EPA
United States
Environmental Protection
Agency
Office of the Administrator
Science Advisory Board
Washington DC 20460
SAB-EC-88-040E
September 1988
Final Report
Appendix E:
Strategies for
Risk Reduction Research
-v * •
-y*
T*fr .
$F -
Report of the Subcommittee
on Risk Reductiorli
i
i
Research Strategies Committee
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NOTICE
This report has be^n Britten as a part of the activities
of the Science Advisory Board, a public advisory group providing
extramural scientific information and advice to the Administrator
and other officials of the Environmental Protection Agency.
The Board is structured to provide a balanced, expert
of scientific matters related to problems facing the Agency.
This report has not been reviewed for approval by the Agencyr
hence, the contents of this report do not necessarily
represent the views and policies of the Environmental Protection
Agency or of other Federal agencies. Any mention of
names or . commercial products do not constitute endorsement or
recommendation for use.
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U.S.
Science Advisory
Research Strategies Committee
Risk Reduce ion Subcommittee
Dr.
8.614 ECJ
Civil
University of Texas, Austin, 78712
Mr.
Corporate Development Fellow
Union Carbide Corporation
Post Box 8361 (770/342)
Charleston, Virginia 25303
Dr.
Tufts University
• 474
-Hall
Center for Environmental t.lanagement
ttedford, Massachusetts 02155
Dr. Anil
Cornell University
, of llathraatics
Central
Ithaca, New York 14853-7901
Dr.
Institute of Technology
Building 66, 466
Massachusetts 02139
Dr.
Decision Research
1201 Oak
Eugene, Oregon 97401
Mr. Roger Strelow
Vice-President
Electric
3132 Turnpike
Fairfield, Connecticut 06431
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EXECUTIVE SECRETARY
Mrs. Kathleen W. Conuay
Deputy Director
Science Advisory Boara
U.S. Environmental Protection Agency
401 M Street, S.W., A101-F
Washington, D.C. 20460
STAFF SECRETARY
Mrs. Dorothy M. Clark
Staff Secretarv
Science Advisory Bcc.rd
U.S. Environmencal Protection Agency
401 M Street, S.W., Aid-?
Washington, D.C. 20460
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TABLE OF CONTENTS
PAGE
1.0 EXECUTIVE SUMMARY 1
1.1 Key Points in This Report 1
1.2 EPA Mission and Strategies 4
1.3 Risk Reduction Research Concepts 8
1.4 Risk Reduction Research Strategy 9
1.4.1 Hierarchy of Strategies 9
1.4.2 Continuum of Activities 11
1.5 Risk Reduction Research at EPA 11
1.6 Core Areas for Risk Reduction Research 15
1.6.1 Criteria for Selection 15
1.6.2 Core Areas for Research 15
1.6.3 Nature and Benefits of Core Areas 16
1.7 Implementation Strategies 16
1.7.1 Research Management Process 16
1.7.2 Education and Technology Transfer 19
1.8 Industry-Government-Academia Partnership 19
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Table of Concents Continued •
2°° BACKGROUND INFORMATION AND DETAILS 21
2.1 Risk Reduction: A Central Goal of Environmental 21
Research and Development
2.1.1 Risk Reduction Research and EPA1 s Mission 21
2.1.2 A New Environmental Policy 22
2.1.3 A Strategy for Risk Reduction Research ' 22
2.2 Defining Core Areas Within the Elements of Strategic 23
Risk Reduction Research
2.2.1 Defining tne Universe of Risk Reduction 24
Techniques
2.2.2 Preventing Wasce and Contaminant Generation 25
2.2.3 Recycling and Reuse 26
2.2.4 Treatment and Control 27
2.2.5 Reducing Exposure After Optimum Pollution 31
Prevention, Treatment and Control
2.2.6 Selecting Risk Reduction Strategies 34
2.2.7 Incentives for Risk Reduction 38
2.3 Education and Technology Transfer 39
2.3.1 Education and Training Programs 40
2.3.2 Technology Transfer 41
2.4 Implementation Strategies for Risk Reduction Research 43
2.4.1 An Orientation to Solving Problems 43
2.4.2 Establishing and Updating Priorities for 44
Risk Reduction
2.4.3 Extramural and Intramural Research 50
APPENDIX A: Memorandum of December 10, 1987 Entitled
"Economic Successes in Risk Reduction Research1
APPENDIX B: References
APPENDIX C: Areas of Strategic Risk Reduction H and D
- ii -
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OF AND
P^GE
1 :
2:
3:
4:
FIGURE 5:
6;
7:
of an Environmental 2
Risk Assessment/Risk Paradigp 2
of for Strategic 5
Risk Reduction Research
Involvements of Strategy ?
Council Core Workshops in Risk
Reduction Research Planning Implementation
Hierarchy for 10
Applies to Environmental 17
Risk Reduction
Education and Technology Trainsfer Important 20
to Reduction of to
the Environment
TABLE 1 :
2:
3;
Example Risk Reduction Activities
of
Value of Benefits
6
13
14
- 111 -
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1.0 EXECUTIVE SUMMARY
In 1987 the Science Advisory Board formed a Research Strategies
Committee to develop a strategy for environmental research and
development. At its first meeting on September 10-11, 1987 the
Coranittee identified five elements of the strategy: sources; transport
and fate; exposure; environmental effects; health effects; and risk
reduction as illustrated in Figure 1 on page 2. The Risk Reduction
Subconmittee met October 12, November 24, and December 17, 1987 and
March 16, 1988. The Risk Reduction Subcommittee prepared the strategy
which follows for the Research Strategies Coranittee. In terms of the
National Academy of Sciences Risk Assessment/Risk Management paradigm,
familiar to many EPA employees and illustrated in Figure 2 on page 2,
risk reduction includes both control options and some aspects of non-risk
analysis.
1.1 Key Points In This Report
The discussions and considerations of the Risk Reduction Subcomnittee
are contained in this report. The important points and recommendations
that resulted from those considerations follow.
1. Risk reduction, the central goal of EPA, should also be the
central goal of research and development at EPA.
2. Risk reduction research,"of the type defined in this report,
is appropriate for EPA and is not likely to be undertaken
by or to duplicate research by the private sector.
3. Risk Reduction techniques include both technology-based
strategies and other strategies (such as those in Table 1
on page 6) involving disciplines other than the physical
and biological sciences and engineering. EPA's research
program should address all appropriate risk reduction
strategies with systematic, rigorous development and
evaluation including peer review.
4. EPA should take a leadership role, broadly construing
its legislative mandates, in solving problems affecting human
health and the environment.
5. EPA should base its activities on a policy that has the
following hierarchy of risk reduction strategies. These
should apply to all environmental media:
a. preventing the generation of wastes, residues and
contaminants,
b. recycling and reuse,
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Figure .1: Elements of an Environmental Research Strategy
. SOURCE
-emissions
-transformation
-transport
EXPOSURE
EVALUATION
-human
-environmental
RISK REDUCTION HIERARCHY
-prevent generation of
wastes and contaminants
-recycle and reuse
-treat
-minimize residual exposure
EFFECTS
-human
-environmental
RISK
CHARACTERIZATION
low
priority
(no current action)
Figure 2: Risk Assessment/Risk Management Paradigm
RISK ASSESSMENT
RISK MANAGEMENT
Exposure
Assessment
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- 3 -
c. treatment and control techniques, and
d. minimizing residual exposure (containment,
exposure avoidance).
6. The research programs in important areas such as source
emissions, transport, fate; human and environmental exposure
evaluation and effects, and risk assessment, should be designed
to contribute effectively to the ultimate goal of risk
reduction, (see Figure 1 on page 2)
7. EPA in consultation with others, should identify core areas of
continuing risk reduction research using criteria presented in
this report. These core areas would support broad comprehensive
needs of EPA and would be critically reviewed periodically.
Examples of initial or candidate core risk reduction
research areas are:
a. preventing pollutant generation,
b. combustion and thermal destruction,
c. separation technologies,
d. biological approaches for detoxification and degradation,
e. chemical treatment of concentrated wastes and residues,
f. ultimate containment methods and approaches,
g. exposure avoidance,
h. risk communication and perception,
i. incentives for risk reduction,
j. education and technology transfer, and
k. environmental management and control systems.
