKINGS
Wyoming DEQ staff did not feel that the risk ranking approach
used in the Region VIII comparative risk project was a
particularly useful approach, and therefore they did not complete
a similar ranking of the issues. They did agree to prepare a
list of priorities that is based on the adequacy of existing
programs and areas they would address given additional resources.
They pointed out the following aspects of the regional risk
ranking approach that limit its usefulness.
In the regional rankings, high ranking issues are primarily
those for which EPA has no program or the existing program
is inadequate.
The comparative risk methodology does not address the
question of what would happen to the risks associated with
lower ranked issues if current levels of control were
lessened.
The methodology does not define risk broadly enough -¦ some
important effects are not included. Emphasizes cancer too
heavily.
GOALS AND STRATEGIES
The following ideas were suggested as possible goals or
strategies for Region VIII to pursue through the strategic
planning initiative.
Limit "micro-management" by EPA and increase technical
assistance. Specific areas where increased technical
assistance would be helpful include: air toxics, ambient
monitoring for nonpoint source surface water pollution,
indoor air pollution and radon; and RCRA.

-------
WYOMING (cont.)
Address the need for better communication between EPA
programs - regulations are overlapping and conflicting.
"Is risk assessment the right scope to aim the gun and pull
the trigger?" Need to consider many other important factors
and/or define "risk" much more broadly. Talk in terms of
identifying most serious environmental problems instead of
highest risks.
Need to focus on high risk areas without cutting back on
existing programs which are already inadequate/underfunded
at the state level.

-------
COLORADO
ATTENDEES
Tom Looby, Asst. Director, Colorado Department of Health
Dave Shelton, Director, Waste Management Division
Brad Beckham, Director, Air Pollution Control Division
Dr. Ellen Mangione, Director, Disease Control & Epidemiology Div.
Gary Broetzman, Office of Health and Environmental Protection
Gary Jessen, Office of Health and Environmental Protection
Kate Kramer, Office of Health and Environmental Protection
Representatives from Radiation Control Division and Water Quality
Control Division were also present
Max Dodson, Director, Region VIII Water Management Division
Don Patton, Chief, Region VIII Policy Office
Patrick Cummins, Region VIII Comparative Risk Project Director
RISK RANKINGS
The following changes to the regional rankings were suggested to
more accurately reflect the risks in Colorado.
For the human health risk ranking:
Criteria Air Pollutants up to category 1
Drinking Water Contamination up to category 2
Groundwater Contamination up to category 3
Accidental Releases higher, possibly category 2 or 3
Pesticides down to category 3
For the ecological risk ranking:
Mining Wastes up to category 1, particularly because of the
link with Nonpoint Surface Water Pollution
Groundwater Contamination up to category 2 - tremendous
value as a water supply for the future, needs to be
protected, limited work to date.
Visibility Degradation is an extremely important issue in
Colorado (probably category 1), both in urban areas as well
as in the mountains. Not really an ecological issue, but
certainly an environmental issue.
Accidental Releases higher, probably category 3
Physical Degradation issues are not category 1 for Colorado,
probably category 2.
Need to include as a high priority an issue related to open
space and recreation opportunities.

-------
COLORADO (cont.)
GOALS AND STRATEGIES
The following ideas were suggested as possible goals or
strategies for Region VIII to pursue through the strategic
planning initiative.
Reexamine state oversight pilot projects undertaken by
Region VIII in the last couple of years. Need to keep up
the emphasis in this area, look at the possibility of
reducing/ redefining EPA's oversight role.
Need to take more risks in our decision-making process.
Can't always require more and more information before action
is taken.
Pursue creative approaches to solving problems - be willing
to try something new as opposed to doing it the same way
every time.
Start addressing regional and state priorities now - should
not be waiting until FY93. Need to bring in mid-level
managers now and get them working towardls these goals.
SEA needs to reflect more of a partnership - What are EPA's
commitments? Currently very one-sided.

-------
EPA REGION VIII
COMPARATIVE RISK PROJECT
SUMMARY REPORT
November 1990
Prepared by:
Region VIII Policy Office

-------
TABLE OF CONTENTS
EXECUTIVE SUMMARY 		1
1 .0	OVERVIEW 		4
1 .1	Background 		4
1.2	Issue Definition 			5
1.3	Risk Analysis 		5
1.4	Risk Rankings 		6
1.5	State Involvement 		9
2.0	RISK SUMMARIES 		11
Appendix A - List of Environmental Problem Areas