8. EPA should develop strong scientific programs in each core
area, provide facilities and incentives to attract top
researchers to run these programs and maintain the stability of
funding needed to nurture scientific leadership in these areas.
9. Education and technology transfer are essential to achieve risk
reduction goals and are thus legitimate and important activities
of EPA and, particularly of the Office of Research and Development.
10. EPA should plan and conduct risk reduction research in partnership
with industry and acaderaia.
11. An EPA risk reduction research strategy should recognize that
there is a continuum of activities (Figure 3 on page 5 and
Table 1 on page 6) that individuals, groups and institutions
can engage in to reduce health and environmental risks. EPA
should design a comprehensive research strategy as recomnenaed
here based on capacity for risk reduction, without regard to
distinctions of discipline, long vs. short-term, pure vs.
applied, or scientific vs. engineering. Understanding where in
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Che continuum of activities it is appropriate to utilize resources
to reduce risk is a kev component of a risk reduction research
strategy. The firsc step, however, is to recognize that there
is a continuum of activities that make up an overall risk
reduction research strategy (Figure 3 on page 5).
12. A new process for implementation of risk reduction research
programs is essential. This process should ensure that the
most important present and future risk reduction issues and
problems are acted upon and that research outputs are relevant
and support program office risk reduction goals. The process
depicted in Figure 4 on page 7 would include:
a. Expanding the function of EPA research committees to
include all the elements of risk reduction research
programs contained in this report,
b. Mechanisms for active involvement of the external
scientific community and affected groups in defining
core areas of research and programs within these areas.
One mechanism is the use of periodic workshops convened
by the SAB involving ORD, program offices and the community
outside EPA, and
c. A Research Strategy Council consisting of senior administrators
and career executives throughout EPA to ensure that this process
results in the most effective risk reduction programs.
1.2 EPA Mission And Strategies
Prior to discussing an appropriate risk reduction research strategy
for the U, S. Environmental Protection Agency (EPA), it is necessary to
identify the basic mission of EPA. The mission transcends the specific
requirements of individual laws and provides the focus for all of the
activities in EPA, including research and development.
EPA's basic mission is to reduce the level of risk to health and to
the environment posed by wastes, residues and contaminants. In carrying
out that mission, EPA must carry out the programs mandated by law as a
first priority. However, state and local government, industry, the
general public, as well as people and institutions in other nations view
EPA as a world leader in all pollution caused problems affecting public
health and the environment. Viewed in this context EPA must provide
leadership on scientific and policy issues involved in environmental
protection and must balance environmental goals with other societal
goals.
In the past, EPA has largely focused on specific programs mandated
by Congress. More recently, EPA has assumed a broader leadership role by
' sponsoring research on global problems, including stratospheric ozone
depletion and indoor air pollution problems such as radon contamination.
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Figure 3: Continuum of Components for Strategic Risk Reduction Research
future
ttation
Dev'eJo
STRATEGIC
RISK REDUCTION
COMPONENTS
a mural
Strategic Risk Reduction Research contains
many inter-related components. Each concern
or problem requires a different set of activities
and outputs to reduce specific risks to human
.- health and the environment.
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PREVEOTINCj
KSJLWfWt
GENERATION
RECYCLING AMD
REUSE
TREATMENT HO
CCNTFCtt,
REDUCE RESIDUAL
EXPOSURE
TTJnrVTDUALS
TabEe 1: Exsmple Risk Reduction Activities
.2
Energy and water
conservation
Purchase non-hazardous
household products
Organic gardening
Reuse of paint
cleaners
Trade in used car
batteries
Donate unused paint
to school art
department
Asbestos removal
Auto inspection and
maintenance
Heating system
maintenance
liana ventilation for
radon, gaa stoves
Home water filtration
devices
Don't fish in polluted
waters
GROUPS
INDUSTRY
OTHER INSTITUTIONS
Car pooling
Integrated pest
management
Land acquisition for
environmental protection
Community solid waste
recycling
Oil recycling
Comminlty hazardous
waste recycling
Hater supply treatment
Community ccnposting
Landfill wood chipping
Proper sanitary landfill
Land use planning
Household hazardous
waste collection
Raw material
substitution
Process redesign
Product redesign
Solvent reclamation
Use of scrap iron in
steel making
Kraft process for
chemical and energy
recovery in pulp making
Solid and hazardous waste
incineration
Air pollution control
devices
Accident prevention
programs
Secure chemical landfill
Pollutant dispersion
technologies
Controlled pesticide
application
Purchase of biodegradable
products
Purchase of recycled
products
Zoning to protect
critical resources
Paper recycling
Commercial glass
recycling
Use ccmposted yard
waste for fertilizer
Co-ccrpoatiiig sludge and
solid waste
Wastewater treatment
Chemical inventory, audit
and control systems
Snake free work areas
Proper building
ventilation
Purchase bottled
water
1. Many of these strategies, e.g., energy conservation, caii^be aiployed by all
2. Communities, connunity groups
3. Federal and state government, acadtmla, health care institutions, ccnmercial business, etc.
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Figure 4: Example Involvements of Research Strategy Council
and Core Area Workshops in Risk Reduction
Planning and Implementation
RESEARCH
STRATEGY
COUNCIL
RESEARCH COMMITTEES
FOR IMPLEMENTATION
PLANNING AT LABS
AND ORD OFFICES'
EPA OFFICE
EVALUATION
WORKSHOPS*
plan 1 0-year
program for
core areas
\
OFFICE OF RESEARCH
AND DEVELOPMENT
AND
POLICY OFFICES
NON-EPAJ
*Non-EPA chair of workshops to advise on whether
the key items from the workshops get to the
Research Strategy Council
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- 8 -
The EPA research and development strategy should focus on problems and
areas where there is the greatest potential for reducing risk to human
health and the environment. This strategy will allow EPA to prevent or
control wastes, residues arid contaminants as efficiently as possible
while focusing the Limited resources of EPA on situations where these
items cause the greatest impact and where the greatest reduction of risk
can be accomplished.
It is clear that risk reduction is a critical aspect of the EPA
mission and can serve as an overall coordinating strategy. Research and
development mist support the risk reduction role of the Agency. Soundly
conceived and properly managed, an EPA risk reduction strategy would use
all available information and studies within and outside EPA to:
a. identify the scientific and technical approaches that have the
greatest opportunity for reduction of risk to human health and
the environment,
b. prioritize these approaches on the basis of relative
risk reduction,
c. provide the logic for resource allocation that is
consistent with relative risk reduction, and
d. provide a sound basis for regulations.
1.3 Risk Reduction Research Concepts
Research at EPA can be considered as:
a. supporting the specific programs and priorities of the
regulators, or and
b. more broadly supporting the basic objectives of the statutes
from which the regulatory programs are derived.
Research that is limited entirely to direct support of current regulatory
programs and priorities may fail to accomplish maximum feasible risk
reduction. Current regulatory activity may not always be focused on the
highest risk associated with the pollutants or activities in question.
Rather, such activity may merely fill gaps in regulations adopted years
earlier. In addition, control of some risks either is not yet, or
perhaps cannot be, dealt with primarily through regulations.
Risk reduction research cannot ignore the needs of ongoing regulatory
programs; however, it should address the needs in a broader, more comprehensive
framework. The total research program helps to reduce environmental risks in
complementary ways:
a. by supporting and facilitating implementation of regulations
aimed at reducing risk,
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_ 9 -
b. by defining the risK at issue and/or developing technology
needed to comply with risk-prevention rules, and
c. by demonstrating the feasibility of risk reduction actions
that, although consistent with regulatory requirements, may be
undertaken independently of regulations.
Therefore, an appropriate research and development program directly
reflects and supports the Agency's risk reduction strategy. Specifically,
planning as described in Figure 4 would determine what research and
development activities are needed to reduce the risk to human health and
the environment posed by wastes, residues and contaminants. Such planning
would also indicate the proper timing of that research and development.
Most importantly, by identifying the extent to which the research (if
successful) will reduce risks to human health and the environment, such a
program provides clear and firm logic for EPA research and development
activities. This facilitates the balancing of competing research
needs. Provision of information to state and local government and to the
public can accomplish risk reduction goals; education and technology
transfer, therefore, has an important place in the research strategy.
^"^ Risk Reduction Strategy
1*4--1 Hierarchy of Strategies — EPA should develop a national environmental
protection""policy based upon preventing environmental pollution and thereby
reduce risks as early as possible. This policy can be described as a
hierarchy of strategies (Figure 5 on page 10) for risk reduction consisting
of: preventing the generation of wastes and contaminants, recycle/reuse,
treatment, and minimizing exposure through containment, and avoidance
(for further illustrative examples, see Table 1 on page 6). As noted above,
the EPA research program should also reflect this same hierarchy of
strategies.
a. Preventing Waste and Contaminant Generation - The most effective
strategy to reduce riskto human health and the environment is
to prevent the production of waste and contaminants. Such a
strategy eliminates potential environmental problems,
Example: Substitution of water-based paint for solvent-based
paint in automaking
b. Recycling and Reuse - Strategies to recycle and reuse wastes
and contaminants can eliminate their release to the environment
thereby avoiding the need for treatment or disposal,
Example: Recycling waste oil
c. Destruction, Treatment and Control: Strategies to destroy,
treat, detoxify or control environmental contaminants in order
to eliminate or minimize their release should be employed for
all wastes which cannot be eliminated or recycled, and
Example: Incineration of hazardous wastes
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Figure 5: Hierarchy for Risk Reduction Research
potential
wast*,
residue,
and
contaminant
generation
prevent
generation
actual
wast*,
residua.
and
contaminant
generation
rei
rec
!S9/
;ycle
wastes
residues and
contaminants
reduced by
recycle/
reuse
tre
at
residual
and
contaminants
contain
avoid
minimal
exposure to
wastes and
contaminants
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d. Minimization of Residual - Once the generation of wastes
hasreduced the release of the
remaining controlled Co
optimum r remaining risk must be
by avoiding or minimizing
Example: Building ventilation
While risk reduction on all of major
control, and recycling receive greater
to to a
ultimate disposal. on environmentally
cost-effective of disposal also since
there will always be wastewaters, that require
treatment disposal. Research on other methods of
should be initiated.
1.4,2 of Activities — A risk strategy recognize
sible r isTT~reduction all part of of
(Figure 3 on 5). to
identify various of this However, as
technology artifical
distinctions Research and development for risk
reduction must be on what will risk, not be
limited by artifical or traditional distinctions. Adhering to this
principle will greatly perception of EPA by all interested
parties. Congress, public, EPA's staff. The program is
an of a non-regulatory program for risk reduction.
all effort all continuum.
pertinent knowledge but is not widely or disseminated,
educational technology transfer efforts be appropriate
stategies. For technologies approaches that technically
economically feasible, large-scale demonstration efforts may be most
appropriate. In situations, fundamental scientific technical
knowledge must be before the of a problem better
identified. The for efforts vary
on available the in obtaining
utilizing pertinent information.
Understanding where in the continuum of activities it is appropriate,
to utilize resources to risk is a key aspect in implementing of a
risk reduction research strategy.
1.5 Risk Reduction Research at EPA
The Question of whether the private sector, and not EPA, should fund
be responsible for control technology is frequently
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Risk reduction strategies encompass much more than treatment technology
(see Figure 5 on page 10 and TasLe 1 on page 6). Risk reduction research
includes research on all of the topics noted in the hierarchy shown in
Figure 5 on page 10.
The private sector is unlikely to take responsibility for risk reduction
research efforts (2, 3, 4). For several reasons, EPA must perform risk
reduction research if the nation is to achieve its environmental goals.
Research and development is in part a "public good" as evidenced by
studies which demonstrate that rr,any successful innovations come from
ideas generated outside the fine which develops the innovation. There are
also insufficient economic incentives for the private sector to perform
basic risk reduction research. Such research has a low chance of commercial
success.' Short deadlines for compliance with regulations encourage the
use of existing technology. No one company or industry is likely to have
a unique, important stance in nany environmental issues, thus making
individual action hard to justify to management or investors. Industry
is not monolithic; there are so many sectors involved that they will not get
together to sponsor generic research. The industrial sector has little
economic incentive to develop technologies which significantly reduce the
emissions of pollutants to below regulatory levels, knowing that such technology
may result in lower emission standards for all industry. In addition,
most pollution control companies do not have the financial strength to
devote significant resources to research and development. Moreover,
municipal wastewater and drinking water treatment are most often performed
by municipal governments which can hardly afford existing technology and
have traditionally invested very liccle in research and development.
Finally, EPA risk reduction research can provide large economic, health
and environmental returns. Recent studies by EPA indicate that successful
risk reduction technologies developed by EPA have saved the nation from
$30 to over $1,000 for every dollar spent by EPA. See Tables 2 and 3,
pages 13 and 14.
Other agencies such as the National Science Foundation, Department
of Energy, Department of Defense, and the Department of Health and Human
Services could conduct risk reduction research. However, the charters for
these agencies are not the same as for EPA. Although these agencies
support research which is technically and scientifically sound, it is
unlikely that such research would obtain the type of data needed by EPA
to make regulatory decisions or provide the research results in a timely
fashion to focus directly on and meet the EPA needs. Divorcing research
needed for risk reduction from the regulatory decision making process would
breed inefficiency and frustration and likely would result in regulator;/
decisions being made on incomplete knowledge.
EPA needs to conduct risk reduction research to assure the Agency's
credibility. EPA is the agency charged with protection of human health
and the environment. EPA is expected to be and needs to be the "authority"
in the broad area of environmental risk reduction. Therefore, it is
imperative that EPA have a strong risk reduction research strategy and
adequate resources to implement that strategy.
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Table 2: Examples of Benefits
EPA's Office of Research and Development has supported research on technologies
which have improved treatment effectiveness, reduced risk, and resulted in
savings of energy and costs. Successful technologies include:
For kastevaterTreatment
trickling filter/solids contact process which achieved
suspended solids and BOD of 10 rag/1 without effluent
filtration
secondary clarifiers with flocculator center wells
which produced average effluent suspended solids and
BOD of 5 rag/1
top-feed vaccun filtration for sludge dewatering which
yielded higher cake solids than bottom-feed vacuum
filters
For Hazardous Wastes
a Superfund Innovative Technology Evaluation (SITE) of
infrared incineration used for the decontamination of soils
on-site treatment for liquid wastes contaminated with dioxins
and furans using potassium polyethylene glycolate (called the
APEG on KPEG process).
raicrobial treatment for both in situ and on site treatment
See Appendix A for details.
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Tabfe 3: Value of Benefits
Benefit:- to-cost
Technology Expend!cure for Research National Cost Savings Ratio
Secondary $ 70 000 $ 380 000 000 1400 to 1
Clarifiers
with
Flocculator
Center Wells
Trickling S 290 000 $ 280 000 000 1000 to 1
FiIter/
Solids
Contact
Process
Oxygen $ 3 200 000 $ 14 000 000 3.3 to 1
Aeration
APH5
Treatment $ 212 000 $ 3 100 000 . 10 to 1
See Appendix A for details
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- 15 -
In .summary, the suggestion that private industry or other agencies will
undertake the risk reduction research needed to protect the nation if EPA
does not, is fiction. Protection of human health and the environment is a
public good, and a public agency should have lead responsibility for and
undertake riskc reduction research, development and demonstration. The
basic mission.of EPA is to reduce the level of risk to human health and
the environment. Therefore, it is appropriate for EPA to have a significant
and serious health and environmental risk reduction research effort.
1.6 Core Areas for Risk Reduction Research
Certain types of pollutants have a large impact on human health
and the environment and thefore require continuing attention and new
technical approaches. Risk reduction research in EPA should be organized
by core areas.
1.6.1 Criteria for Selection — Selection of core areas should be guided
by the following criteria:
a. problems of high risk that can be expected to persist for a
decade or more,
b. areas in which generic research can support a number of existing
and anticipated EPA and state programs,
c. areas in which inadequate information exists for sound regulatory
decisions and guidance, and
d. areas where research is unlikely to be conducted by others.