-------
EXECUTIVE SUMMARY
As part of EPA's strategic planning initiative, Region VIII
conducted a comparative risk project from April through November
1990. The purpose of this project was to identify the most
important environmental issues in the region based on the
relative level of human health and ecological risk posed by each
issue. Regional EPA staff on the Comparative Risk Advisory
Council directed the project with assistance from a contractor
and the Region VIII Policy Office.
The information and conclusions in this report, including
the final rankings for human health and ecological risk
(Table 1), are based primarily on the work of the Region VIII
Comparative Risk Advisory Council, other EPA staff, and the
contractor, but also reflect input from state environmental
managers received during an intensive effort at state involvement
carried out during the last two months of the project.
Given the results of previous comparative risk projects,
this project provided little new insight into the relative
severity of environmental problems. During the course of the
project, EPA and state personnel pointed out the following
shortcomings of the approach and made suggestions for how it
could be improved in the future.
1)	The concept of "residual risk" (current risk given existing
controls) biases the rankings in favor of areas where EPA
has limited programs or no programs at all. Future
comparative risk work should simultaneously address the fact
that cutting back on program activity for lower ranked
problem areas will lead to increased risks.
2)	The issue definitions used for the project do not provide a
sound basis for analysis of environmental problems. There
is tremendous overlap between issues that makes it difficult
to sort out the importance of different aspects of the
problems and leads to a great deal of confusion in the
analysis and rankings. Also, the issue list requires
comparison of natural resources, pollution sources, specific
pollutants, and effects of pollution. This limits the
usefulness of this approach for comparing the relative
severity of environmental problems. In the future, issues
should be defined consistently and in a way that minimizes
the overlap between issues.
1

-------
3) The analytical framework does not account for important risk
factors that are necessary to determine the most serious
environmental problems. By focusing on "end-of-the-pipe"
pollution, the analysis does not capture elements of the
problems that, if they were included, would lead to a
different conclusion. A life-cycle perspective combined
with a more logical issue definition would provide insights
that do not show up here.
2

-------
TABLE 1
FINAL RANKINGS OF ENVIRONMENTAL PROBLEM AREAS
(Include State Input)
HUMAN HEALTH RISK
Category 1
Indoor Air Pollution and Radon
Criteria Air Pollutants
Pesticides
Category 2
Drinking Water Contamination
Groundwater Contamination
Lead from all Sources
Category 3
Ozone Depletion & Climate Change
Hazardous/Toxic Air Pollutants
Radiation other than Radon
Storage Tanks
Category 4
Abandoned/Superfund Waste Sites
Mining Wastes
RCRA Hazardous Waste
Municipal Solid Waste
Industrial Solid Waste
Accidental Releases
Ind. Discharges to Surface Water
Category 5
Nonpoint Surface Water Pollution
Municipal Wastewater Discharges
ECOLOGICAL RISK
Category 1
Nonpoint Surface Water Pollution
Ozone Depletion & Climate Change
Physical Degradation of Wetlands
and Aquatic Habitats
Category 2
Physical Degradation of
Terrestrial Habitats
Pesticides
Mining Wastes
Groundwater Contamination
Category 3
Abandoned/Superfund Waste Sites
Ind. Discharges to Surface Water
Municipal Wastewater Discharges
Municipal Solid Waste
Industrial Solid Waste
Category 4
Criteria Air Pollutants
Acid Deposition & Visibility Deg
Accidental Releases
RCRA Hazardous Waste
Storage Tanks
Category 5
Radiation other than Radon
Lead from all Sources
Hazardous/Toxic Air Pollutants
3

-------
1.0 OVERVIEW
1.1 BACKGROUND
In November 1989, EPA headquarters outlined the main
features of its strategic planning initiative which gives the
regions an expanded role in the Agency's planning and budgeting
process. This expanded role gives the regions more flexibility
to address issues that are not adequately emphasized in national
program strategies, and it is part of the Administrator's
commitment to ensure that EPA management systems allocate budgets
as a result of risk-based planning that involves the regions.
The first phase of the strategic planning initiative was for each
of the seven regions that had not completed comparative risk
projects to do so in FY 90. The purpose of these projects was to
identify the most important environmental issues in the regions
based on the relative level of human health and ecological risk
posed by each issue. This report documents the results of the
Region VIII Comparative Risk Project.
The' Region VIII Comparative Risk Project involved EPA and
state personnel in a dynamic process from April through November
1990. The project was directed by the twelve-member Region VIII
Comparative Risk Advisory Council, made up of managers and key
staff from each division and office in Region VIII. The advisory
council was responsible for defining the issues to be analyzed,
approving the analytical approach, reviewing the results of the
analysis, and performing the preliminary risk rankings. Their
conclusions were then presented to Region VIII senior staff and
state environmental managers as part of an intensive effort to
obtain state input in this first phase of the strategic planning
initiative.
Region VIII senior staff were involved in the project from
the start, and the project design was based on their guidance.
State environmental directors were also involved early in the
process. At the state directors' meeting on May 4, 1990, a
presentation on the project was given by EPA staff, and options
for state input were discussed. Due to the logistical problems
of involving state staff in a region as large as Region VIII, it
was decided that the most practical way to involve the states was
to give them an opportunity to review and comment on the results
of the project after the advisory council had reached their
conclusions.
Overall management of the project was performed by staff
from the Region VIII Policy Office, and contractor support was
provided by Don Peterson and his associates at RCG/Hagler,
Bailly, Inc. in Boulder, Colorado.
4

-------
1.2 ISSUE DEFINITION
The list of environmental problem areas used for the Region
VIII Comparative Risk Project was derived almost entirely from
the "Core List" provided by headquarters to each region. The
following minor changes to the list were made to address regional
concerns and areas where the advisory council thought the
headquarters' list was deficient.
Criteria air pollutants were aggregated into one problem
area.
Acid deposition and visibility degradation were added as a
separate problem area.
Mining wastes were added as a separate problem area.
Lead from all sources was added as a separate problem area.
Climate change and ozone depletion were added as a separate
problem area. (These issues were included on the
headquarters' list as optional problem areas.)
1.3 RISK ANALYSIS
The risk analysis for the project was prepared by a
contractor with assistance from members of the advisory council
and numerous other regional EPA staff. The complete analysis can
be found in the risk reports which were published as a separate
document accompanying this report.
Realizing that time and budget constraints would make it
impossible to do a comprehensive analysis of the health,
ecological, and welfare risks associated with the twenty-three
environmental problem areas being considered, the advisory
council agreed that the analysis should concentrate on the areas
where it would add the most value. Therefore, the first step in
the process was to conduct a screening-level analysis of each
issue in order to determine the optimal allocation of time and
resources. Based on the results of this screening, more
analytical effort was spent on areas that: 1) were not already
well understood; 2) were expected to be of special regional
significance; 3) had enough data available to do a reasonable
analysis; and/or 4) were associated with a relatively high level
of uncertainty.
Furthermore, it was decided that attempting to reach
quantitative, deterministic conclusions was not practical for
most of the problem areas. Doing so would have required making
too many assumptions that could not be backed up by the available
5

-------
data. It was decided that the analysis should present the
information in a manner that would be most useful to the advisory
council as they approached their job of conducting the relative
ranking of the issues. This meant presenting information in a
form that was easily understood, and it also meant not drawing
any quantitative conclusions that were not defensible in light of
the available data. This would allow the advisory council to
make their own interpretations of the information.
With these concepts agreed to, the contractor began working
with EPA and state staff in all of the program offices to collect
available data. Throughout the preparation of the analysis, he
worked closely with the technical experts who provided valuable
guidance and assistance. The analysis relied on these sources as
well as previous state and regional comparative risk assessments
and national exposure response functions.
Once the analysis was completed, it was distributed to the
advisory council so that they could use it to perform the risk
rankings. It was also distributed to the technical staff in each
program office who provided technical review and comments that
were used to finalize the analysis.
1.4 RISK RANKINGS
The risk rankings completed by the Comparative Risk Advisory
Council were arrived at through a three-step process. After
reviewing the information presented in the analysis, council
members completed ranking worksheets that had them rate each
problem area on a scale of 1-5 for human health risk and 1-5 for
ecological risk. Council members were asked to use the following
guidelines when completing the worksheets,
1)	Rank the issues based on residual risk, which is the current
level of risk given existing controls.
2)	Use the definitions established by the council for each
issue. (See Appendix A)
3)	The rankings should reflect relative comparisons between the
problem areas under consideration; they do not establish any
absolutes in terms of high or low risk.
4)	Base the rankings on the information provided in the
analysis and best professional judgement. Be conscious of
uncertainties and how they influence the rankings.
5)	For human health risk, consider the following criteria: 1)
individual risk, which is the risk to highly exposed or
particularly sensitive populations; 2) population risk; 3)
6

-------
cancer risk; 4) non-cancer risks; 5) severity of non-cancer
risks; and 6) persistence of pollutants in the environment.
6) For ecological risk, consider the following criteria: 1)
size of affected area; 2) severity of damages; 3)
reversibility; and 4) damage to sensitive or unique
ecosystems.
The ranking worksheets were then tabulated to arrive at a
straw ranking. This straw ranking was presented at a meeting of
the advisory council and consensus was reached on the preliminary
ranking of the issues. Going from the results of the worksheets
to the preliminary ranking required council members to discuss
their differences and come to an agreement about how the issues
should be ranked. The toughest part of this process was grouping
the issues in categories that represented an approximately
equivalent level of risk. They ended up with five categories for
human health risk and five categories for ecological risk, with
category 1 representing the highest level of risk. The issues
were not ranked within each category.
The preliminary rankings were then reconsidered at another
meeting two weeks later. This was to give council members a
chance to make any changes they felt were necessary before
finalizing their rankings. However, it was decided that no
changes were necessary, and the preliminary ranking was ratified
as the advisory council's final ranking (Table 2).
At this time, the council also decided that it would not
perform a welfare risk ranking or a combined effects ranking.
While they agreed that there were important welfare risks that
should be considered when addressing the issues through the
strategic planning initiative, they did not think that they had
enough information to do a ranking for all the issues.
The final risk rankings done by the Region VIII Comparative
Risk Advisory Council were then discussed with state managers to
get their judgement about how well the rankings reflected the
relative risks in their state.
7