1.6.2 Core Areas for Research - Examples of initial or candidate core
risk reduction research areas are:
a. preventing pollutant generation,
b. combustion and thermal destruction,
c. separation technologies,
d. biological approaches for detoxification and degradation,
e. chemical treatment of concentrated wastes and residues,
f. ultimate containment methods and approaches,
g. exposure avoidance,
h. risk comrnunication and perception, and
i. incentives for risk reduction.
Other research strategy group reports discuss additional potential
core areas which can contribute to risk reduction. The development or
test methods and the conduct of risk assessments, for example, may support
the risk reduction effort.
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_ 16 -
1.6.3 jind_ Benef its_ of^ Cere Areas -- Risk reduction research in
core ultimately Include full of activities illustrated
by Figure 3 on 5. The challenge for EPA is to determine at point
in continuum to utilize available resources in of these core
in of on:
a. mtnimtzing cross-media transfer of ,
b, clarifying the technical scientific
6 on 17), and
c. identifying economics of feasible source reduction, recycling,
treatment disposal options,
reduction research the of
programs in a broader, more comprehensive framework. Gore focus
on problems soIutiDrs require an on-going research program
will current and future at
reducing risks to healer, ana the
Strength in the core benefits the offices by placing
EPA in a position to develop guidance for problems
at risk. in
reduction current and future risks- to health
environment, thereby increasing the quality of life productivity.
Such research is an that protects only present but
If world ideal, a risk reduction strategy could focus primarily
on problems that arising. However, a realistic
strategy resulted
current activities:
a. as sites
b. currently and residues are affecting
soil, air modifying
c. control of activities such as of chlorofluorocarbons (CFCs)
that the future risks to health the environment.
Risk reduction in core diverse problems,
1 ,7 1^1 emendation Strategies
1.7.1 Research Procjass - EPA a research management
tor risk reduce ion" "res'earch to that: (a)
important present future risk reduction Issues
upon, (b) research outputs relevant (c) the research supports program
office risk reduction goals. The process, depicted by Figure 4 on page 7,
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- 17 -
Figure 6: Fundamental Research Applies to
Environmental Risk Reduction
Increased Risk Reduction and a Clean,Healthy Environment
OTHER EXPLORATORY
PROGRAMS
NSF, NIH, NIEHS
OTHER RESERVOIRS
ATSDR.COC,
DOD, DOE, NASA
SLOW PERCOLATION
)W PERCOLATION
DIRECT REPLENISHMENT REQUIRED
NEW IDEAS
UNDERSTANDING
INSIGHT
ATELY SPONSORED
RESERVOIR
Or Joir L vwanar
« Univ«rn>y Ot Action*
UNDAMENTAL RESERVOIR
OF INSIGHT AND UNDERSTANDING
ON GENERIC PROBLEMS DIRECT
APPLICABLE TO EPA'S INTERESTS
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- 18 -
would expand the role of the existing research committees to include all
the elements of risk reduction research programs. The jurisdiction of
the research committees would include some elements which have not
been high priorities or a traditional part of the ORD mission, (e.g.,
chemical accident prevention strategies, risk communication).
The process would also involve mechanisms for periodic active
involvement of the external scientific community and other affected
and interested groups in defining core areas of research and programs
within these research areas. One such mechanism of involvement is the
use of periodic workshops convened by the SAB involving ORD, program
offices and the community outside EPA. Such mechanisms can give EPA
access to additional expertise which will assist the agency in targeting
the research efforts to the most important problems and can build external
support for its research effort. The proposed workshops will recommend
the relative resources that should be allocated to core areas and the
appropriate administrative structu7-es for carrying out the research.
These workshops probably will redefine the core areas.
A Research Strategy Council consisting of senior administrators and
career executives from all major EPA programs would oversee the process
to provide a continuing, high level management mechanism for the scope
and direction of risk reduction research. The Council would focus on the
cross-cutting issues that need attention and on how to structure approaches
that would assure that adequate resources would be available for the
designated core areas. The purpose of the Council would be to elevate
the shaping of each year's research program above the level, of simply
responding to separate and perhaps uncoordinated regulatory or program
office demands.
The Council would assure that adequate vision and support is provided
to:
a. identify broad problems areas of high risk that are characterized
by a lack of scientific understanding,
b. address problems in ways that generate timely research results
for decision-makers,
c. assemble and retain a qualified group of scientists, engineers
and other researchers, and
d. forecast new and escalating problems which will require research
and development efforts.
The Council would meet once or twice annually to review past efforts
and focus on major policy issues involving risk reduction programs which
require significant continuing research efforts. Such a body would also
provide a structured mechanism for high level input from research
administrators into the Agency's other programs.
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~~ - 19 -
•
The outside scientific community can develop and articulate technical
consensus opinions on a variety of issues for EPA to use in managing
research. One mechanism for the development of technical consensus is
workshops as illustrated in Figure 4 on page 7.
Problems for such 'workshops to address can be predicated in ways
analogous to those used for technological forecasting (16):
a. intuitive forecasting either by a committee of experts or by a
Delphi technique of separately and iteratively polling experts,
b. scenarios, or rich descriptions of assumed future conditions;
these are useful in looking at possibilities not defensible
with traditional logic and can examine extremes, and
c. monitoring or searching for signals of new concerns and for
better approaches to reduce or eliminate current and future
concerns.
1.7.2 Education and Technology Transfer — One of the greatest difficulties
in a risk reduction strategy is getting pertinent information to the
institutions, organizations and people who can use it. This is a particular
problem for small and medium sized industries, for state and local governments
and for consultants and design engineers. These groups and individuals look
to EPA for the needed expertise and knowledge. The .current EPA mechanism
for education and technology transfer is an _ad hoc system of individual
contacts and occasional seminars, training courses and conferences.
Education and technology transfer is a legitimate function of EPA
and of research and development at KPA. Private industry, academia and
EPA should work cooperatively to provide the education and technology
transfer to assure that the risk reduction research information is
adequately disseminated and used (Figure 7, page 20).
1.8 Industry-Government-Academia Partnership — It is important that EPA
include other sources of expertise as part of its risk reduction strategy.
Researchers outside EPA have much to bring to the endeavor that EPA often
cannot duplicate internally. EPA must lead a broad-based, multi-party
risk reduction research effort. For example, a risk reduction research •
partnership that includes industry is critical for source control, source
reduction and recycling studies. Such studies can involve research on process
redesign, product substitution and control technology.
There should be a strong extramural risk reduction research program
to complement the EPA intramural risk reduction research program. This
is important to encourage fresh interdisciplinary ideas and to make best
use or the talent that exists in the nation. The partnership can consist
of support for studies, technology transfer, use of facilities, joint use
of personnel and training. Investigator initiated research should be a
significant component of the effort.
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Figure 7: Education and Technology Transfer
are Important to the Reduction of Risks
to Human Health and the Environment
RISK REDUCTION
RESEARCH
a prevent generation
a control residual
and exposure
3 better education
and technology
transfer
EDUCATION AND
TECHNOLOGY
TRANSFER
Research and
Information Nsecfs
USERS
a regulators
a Industry
a public
a aeademia
ACTUAL
REDUCTION
OF RISK
TO HUMAN
HEALTH AND
THE
ENVIRONMENT
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- 21 -
*
2.0 BACKG_BOUND INFORMATION AND DETAILS
2.1 Risk Reduction:A Central Goal of Environmental Research and
Development ~~~
2.1.1 Risk Reduceion Research and EPA's Mission - EPA's basic mission »
is to reduce~cHe~TeveITof risk to human health and to the environment
posed by waste, residues and contaminants. In carrying out that mission
EPA must carry out the programs mandated by law as a first priority.
However, EPA is also viewed by state and local government, industry, the
general public and by people and institutions in other nations as a world
leader in all pollution caused problems affecting public health and the
environment. In this context EPA is viewed as an organization which must
provide leadership on scientific and policy issues involved in environmental
protection and must balance environmental goals with other societal
goals. A major responsibility in carrying out this mission is to provide
information to state and local government, industry and the public about
risk reduction strategies that will achieve human health and environmental
goals. Further, EPA is expected to develop and evaluate risk reduction
strategies in the legal, scientific, political, cultural and social
context in which it operates.
In the past, EPA's work on developing risk reduction strategies has
largely addressed the specific programs mandated by Congress. Itore
recently, EPA has assumed a broader leadership role by sponsoring research
on global problems including stratospheric ozone depletion and indoor air
pollution problems such as radon contamination. 'However, EPA's'research
effort has been focused on cleaning up existing pollution problems with
primary emphasis on pollution control technology. Moreover, the risk
reduction work has been oriented to problems in specific environmental
media such as control of water pollution control rather than generic
research oriented toward minimizing problems across environmental media.
The orientation of EPA's risk reduction research is a result of the
Agency following the narrow statutory mandates with tight deadlines for
applying risk reduction strategies. These statutory mandates use a
command and control regulatory approach designed to meet environmental
quality standards as a means of rectifying existing environmental problems.
Very little effort is expended on waste, residue and contaminant prevention
across all environmental media, the most effective means of future risk
reduction. This is not surprising. The EPA risk reduction research program
is a microcosm of the way in which society has approached environmental
protection problems. Pollution control has been reduced to a kind of programmed
thinking and a way of shaping questions and answers about environmental
management. As stated by Joel Hirschhorn of the Office of Technology
Assessment, "the entrenched, rigidly adhered to, and unquestioned
perception of pollution control as the way to achieve environmental
protection defines the paradigm and undermines pollution prevention." (15)
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- 22 --
In addition to not fostering waste, residue and contaminant prevention,
the pollution control strategy has become extremely expensive and caused
intermedia environmental prooleras, e.g., scrubbers which reduce air
pollution create a noxious sludge for land disposal. In addition, the
current strategy has not achieved r.ne broad environmental goals desired
by the public mandated by Congress and State legislatures.
2.1.2 A_Ngj_^&wirgrmejTta.l Policy - It is time for EPA t.o establish a
new nationaT~eTivir^nmentaI~poli"c^p based on a hierarchy of strategies for
risk reduction for all environmental media. The policy would establish
preventing waste, residue and contaminant generation as the primary
method of risk reduction. Preventing the generation of wastes, residues
and contaminants through source reduction or by natural resource management
would yield the greatest risk reduction because it eliminates or reduces
exposure to public health and the environment. As evidenced by the large
cost of rauediating problem from inappropriate hazardous waste management,
prevention is often the most ccst effective risk reduction strategy,
After exhausting these raetnods, strategies to recycle or reuse wastes and
prevent or reduce the release of contaminants would be applied. Next,
treatment, destruction, accident prevention and other control techniques
would be utilized to minimize the quantity and toxicity of substances
released into the environment:. Recognizing that such a policy cannot be
fully implemented for all environmental problems in the short run, it
will also be necessary to look at other exposure reduction techniques.
Strategies "such as containment, pollutant dispersion or.protecting individuals
from exposure would be employed as a last, resort in controlling or avoiding
any residual exposure from potential polluting activities. Figure 5 on
page 10 describes the conceptual idea of this environmental policy.
Table 1 on page 6 describes a number of actions individuals, groups,
industry and other institutions can take to reduce risks in the framework
of this new environmental policy paradigm.
2.1.3 A Strategy for Risk Reduction Research - Such a national policy
would "provide~"EPA' s~0f f Ice of Research and Development (ORD) with a
consistent conceptual framework for developing its risk reduction research
strategy. This research and development strategy should focus on scientific
and technical areas having the greatest potential for reducing risk to
human health and the environment. This strategy will allow EPA to control
pollution efficiently by focusing the limited resources of EPA on situations
where wastes, residues and contaminants have the greatest impact and where,
therefore, the greatest reduction of risk can be accomplished.
Such a research strategy should be based on a systematic way to
evaluate the risks to health and the environment and must consider:
a. assessment of sources, transport to a receptor and transformation
during the transport and ultimate fate of the contaminants,
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- 23 -
b. evaluation of Che exposure that humans or Che environment
rece ive,
c. determination of the effects Chat result from that exposure,
d. measures to reduce the risks that result, and
e. characterization of risk, to humans and the environment.
This system is depicted in Figure 1 on page 2. Risk reduction measures
can occur at many locations in the cycle and are a key component in EPA
decision-making and in the mission of EPA.
EPA's research and development strategy should identify and
quantify the links in the risk assessment-risk reduction scenarios
for specific major problem areas. Problem areas within EPA and state
responsibilities and mandates should be considered as well as emerging
problems such as global climate change.
The identification and quantification would:
a. more clearly identify scientific uncertainty,
b. indicate where more knowledge would reduce that uncertainty
and reduce risks to human health and the environment,
c. provide a better logic base to allocate limited resources, and
d. provide better information on which to base regulations.
The risk reduction part of the research strategy would focus on
determining what research and development activities are needed to reduce
risk to human health and the environment and what is the proper timing of
that research and development. Most importantly, the clearer, firmer
logic for EPA research and development activities should make it easier
both to prioritize competing research needs and to balance them based on
the extent to which the research will reduce risks to human health and
the environment.
2.2 Defining Core Areas Within The Elements Of Strategic Risk Reduction
Research
Selection of core areas for long range risk reduction research should
be guided by che following three criteria. The core areas should address
problems chac are expected Co persist over a period of a decade or more;
problems where generic research will support a number of existing and
anticipated EPA programs; and problems which are unlikely to be addressed
by the private sector.
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- 24 -
Workshops involving che appropriate experts, from both ORD and
academia, with representatives from the program offices and industry
would establish both the core areas and the comprehensive research program
directions within each area. In tnis mariner, programs of high scientific
quality relevant to EPA's goals can be formulated. EPA would also convene
periodic workshops to review the relevance of the core areas and to update
their programs.
EPA should maintain strong scientific programs in the core areas.
"Having a research program of high quality could pay off for EPA also by
enabling it to work with other agencies as a leader, not as a 'lead agency'
in the way OMB uses that tern, but as a scientific leader."(13) EPA should
encoura.ge researchers in the EPA laboratories to become world-class
investigators in their areas by publishing in premier journals and by presenting
papers at international society meetings. The active involvement of EPA
researchers at the frontier cf their fields would enhance the EPA's
credibility, and provide to EPA early access to research being done in
other laboratories.
Examples of core areas, to be identified and refined by the workshop
process defined above, follow. The EPA OEETD report on strategic risk
reduction research and development (5) identified research needs which
are listed in Appendix C, categorized by the core area into which they
might fit.
2.2.1 Defining the Universe of Risk Reduction Techniques - Traditional
environmental protection programs have employed a variety of technology-based
strategies for risk reduction. Most such strategies employ devices to
collect, store, convert, destroy or block the movement of contaminants to
meet environmental standards and/or to cut down on unsafe exposures. For
a variety of reasons, risk reduction techniques and strategies which
reduce or prevent the produceion or release of contaminants to the environment
without employing treatment or control technology are being increasingly
utilized. However, research on these techniques has been meager and has
suffered from having an inadequate conceptual framework to evaluate
efficacy, potential implementation problems or long terra costs. Because
of the increasing interest in these techniques and their potential to
have both positive and negative impacts on a broad range of societal
values it is imperative that EPA have a strong, coordinated research
program on these techniques.
Many of these risk reduction strategies, such as, prohibition of
hazardous substance production, product substitution or aquifer protection
zoning are often considered to be policy oriented or "soft science" and
have been developed and evaluated by EPA program and policy offices. The
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- 25 -
EPA Office of Research and Developrnenc (ORD) has concentrated largely on
technology-based risk reduction strategies. However, non-technology-based
techniques are extremely important and deserve the same systematic,
rigorous development and evaluaton as is traditionally applied to scientific
and technology-based strategies. Accordingly, EPA should consider expanding
the role of ORD to include research on these strategies. While this
would cause some minor organization disruptions it could greatly enhance
the credibility and use of those strategies.
2.2.2 Preventing Waste andContaminant Generation
The most effective strategy to reduce health and environmental risks
is to prevent the generation of environmental contaminants. This strategy
has two components:
a. source reduction, defined as changing industrial production
input materials and processes, substitution of products
using different raw materials, changing energy production
methods and fuels, and resource conservation which eliminates
or reduces the release of contaminants into all environmental
media - air, water and land, and
b. management of potentially polluting activities through
strategies such as local or regional land-use zoning to protect
critical resources, land purchase and acquisition, and watershed
management to effectively limit the generation or release of
contaminants in critical resource areas or population centers.