-------
TABLE 2
COMPARATIVE RISK ADVISORY COUNCIL RANKINGS
HUMAN HEALTH RISK
Category 1
Indoor Air Pollution
Indoor Radon
Pesticides
Category 2
Criteria Air Pollutants
Lead from all Sources
Category 3
Drinking Water Contamination
Hazardous/Toxic Air Pollutants
Radiation other than Radon
Storage Tanks
Ozone Depletion & Climate Change
Category 4
Abandoned/Superfund Waste Sites
RCRA Hazardous Waste
Groundwater Contamination
Accidental Releases
Mining Wastes
Industrial Discharges to
Surface Water
Category 5
Nonpoint Surface Water Pollution
Industrial Solid Waste
Municipal Solid Waste
Municipal Wastewater Discharges
ECOLOGICAL RISK
Category 1
Nonpoint Surface Water Pollution
Ozone Depletion & Climate Change
Physical Degradation of
Terrestrial Habitats
Physical Degradation of Wetlands
and Aquatic Habitats
Category 2
Pesticides
Mining Wastes
Category 3
Abandoned/Superfund Waste Sites
Industrial Discharges to
Surface Water
Municipal Wastewater Discharges
Category 4
Criteria Air Pollutants
Acid Deposition & Visibility peg
Accidental Releases
RCRA Hazardous Waste
Storage Tanks
Municipal Solid Waste
Industrial Solid Waste
Category 5
Groundwater Contamination
Radiation other than Radon
Lead from all Sources
Hazardous/Toxic Air Pollutants
8

-------
1.5 STATE INVOLVEMENT
From the very beginning, Region VIII managers made it clear
that they wanted a strong role for Region VIII states in the
process. While it was not practical to involve state staff in
the entire comparative risk project, a concerted effort to get
their input was made during the last two months of the project.
A complete set of the comparative risk analysis was sent to
each state for their review. Accompanying the analysis were
ranking worksheets identical to those used by the Region VIII
Comparative Risk Advisory Council, and state managers used them
to complete their own rankings of the issues. During late
October and early November, the Region VIII comparative risk
project director and one member of the senior staff made a visit
to each state to discuss how the risks in each state differ from
the ranking completed by the advisory council. A complete write-
up of these discussions can be found in the document titled
"State/EPA Discussions on the Comparative Risk and Strategic
Planning Initiative."
These state visits laid the groundwork for a state
directors' meeting held in Keystone, Colorado on November 8 & 9.
This meeting was attended by state environmental program
directors and EPA senior staff, and in addition to discussing the
comparative risk rankings, the group reached tentative agreement
on the major strategic goal areas that the region should pursue
through the strategic planning initiative. A description of
these goal areas will be forwarded to headquarters with this
report.
Based on the risk rankings completed by the states, the EPA
and state representatives present at the Keystone meeting agreed
to make some changes to the rankings completed by the advisory
council. These changes are summarized below.
Indoor air pollution and radon remained in category 1 of the
human health risk ranking but were combined to form one
issue. This was done because the group did not agree that
it made sense to break radon out as a singularly important
indoor air pollutant when that issue includes other
potentially serious pollutants like asbestos and
environmental tobacco smoke. Also, many state managers
think that the methodologies used to derive such high risk
estimates for radon are flawed.
Criteria air pollutants were moved from category 2 of the
human health risk ranking to category 1 due to large
populations in Colorado and Utah living in areas that do not
attain the federal health standards for these air
pollutants.
9

-------
Drinking water contamination and groundwater contamination
were elevated to category 2 of the human health risk
ranking. This recognizes the fact that these issues were
ranked 1st and 2nd for human health risk in North Dakota,
South Dakota, and Montana where air pollution concerns, both
indoor and outdoor, are limited. It also recognizes the
link between groundwater and drinking water in Region VIII
states.
Industrial and municipal solid waste were moved from
category 5 to category 4 in the human health risk ranking,
and from category 4 to category 3 in the ecological risk
ranking. This was done because the grpup felt that the
analysis missed important aspects of these problems that
would have been captured in a life-cycle analysis.
Physical degradation of terrestrial habitats was moved from
category 1 to category 2 of the ecological risk ranking
because the risks associated with this issue are limited in
some Region VIII states, and also because the group did not
believe that they were comparable to physical degradation of
wetlands and aquatic habitats.
Groundwater contamination was moved from category 5 of the
ecological risk ranking to category 2. This reflect an
intense concern over preserving and protecting this
invaluable resource in Region VIII states. While this is
not an ecological risk in the strict sense, it certainly is
an environmental risk, and the group chose to use the
broader definition in this case. Like many other ecological
risks, this reflects the relationship with what are usually
considered welfare effects.
10

-------
2.0 RISK SUMMARIES
The purpose of this section is to briefly describe the most
important factors that led the Region VIII Comparative Risk
Advisory Council to rank the issues the way they did. These
descriptions do not reflect the changes explained in the last
section that were made as a result of the state involvement
process. Complete descriptions of the risks associated with each
problem area can be found in the risk reports which were
published as a separate document accompanying this report.
Indoor Air Pollution
(Category 1 for health; unranked for ecological)
High human health risk due to wide range of pollutants found
indoors at relatively high concentrations. Exposure is
significant considering that people spend most of their time
indoors. Particularly dangerous pollutants include
environmental tobacco smoke, asbestos, and pesticides.
Occupational exposures to indoor air pollutants were
included, and this also drove the risk ranking higher.
Indoor Radon
(Category 1 for health; unranked for ecological)
Concentrations of indoor radon are relatively high in Region
VIII states. Risk estimates indicate a large population at
high risk of lung cancer due to exposure to indoor radon.
Pesticides
(Category 1 for health; Category 2 for ecological)
Health risk are driven by prevalence of pesticides in the
environment and numerous potential routes of exposure
including household use of pesticides; pesticide application
in urban environments; pesticide residue on food;
agricultural workers' exposure to pesticides; and drinking
water contamination.
Ecological risks are high due to widespread use of
pesticides in Region VIII and the likelihood of impacts on
non-target plants and wildlife. Pesticide use results in
nonpoint source surface water pollution that can directly
effect aquatic species and have a negative impact on aquatic
habitat. Bioaccumulation in the food chain has been
demonstrated to effect several species of wildlife.
11

-------
Criteria Air Pollutants
(Category 2 for health; Category 4 for ecological)
Large populations in Colorado and Utah live in areas that
exceed federal health based standards for particulate matter
and carbon monoxide.
See acid deposition and visibility degradation for
description of ecological effects.
Lead from all Sources
(Category 2 for health; Category 5 for ecological)
New information on health effects from lead show adverse
effects at lower blood-lead levels. In addition to lead
exposure from lead based paint, automobiles, and leaded
solder, Region VIII has areas of extreme lead contamination
from mining, smelting, and refining operations.
Ecological impacts are localized and not severe except in a
few isolated cases.
Nonpoint Source Surface Hater Pollution
(Category 5 for health; Category 1 for ecological)
High ecological risk results from nonpoint sources being a
major contributor to degraded surface water quality in
Region VIII. Sources include farming, ranching, mining,
urban runoff, and silviculture.
Human health risk is low due to limited routes of exposure.
Ozone Depletion and Climate Change
(Category 3 for health; Category 1 for ecological)
Even with the high level of uncertainty surrounding these
issues, they are believed to pose serious ecological risk.
This reflects the fact that if these effects occur the
damages will be catastrophic.
Human health risk is related to increased rates of skin
cancer from exposure to ultraviolet radiation that would
occur with ozone depletion.
12

-------
Physical Degradation of Terrestrial Habitats
(unranked for health; Category 1 for ecological)
Terrestrial habitat degradation is a serious problem in
Region VIII. Sources of degradation include drilling for
oil and gas, mining, logging, construction, urban
development, farming, ranching, and soil erosion. Among
other problems, this results in habitat fragmentation and
migration path blockage.
Physical Degradation of Wetlands and Aquatic Habitats
(unranked for health; Category 1 for ecological)
Relatively widespread destruction of wetlands from
agriculture and development, and damages to aquatic habitat
from alterations in the quantity and flow patterns of
surface water bodies resulted in a high ecological risk
ranking for this issue.
Mining Hastes
(Category 4 for health; Category 2 for ecological)
Although toxic pollution from mining is fairly prevalent in
Region VIII, it does not result in extensive human exposure.
Ecological impacts from physical degradation of aquatic and
terrestrial habitat, nonpoint source surface water
pollution, point source discharges, and toxic contamination
connected with mining in Region VIII are serious.
Drinking Water Contamination
(Category 3 for health; unranked for ecological)
The potential for a wide range of contaminants to be present
in drinking water, along with daily exposure to the entire
population, led to a fairly high human health risk ranking.
Of particular concern are individuals consuming untreated
groundwater as their drinking water source and the
possibility of contaminants going undetected in public water
supplies.
Hazardous and Toxic Air Pollutants
(Category 3 for health; Category 5 for ecological)
Population at risk is limited to population centers in Utah
and Colorado, and even these areas are not as heavily
industrialized as many other parts of the country. No
demonstrated ecological effects in Region VIII.
13

-------
Radiation other than Radon
(Category 3 for health; Category 5 for ecological)
Concern over radiation from mining and national defense
related activities, especially occupational exposures.
Possibility of risk to entire population from exposure to
sources of non-ionizing radiation including transmitters,
power lines, household appliances, televisions, and computer
monitors.
No demonstrated ecological effects in Region VIII.
Storage Tanks
(Category 3 for health; Category 4 for ecological)
Ranked higher for human health risk than other hazardous
waste issues because of the large number of storage tanks
spread throughout the region which are currently
uncontrolled and may be leaking. Program to address
potential risks not as mature as for other hazardous waste
issues.
Relatively low ecological risk since the majority of the
potential ecological risks are associated with groundwater
contamination.
Groundwater Contamination
(Category 4 for health; Category 5 for ecological)
Ranked lower for human health risk than drinking water
contamination since this issue represents a subset of the
total population considered under that issue.
Groundwater contamination was ranked very low for ecological
risk due to the fact that it does not usually result in
direct damage to ecosystems.
Hazardous and Solid Waste Issues
Ranked low for human health risk because strict regulations
and existing programs minimize potential problems. Also,
these facilities do not usually have a direct route of
exposure to large populations.
With the exception of Superfund sites related to mining,
these facilities do not generally pose significant
ecological risks.
14