Source reduction should be applied to all potential environmental
contamination sources, from pesticides and toxic substances to air and
water pollution and hazardous and solid wastes.
The research strategy should address both components of the waste
and contaminant prevention strategy. The current waste minimization
strategy should be expanded to cover all environmental media programs,
including pesticides and toxic substances. In this context, waste should
be defined as any non-product substance (solid, liquid or gas) that
leaves a production process or site or that is released into the environment
in handling, use or storage. The research program should be oriented
toward:
a. understanding and developing strategies to overcome
barriers to and create incentives for source reduction.
Priorities include development of improved methodologies for
costing waste managenent alternatives, including life cycle
costs, and potential legal liabilities,
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b. improving technology transfer, technical assistance and
education programs designed to promote source reduction,
c. quantitative measurement of source reduction and recycling
accomplishments relative to production output and other
benchmarks of progress,
d. '• improving production and use of materials which can result in
environmental contamination,
e. improving, refining and developing better natural resource
management strategies such as local and regional land-use
zoning controls to protect critical resources, land purchase
and acquisition, and watershed management,
f. integrated pest management to reduce pesticide and
fertilizer use,
g. strategies involving substitution for and prohibition of
the use of harmful substances, and
h. energy conservation strategies,
2.2.3 Recycling and _Reuse - Environmentally sound methods of recycling
and reuse" of potential"contaminants can eliminate or greatly reduce the
release of contaminants to the environment, reduce the amount of waste to
be treated or disposed of, and reduce the generation of pollution from
the use of virgin materials. For example, the recycling of solvents in
an industrial facility can eliminate air pollutant releases and hazardous
waste which must be incinerated or landfilled.
The research strategy should include the following elements:
a. expansion the recycling component of the current waste
minimization strategy to all environment media,
b. research on strategies to create adequate markets for
recycled goods (secondary materials),
c. understanding and developing strategies to overcome
barriers to and create incentives for recycling,
d. development of improved methodologies for costing
waste management alternatives, including life cycle
costs and potential legal liabilities, and
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e. research on ways to recycle specific products and
pollutants which create the most significant
problems when released or disposed of, e.g.,
plastics, solvents, batteries, tires, inks, pigments,
autos.
2.2.4 Treatment and Control — Strategies to prevent the generation
of contaminants and/or strategies for recycle should be the first choices
for risk reduction. When these strategies have been exhausted, strategies
and techniques which destroy, treat, detoxify and reduce either the volume
or toxicity of environmental contaminants should be applied. This approach
will reduce and, if applied vigorously, minimize the release of environmental
contaminants.
There are a nunber of strategies for controlling environmental
releases to reduce or minimize the potential forrelease of and exposure
to harmful substances. These include:
a. facility management programs such as
o accident and spill prevention systems
o information, audit and control systems
o plant risk analysis,
b. auto emissions inspection and maintenance programs,
c. environmental monitoring and surveillance systems, and
d. labelling of products to ensure safety of use,
recycling and proper disposal.
EPA should develop a coordinated, systematic research program to evaluate
and further develop such strategies as an important component of risk
reduction research.
Further combustion and thermal destruction research can contribute to
treatment and control of wastes, residuals and contaminants. The products of
combustion of fossil fuels are pervasive in our industrial society. This
source accounts for the emission of 90 tons/capita per year of combustion
products in the U.S., is the dominant source of the criteria pollutants,
and is the cause of current concerns with pollution on a local (NO and CO
in homes), regional(NOx and SO^), and global(C02 and N^O) scale. This
source has the potential of being of continuing concern into the forth-
coming decade and beyond into the 21st century as fuel consumption and
combustor designs change. In addition, the high temperature processes in
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combustors for fossil fuels, in wood stoves, in municipal and hazardous
waste incinerators, and in a number of the high temperature pyrolysis and
other thermal destruction methods proposed for Superfund sites have much
in cannon. Generic, research areas could include the following:
a. The chemistry of high temperature reactions: Models of the
reactions in flames and pyrolysis units, together with
mixing models, will be of benefit for defining products of
incomplete combustion (PICs) in incinerators or for
anticipating the conditions that lead to the formation of
previously unsuspected pollutants such as N'20 in furnaces.
b. Mixing: ttuch can be gained from a more fundamental
understanding of the mixing process in order to reduce
emissions from a wide range of combustors. For example,
the effectiveness of destroying 11G in furnaces by hydro-
carbon injecticnCreDurnuig) or the burnout of primary
pyrolysis products in the secondary combustion chamber
of hazardous waste incinerators or above the grates in
a municipal incinerator depend upon attaining mixing of
the reactants at a molecular level.
c. Aerosol generation and elimination: The.vaporization of
trace metals from the incineration of municipal sludges,
municipal solid wastes, and hazardous wastes as well .as
- from the inorganic constituents of coals and oils results
in the formation of fine aerosols that are difficult to
collect. Understanding of the mechanism and the rates
governing the processes could both better guide the field
monitoring programs designed to evaluate this mode of
mobilization of heavy metals, as well as suggest improved
coobustor operation to minimize emissions.
d. Gas-solid reactions: Problems that will certainly continue
to be of concern over a decade include the capture of sulfur
by limestone, the burnout of a solid residue in an incinerator,
the development of advanced sorbents for gasifiers with
the potential for high temperature applications. These
problems are part of a wide class of gas-solid reactions,
the understanding of which could lead to improvements in
processes such as acid gas removal or the reduction of the
formation of a throwaway by-product.
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e. Development of real-time monitors: Monitors for continuously
measuring the emissions from incinerators would, by providing
a means of rapidly responding to process upsets, enable the
reduction of emissions of products of incomplete combustion
and, hence overcome some of the objections to the use of this
technology. A number of options exist, but require the
development of toxicological and risk correlations between
the compounds of concern and compounds that are readily
measureable.
This partial listing illustrates the potential for defining areas of
research in combustion that pertain to several classes of problems which
fall in EPA's purview. Combustion is an .area of research pertinent to
other agencies. EPA's role should be the development of a long range
research program built around topics, such as mixing and kinetics, that
can serve short-term goals on identification and destruction of PICs or
acid rain precursors, as well provide information that would be relevant
to potential future problems.
Physical and chemical treatment can be used to destroy, treat, detoxify
and reduce either volume or toxicity. Among the roore pervasive environmental
problans is the treatment of waste streams containing very low concentrations
of pollutants. The pollutants may be dispersed in a gaseous, liquid, or
solid stream either in a molecular form or as fine particles(aerosols or
colloids). The.challenge is to achieve high removal efficiencies at low
concentration levels, while minimizing the formation of undesirable
by-products, and to develop cost-effective technologies in process.
These problems have been of importance throughout the history of the EPA.
Many of the problems are site-specific and are being adressed by the
private sector. There are, however, a large number of medium and small
companies utilizing chemicals that do not have the technical resources
to recognize the environmental problems to which their effluent streams
may be contributing or to develop and implement an appropriate control
strategy. The EPA has an important contribution to make in conducting
the risk reduction research for these smaller and medium sized companies.
Additionally, EPA needs to conduct risk reduction research for
problems generated by households, by municipalities, and by other parts
of the public sector. Air toxics illustrate these problems since a major
fraction of the organic molecules in urban atmospheres comes from a wide
variety of dispersed and currently unidentified sources. Another example
is the contamination of both drinking water and effluents from municipal
wastewater treatment systems, where traditional treatment methods are
often found to be inadequate.
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Suggestions for Che type of core research that could be done include:
a. Fine Particle Conrrcls: The control of the emissions of
toxic metals requires the development of improved under-
standing of che control of the fine particles produced
by vaporization/condensation. Particles in the 0.1 to
1.0 micron size range are of special concern,
b. Absorption/Desorption: Better understanding of the
absorption and desorpcion by high surface area porous
solids would be of benefit for both the better design
of filters, such as activated carbon, and for the
possible development of more economical means of
removing trace contaminants from soils.
c. Concentration of Wastes: Economies can be achieved by
reducing the volume of the waste stream. Innovative
methods such as supercritical extraction, liquid membranes,
and reverse micelles are providing new directions in
separation technology.
d. Advanced Chemical Treatment: Detoxification of wastes by
chemical treatment is very cost-effective. The method must
be tailored to the waste in question since the chemical
• reactions are specific to a compound or class of compounds,
arid the method of application depends upon the physical
nature of the waste. The on-site dechlorination of compounds
in soils (the APtLi and KPiE processes) is a good example of
the potential of such technologies.