-------
Municipal and Industrial Wastewater Discharges
Relatively low human health risk since discharges are
permitted and there are very few direct routes of human
exposure.
Ranked in category 3 for ecological risk because of adverse
effects on surface water quality.
Accidental Releases
(Category 4 for health; Category 4 for ecological)
Ranked low for human health and ecological risk. Impacts
tend to be localized and quickly remediated. Potential for
catastrophic event could lead to a higher ranking for health
risk.
Acid Deposition and Visibility Degradation
(unranked for health; Category 4 for ecological)
While surface water in Region VIII is vulnerable to acid
deposition because of low buffering capacity, there have
been few if any demonstrated effects to date. Sulfur
loadings are low in this part of the country.
Visibility degradation ranks low if you consider only direct
ecological risk, but ranks much higher if you interpret
ecological risk to include environmental degradation.
Visibility degradation, both in urban and pristine areas in
Region VIII is a serious problem. Particularly important
are protecting areas which currently have good visibility
(Class 1 areas) and addressing pollution problems in other
parts of the country that impact visibility in Region VIII
states.

-------
Appendix A
LIST OF ENVIRONMENTAL PROBLEM AREAS
FOR REGION VIII COMPARATIVE RISK STUDY
1.	Industrial Discharges to Surface Water
Industrial sources that discharge effluent into surface waters
through discrete conveyances such as pipes or outfalls. Does not
include municipal wastewater discharges. Pollutants of concern
include total suspended solids? BOD; toxic organics; toxic
inorganics such as heavy metals; and thermal pollution. Typical
sources include metal finishers, pulp and paper processors, and
iron and steel producers. Most of these sources require permits
under the National Pollution Discharges Elimination System
(NPDES).
2.	Municipal Wastewater Discharges to Surface Water
Includes all pollutants from public and privately owned sewage
treatment facilities. Major contaminants include those found
under Industrial Discharges, plus ammonia, chlorination products,
and nutrients. Combined sewer overflows are included in this
problem area.
3.	Non-point Source Discharges to Surface Water
Sources include agricultural, urban, and industrial runoff,
mining, silviculture, and public lands. Contaminants include
most of the constituents of industrial and municipal point source
pollution.
4.	Physical Degradation of Wetlands and Aquatic Habitats
Destruction and damage of wetlands, and damages from alterations
in the quantity and flow patterns of surface water bodies. Such
alterations include channelization, dams, construction,
irrigation systems, urban development, and dredge and fill
activities.
5.	Groundwater Contamination
All forms of groundwater pollution.
6.	Drinking Water Contamination
Contamination of public and private water-supplies (surface water
and groundwater) occurs from a wide variety of sources, both
natural and man-made. Additional contaminants may be introduced
during the treatment and distribution of drinking water.
Pollutants of concern include disinfection byproducts,
pesticides, metals, radionuclides, toxic organics, and
microbiological contaminants.

-------
7. Storage Tanks
Routine or chronic releases of petroleum products or other
chemicals from tanks that are above, on, or underground. Stored
products include motor fuels, heating oils, solvents, and
lubricants. Tanks may have air emissions, and can contaminate
soil and groundwater with such toxics as benzene, toluene, and
xylene. This category excludes hazardous waste tanks.
Accidental releases are excluded from this problem area.
8.	RCRA Hazardous Waste
Active and inactive hazardous waste facilities regulated under
the Resource Conservation and Recovery Act (RCRA). These include
landfills, surface impoundments, hazardous waste storage tanks,
hazardous wastes burned in boilers and furnaces, incinerators,
and solid waste management units. Seepage and routine releases
from these sources contaminate soil, surface water, groundwater,
and pollute the air. Contamination resulting from waste
transportation and current illegal disposal are also included.
Radiation from hazardous mixed waste is included here as well as
under the radiation problem area.
9.	Abandoned/Superfund Hazardous Waste Sites
Abandoned hazardous waste sites and those covered under the
Superfund program. Sites may be on the- National Priority List
(NPL), deleted from or candidates for the NPL, or simply be noted
by the federal government or states as unmanaged locations
containing hazardous waste. Sites may contaminate groundwater or
surface water, pollute the air, or directly expose humans and
wildlife. There are many pollutants and mixtures of pollutants,
including TCE, Toluene, heavy metals, and PCB's. Radiation from
these sites is included here as well as under the radiation
problem area.
10.	Municipal Solid Waste
Open and closed municipal landfills, sludge and refuse
incinerators, and surface impoundments. Medical and household
hazardous wastes area also considered under this problem area.
Groundwater, surface water, and air can be contaminated with
metals, particulates, toxics, BOD, microbes, and nutrients.
Contamination may occur through routine releases, soil migration,
or runoff. Most sites are regulated under Subtitle D of RCRA.
11.	Industrial Solid Waste
Open and closed industrial landfills, sludge and refuse
incinerators, and surface impoundments. Groundwater, surface
water, and air can be contaminated with metals, particulates,
toxics, BOD, microbes, and nutrients. Contamination may occur
through routine releases, soil migration, or runoff. Most
facilities are regulated under Subtitle D of RCRA.

-------
12. Accidental Chemical Releases
Contaminants are accidentally released into the environment in a
variety of ways from production processes and transportation of
hazardous materials and hazardous wastes. Human life may be
jeopardized, and damage to property and the environment may occur
from these intense, short term releases of toxic or flammable
chemicals. Acids, PCBs, ammonia, pesticides, sodium hydroxide,
and various petroleum products have been accidentally released.
13.	Pesticides
Risks to human health and the environment resulting from the use
of pesticides. Includes risks to individuals who apply
agricultural pesticides, risks from pesticide residues on food,
ecological damages from pesticides, and health effects from
pesticide use in residences, public buildings, and other
urban/suburban settings by both commercial firms and individuals.
Some of the more dangerous substances include ethyl parathion,
paraquat, dinoseb, EPN, aldicarb, and diazinon.
14.	Criteria Air Pollutants
Criteria air pollutants are the six pollutants for which National
Ambient Air Quality Standards (NAAQS) have been established under
the Clean Air Act. These are ozone, carbon monoxide, sulfur
oxides, nitrogen oxides, particulate matter, and lead. The
primary sources of these pollutants are related to the burning of
fossil fuels for various purposes. Other sources include'
fireplaces, wood stoves, forest fires, VOC sources (ozone
precursors), industrial and commercial processes, and
construction. These pollutants are capable of damaging human
health and the environment, and can also cause economic and
welfare damages.
15.	Acid Deposition and Visibility Degradation
While these problems are primarily the result of air pollution
being considered under Criteria Air Pollutants, they have been
broken out as a separate category in order to recognize the fact
that there are current efforts underway to assess and control
these problems that are different from the efforts to control
criteria air pollutants in urban areas-
16.	Hazardous/Toxic Air Pollutants
Outdoor exposure to routine emissions of airborne hazardous air
pollutants from mobile and stationary sources- Pollutants
include metals, organic gases, hydrocarbons, gasoline vapors, and
products of incomplete combustion. Major sources include large
industrial facilities, motor vehicles, chemical plants,
commercial solvent users, and other combustion sources.

-------
17- Indoor Air Pollutants other than Radon
Sources of indoor air pollution include unvented space heaters,
gas stoves, foam insulation, pesticides, tobacco smoke, wood
preservatives, fireplaces, cleaning solvents, and paints.
Pollutants include environmental tobacco smoke, asbestos, carbon
dioxide, carbon monoxide, nitrogen oxides, lead, pesticides, and
volatile organic chemicals. Occupational exposures are included,
as is inhalatidn of contaminants volatilized from drinking water.
18.	Indoor Radon
Radon gas can migrate into buildings through cracks or other
openings in the foundation and can volatilize from domestic water
use. When inhaled, radon decay products can cause lung cancer.
19.	Radiation other than Radon
Sources of non-ionizing radiation include TV transmitters, AM/FM
antennas, radar and microwave transmitters, power lines, home
wiring, household appliances, televisions, and computer monitors.
Sources of ionizing radiation include natural sources, Department
of Energy facilities, nuclear power plant operations, medical
facilities, research laboratories, mineral extraction industries,
medical x-rays, air travel, and occupational exposures.
20.	Mining Wastes
Health, ecological, and economic/welfare effects associated with
contamination of the environment by active and inactive mining
and milling sites. Includes impacts from air emissions, surface
runoff, point source discharges, groundwater contamination, and
aquatic and terrestrial habitat destruction. Major sources
include coal mining, hard rock mining, uranium mining, sand and
gravel mining, milling, smelting, and refining operations.
Pollutants of concern are metals, cyanide, radionuclides, acid
mine drainage, and sediments.
21.	Lead from all Sources
Human health risks, and subsequent economic/welfare effects, from
exposure to lead from all sources including air, soil, food, and
drinking water. Lead can be found in solder, water distribution
pipes, gasoline, and paint, and is emitted by mining, smelting,
and refining operations.
22.	Physical Degradation of Terrestrial Ecosystems/Habitats
Physical modifications (mining, logging, construction, etc.) and
other sources of physical degradation that damage terrestrial
ecosystems and habitats. Soil erosion, desertification, and
effects on undisturbed lands that result from nearby degradation
(habitat fragmentation, migration path blockage) are also
included in this problem area.