By far the most versatile, cost-effective approach for treating
most organic pollutants at low concentration is through use of biological
systans for controlling pollutant release. A continuing core research
program is needed co take full advantage of such systems. A research
initiative EPA proposed in this area in March 1987 (17) should be supported;
however, more emphasis should be placed on utilizing naturally occuring
organisms than was originally proposed.
Key generic research activities in this area of include the following:
a. Identify and characterize biotransformation processes
occurring naturally in surface waters, soils, and
aquifers. Establish optimal conditions co enhance
transformation races.
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b. Evaluate the utility of genetically engineered
organisms in effecting transformations'not achievable
by natural organisms at reasonable rates.
c. Develop new biosystem concepts for incorporating natural
and engineered organisms and conditions to effect desired
transformations. Include in situ treatment as well as
centralized treatment facilities. Develop improved
mathematical models to describe biological treatment
operations. Initial emphasis may be on cleanup of Super-
fund sites, but the program should have broad pertinence
to wastewater treatment, land treatment, and aquifer
restoration. Include research on anaerobic and aerobic
systems for wastewater treatment and sludge stabilization,
on enzymatic reagents and delivery systems for treatment
of contaminated soils, and on treatment of combined sewer
overflows.
d. Determine the environmental fate and effects of the
treatment residuals, including engineered organisms.
Develop means for proper communication of risk (or lack
thereof) to the public.
e. Develop means to mitigate adverse consequences of the
release of engineered organisms.
f. If not covered under other programs, include research
on pathogen inactivation.
2.2.5 Reducing Exposure After Optimum Pollution Prevention Treatment and
Control — Once the generation of environmental contaminants has been
reduced and the release of the remaining contaminants has been controlled
to the optimum extent, any remaining risk must be addressed by avoiding
or minimizing exposure. This can be accomplished by strategies such as
proper land containment, pollutant dispersion, use of home water treatment
devices, buffer zones and risk communication.
An important part of the EPA risk reduction research strategy must
be a viable, strong research program that investigates sound approaches
for the land containment and disposal of wastes and residues. Land disposal
will continue to be a very important risk reduction activity. There are
only three major ultimate disposal locations: air, water and land. Although
other options exist and will be used, land disposal has a continuing,
inevitable and important risk reduction role for EPA and for the nation.
Land disposal options will continue to be needed, and as part of meeting
overall EPA needs, land disposal research can help assure that such
disposal will be protective of human health and the environment.
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Environmentally sound land disposal practices will be needec even
more in Che future for: municipal solid waste, household hazardous wastes,
very small quantity generator hazardous wastes, residues resulting from
treatment of hazardous wastes; high volume wastes such as fly ash, bottom
ash and mining wastes; CERCLA remediation and removal wastes; incinerator
residues; demolition wastes; and contained wastes that have no other
technically feasible or economic disposal alternative. In addition,
technology is needed to retrofit existing land disposal facilities and
for future facilities. EPA needs a strong land disposal research program
(LDRP) to address these issues.
Another ne'ed that can be met by a strong LDRP is to evaluate
and understand the long-terra performance of what are now considered
environmentally sound and technical!'/ appropriate land disposal practices
and the associated monitoring methods to assure that they are environmentally
sound over many decades. In spite of the research conducted to date, it
remains very difficult to predict that improved land disposal practices,
such as "secure" landfills, will protect banian health and the environment
in future decades. Without such an understanding, the nation will never
have permanent verified solutions to the proper management of the above
wastes and may find itself caught with the need of continuing to clean up
waste disposal sites, because of no cohesive, viable LDRP.
A recent review (6) of the current EPA LDRP concluded that EPA does
not have a waste management strategy that clearly defines the continuing
role of land disposal and that recognizes the need for a strong and vital
LDRP. Unless this is corrected, EPA and the nation will lack the scientific
and technical knowledge necessary to the ongoing development of scientifically
sound land disposal guidance and regulations.
This situation appears to have occurred because, as with almost all
EPA programs, the LDRP is driven by immediate and legitimate program
office needs for information to support Congressional mandates and court
deadlines to develop regulations. As a result of changing program office
direction, the research focus has shifted during the past decade. In the
1970's, the LDRP emphasized municipal solid wastes in response to the
needs of the Solid Waste Disposal Act. With the passage of the Resource
Conservation and Recovery Act (RCRA) in 1976, the focus began to change
to the control of hazardous wastes. In recent years, the LDRP has evaluated
whether hazardous waste land disposal methods are protective of human
health and the environment. With the current (RCRA) emphasis on alternative
technologies to land disposal (needs that resulted from the requirements
in the 1984 RCRA Amendments), the perceived need for hazardous waste land
disposal research efforts has declined. These funding reductions cripple
the program's ability to meet future technical requirements in regard to
the use of environmentally souna land disposal methods. The net effect
of these cumulative individual decisions results in EPA being left with a
LDRP that does not meet the Agency's overall long-term needs.
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The Science Advisory Board review (6) recommended numerous efforts
that should be parr of a land disposal research strategy. These included:
a. identification of changes in the characteristics of wastes likely
to be land disposed in the future,
b. field scale research to have a technical understanding of the
performance of cover and liner systems. The emphasis on land
disposal closure and post-closure operations and monitoring
should be Increased because many land disposal facilities
recently have closed, and others will close,
c. research on approaches and designs that facilitate liner and
cover repairs,
d. evaluation of monitoring data at permitted facilities to evaluate
containment designs, and
e. an increase in cooperative efforts with the private sector to
develop better analytical and evaluation methods for constructing
and defining the performance of land disposal components and
systems.
Assuming that opportunities to mediate those environmental processes
which transport and transform the contaminants are unconmon and also that
personal protective devices are an undesirable last resort, then a promising
area of research concerns education of the public on personal exposure
avoidance.
Research into human exposure avoidance embodies sociological, cultural
and psychological issues. Learning what motivates people to take action
concerning their health and how to prepare and deliver educational materials
to be effective are essential elements. Exposure avoidance, by personal
action, deserves its place along with source reduction and control as an
important element in a strategy of risk reduction. A companion research
program in total human exposure would provide the technical information
used in the exposure avoidance.
Other programs in risk reduction through exposure avoidance relate
to protection of pesticide applicators and asbestos abatement workers;
drinking water treatment (central and at point of use); providing alternative
sources of drinking water, indoor air ventilation, and land use planning
(e.g. industrial buffer zones). Of these, continued core research programs
are recommended on drinking water treatment (particularly at point of
use) and on the reduction of indoor air pollution from passive smoking,
asbestos, solvents, combustion products and radon.
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Proper siting of noxious facilities is an important strategy in
reducing public exposure ana environmental contamination from harmful
substances. EPA's research strategy should address both technical and
non-technical strategies to iroprove government decision-making on siting
potentially noxious and polluting facilities. The research should focus
on improving the use of sicir.g as a strategy to minimize public exposure
and environmental contamination and on overcoming barriers to siting,
recycling, treatment and disposal facilities needed to reduce environmental
risks.
2.2.6 Selecting Risk Eeduction Strategies -- The selection of risk reduction
strategies to^ achieve desired risk reduction goals will involve a variety
of legal, scientific, economic, political and social factors. However,
one critical element in Baking these decisions is the communication
between decision-makers, parties affected by the decisions and others, e.g.,
the news media and acadeiics, who report, chronicle and evaluate these
decisions. Indeed, some would argue that risk conmunication is the most
critical element in such decisions. Because it is newly emerging as a
defined subject area of intellectual organization and because of its
importance, EPA should .expand and develop a strong research program in
risk communication.
The importance of risk communication to risk reduction efforts was
recently expressed by Milton Russell, former assistant administrator
for Policy, Planning and Evaluation at. EPA. Russell observed that:
"leal people are suffering and dying because they don't
know when to worry, and when to calm down. They don't know
when to demand action to reduce risk and when to relax, because
health risks are trivial or sitnply not there. I see a nation
on worry overload. One reaction is free floating anxiety. Another
is defensive indifference. If everything causes cancer, why stop
smoking, wear seat belts or do something about radon in the home?