-------
23. Climate Change and Ozone Depletion
Increased atmospheric concentrations of carbon dioxide and other
gases may result in global warming that would cause climate
change and disrupt weather patterns. Potentially serious health,
economic, and ecologic impacts are possible. Releases of
chloroflourocarbons (CFCs) and other gases could significantly
reduce the earth's protective ozone layer and subject humans to
harmful ultraviolet radiation.

-------
Attachment E
REGION VIII STRATEGIC PLANNING PROJECT
STRATEGIC CRITERIA AND EVALUATION MATRIX
As primary criteria to focus potential reallocation
decisions in Region VIII, the following concepts are offered:
COMPARATIVE RISK: Focusing on the problems and issues that
present the highest risks, while reducing investments in lower
priorities, risk-wise. The Regional Comparative Risk Ranking,
compiled with regional/state/contracted expertise, will
serve as a guideline. (We emphasize that risk is only one of the
criteria.) Regional examples are a "worst sites first," multi-
media orientation in Superfund, as at Rocky Mountain Arsenal, and
the work being performed at Brookhurst in Wyoming. Ecological
risk is a major Regional priority, with emphasis on geographic
areas of greatest vulnerability, as in Colorado's South Platte
Ground Water project and Montana's comprehensive Clark Fork
project.
TECHNICAL ASSISTANCE/EDUCATION: The transfer of expertise to EPA
customers including states, tribes, industry and the general
public. Regional examples are state/EPA sharing of TRI data,
review of Denver Airport design plans, and inter-Agency
cooperative efforts on water quality impacts from mining and
agriculture. The Region 8 Institute and Office of External
Affairs will play a strong role; Divisional expertise and
outreach is critical too.
POLLUTION PREVENTION: An integrated search for alternatives that
will reduce or eliminate environmental impacts and pollution.
Examples are water conservation options in connection with
Two Forks Reservoir, SOLVNET, the Pollution Prevention
Partnership's Solvent Reduction project, Solid Waste
demonstration projects throughout our states, and the regional
focus on sustainable agriculture. An economic sector approach —
looking at environmental problems according to activities such as
energy and agriculture — will also be a special focus.
ENFORCEMENT; Special emphasis on targeted enforcement. Examples
are the Sand Creek Initiative and the region-wide Pollution
Prevention Enforcement Settlement project, in which enforcement
cases will use pollution prevention as conditions of the
settlement.
STATE/LOCAL/TRIBAL/EPA RELATIONS: Developing state and tribal
capabilities and "appropriate oversight." Putting more emphasis
on technical assistance and less on "micro-managing," and
stronger teamwork at the staff level. Working toward greater
fiscal flexibility at the state level, and developing full state
delegation wherever feasible. Good examples are the NPDES
program in Utah? and pesticides initiatives with the Turtle
Mountain tribe, and in North Dakota and South Dakota.

-------
MULTI-MEDIA PROJECTS; Focusing on inter-programatic solutions to
problems that avoid shifting pollutants/impacts from one media to
another. Good examples are vulnerability studies using GIS data
analysis, inter-media efforts at Superfund sites throughout the
Region, and multi-media inspections. These projects place a high
emphasis on teamwork regionwide, with states, and with other
federal agencies.
EVALUATION MATRIX
STRATEGIC CRITERIA
PROJECT/
ISSUE
AREAS
Aim 1
Area 2
•t. al.
Comparative
Risk
X
X
Technical
Assistance/
Education
X
Pollution
Prevention
X
Enforcement
X
X
State/Local/
Trlbal/EPA
Relatione
X
Multi-Media
Protects
X
X
2

-------
ATTACHMENT F
REGION VIII STRATEGIC PLANNING INITIATIVE:
Project/Issue Areas Under Consideration
INVESTMENTS
Build State/Local and Tribal Capabilities (e.g., IPA's to States, Toxicology,
and Groundwater Assessment Skills)
Enhance Regional Expertise to Optimize Technical Assistance Through
Training and "In Reach" (e.g., Pollution Prevention Audits and Innovations)
Develop Multi-Media Team Approach to Problems Using a Geographic Base
(e.g., Water Quality Issues at a Superfund Site)
Focus on Mining Waste Issues From a Multi-media Perspective (e.g., Clark
Fork River in Montana and Sand Creek Industrial Area in Colorado)
Increase Regionwide Awareness of Indoor Air Quality Issues
Use TRI Data to Identify Opportunities for Voluntary Pollution Prevention,
Technical Innovation and Enforcement
Increase Staff and Management Effectiveness Using TQM (e.g., Reduce
Duplication and Friction and Perform Tasks More Efficiently)
Focus on Sustainable Agriculture
Implement Water Conservation and Pollution Prevention at Municipal Facilities
REDUCED INVESTMENTS
Decrease State Oversight Where Appropriate
Eliminate Unnecessary Inspections, Permits, and Reviews
Reduce Activities at Lower Risk Superfund Sites
Redirect Municipal Waste Water Activities
Diminish Emphasis on Air Pollutant Standards Which We Have Attained (e.g. Ozone)

-------