Anxiety and stress are public health hazards in themselves. When
the worry is focused on phantom or insignificant risks it diverts
personal attention from risks that can be reduced."
Implicit in Russell's statement are two basic functions served by risk
conmunication. One is the provision of basic information and education
in order to help people understand risk and put it in perspective so that
they will know "when to -worry and when to calm down." Communications
about the risks from eating flour contaminated with EDB or drinking water
containing radioactive fallout from Chernobyl are examples of this category
of information. The second function is to communicate in order to motivate
necessary risk-reducing actions such as renovating a home that has high
radon levels or disposing of household chemicals properly.
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The goal or informing people about risk and motivating behavior
change sounds easy in principle but is surprisinglv difficult co accomplish.
To be eftective, risk conniunicators must recognize" and overcome a number
of obstacles. First, doing an effective job of conmunicating means
finding comprehensible ways of presenting complex technical material that
is cloaked in uncertainty and is inherently difficult to understand. To
further complicate matters, risk information may make a hazard seem more
frightening, even when the aim of the message is to calm public concerns.
When public attitudes and perceptions are well established, as with
nuclear power, they are hard to modify because new information is filtered
in a way that protects established beliefs. However, when people lack
strong prior views, the opposite situation exists—they are at the mercy
of the way that information is presented or "framed." 'in such cases,
subtle changes in the ways that risks are expressed can have a major
impact on perceptions and decisions.
Understanding risk perception is critical to clearly "framing"
and cotornunicating rusk's to the puElic. Many risk analysts have argued
that health risks can best be understood and appreciated by means of
comparisons with risks from other (often more familiar) activities. Such
comparisons are thought to provide a "conceptual ruler" that is intuitively
more meaningful than absolute numbers or numerical probabilities. Yet,
to date, there is little specific knowledge about how to formulate such
comparisons and determine whether or not they communicate effectively.
There is a need for creative new indices and analogies to help individuals
translate risk estimates varying over many orders of magnitude into
simple, intuitively meaningful terms. The task will not be easy. Ideas
that appear, at first glance, to be useful, often turn out, upon testing,
to make the problem worse. For example, an attempt to convey the smallness
of one part of toxic substances per billion by drawing an analogy to a
crouton in a five-ton salad seems likely to enhance one's misperception
of the contamination by making it more easily imaginable. The proposal
to express very low probabilities in terms of the conjunction of two or
more unlikely events (e.g., simultaneously being hit by lightning and
struck by a meteorite) also seems unwise in light of experimental data
showing that people greatly overestimate the likelihood of conjunctive
events. Perhaps public understanding of quantitative risk can be improved
by studying their understanding of commonly used measures, such as distance,
time and speed.
The sensitivity of risk communications to framing effects points to
another avenue for research. We need a better understanding of the
magnitude and generality of these effects. Are public perceptions
really as malleable as early results suggest? If so, how should the
communicator cope with.this problem? One suggestion is to present
information in multiple formats—but does this help or confuse the
recipient? Finally, the possibility that there is no neutral way to
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present information, coupled with the possibility that public preferences
are very easily manipulated, has important ethical and political implications
that need to be examined.
Because of tr£ complexity of risk comnunications and the subtlety of
human response to them, ic is extremely difficult, a priori, to know
whether a particular message will adequately infomfics recipients.
Testing of the message provides needed insight into its impacts. In
light of the known difficulties of communicating risk information, it
could be argued that an agency which puts forth a message without testing
its comprehensibility and effectiveness is guilty of negligence or at
least of short sightedness. This assertion raises a host of research
questions. How does one test a message? How does the communicator judge
when a message is good enough in light of the possibility that not all
test subjects will interpret it correctly?
Risk communication is closely linked with risk perception. To
communicate effectively, we need to understand the nature of public
knowledge and perceptions. Thus, a ccxprehensive research program on
risk reduction also needs to include research on risk corammication
and perception-
Some general research questions dealing with research on risk
communication and perception are:
a. What are the determinants of "perceived risks?" What are
the concepts by which people characterize risks? How are
those concepts related to their attitudes and behavior
toward environmental hazards?
b. What steps are needed to foster enlightened behavior with
regard to risk? What sorts of information do policy makers
and the public need? Kow should such information be
presented? What indices or criteria are useful for putting
diverse risks in perspective and motivating desirable
behavior change? How should uncertainty be explained to
the public and to policy makers?
c. What makes a risk analysis "acceptable?" Some analyses
are accepted as valuable inputs to risk management decisions,
whereas others only fuel controversy. Are these differences
due to the specific hazards involved, the political philosophy
underlying the analytical methods, the way that the public
is involved in the decision-making process, the results of
the analysis, or the incorporation of social values into
risk analysis?
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d. How can polarized social conflict involving risk be reduced?
How can an atmosphere of cruse and muDoal respect be created
among opposing parties? How can we design an environment
in which effective, multi-way communication, constructive
debate, and compromise can take place?
e. Are certain contexts of risk communication more or less
conducive to the processing of risk information? The
information-theoretic model of risk communication has been
useful to a limited degree, but it is too constraining.
In addition to looking at information flow, channels and
receivers, we have to look at the social and cultural
contexts within which scientific information gets transmitted.
f. In dealing with public perceptions of risk, we need research
that examines now people come to an understanding of risk
in real time, under actual conditions. Ethnographic case
models are important. Laboratory models of risk perception
have provided an important conceptual framework, but they
need to be complemented by analytic case studies.
g. How do we get consensus in the expert community? What are
the factors that impede consensus? We need to know more
about the problem of risk communication between experts.
h. How should lack of scientific consensus be transmitted to the
lay public? We need to clairfy and describe the issues in an
understandable manner for public consumption.
Risks can be defined as threats to people and things they value (their
health, their finances, the quality of their environment). Considerable
research has been directed toward assessing values associated with human
mortality and morbidity, so that these values could be factored in to
risk benefit analyses. Much less attention has been given to the valuation
of environmental features such as clean air and water, protection of
plant and animal species, etc. Typically these valuation efforts have
been approached from an economic (e.g., cost-benefit or willness to pay)
perspective. For instance, the public and policy makers are asked to
assume that a market exists for trading such "goods" and they are asked
to estimate appropriate "prices" expressed in terras of "willingness
to pay" to save (or to avoid the loss of) a honan life, to clean up a
polluted lake, to preserve an animal species, and so on.
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The market approacr. t: ./aiLiir.i 20003 ror which r.o ~arK.ec actually
exists has come under severe ori-icLsra, however, on che grounds that it
is biased at best and invalid at \nrst. Ic appears that many outcomes
associated with environmental protection may simply not be able co be
evaluated in terras of well-definec dollar values that can be compared
with monetary values for traced goods or services. People may care about
maintaining a clean environment, reducing perceived risks, protecting
their health, or preserving a threatened animal species without really
being able to express the importance of such outcomes in terms of
monetary values. Instead, their values may reflect a complex mix of
aesthetic, moral, political, psychological, social and economic concerns
that need to be measured by innovative new methods. The methodology of
multi-attribute utility theory, for example, might be used co construct
overall values from the ccnpcnent ainensions of value.
Thus, aespite modest research efforts in the past, we still lack the
ability to evaluate many out coir es
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2.3 Edocacion jindJTechr.clogy Transrer
One of Che greatest difficulties in implementing innovative risk
reduction strategies is getting the information in the hands of institutions
and people who can implement the strategies. For example, they are often
faced with a proposal for a new facility which wishes to employ a new
technology for risk reduction. In addition to checking the literature
and consulting professional colleagues, state and local officials often
call EPA and sometimes other states for advice. They do so for several
reasons. They assume EPA has or should have the expertise to evaluate
the technology, and that EPA and other states may have been faced with
similar issues. Moreover, state and local governments feel that they are
on firmer ground with the backup of EPA or another state which condones,
has approved or utilized the technology or strategy. State and local
governments also perceive the value of technology transfer activities to
their communities and local economies. EPA assistance that enables
coraraunities to achieve environmental goals more cost-effectively is
clearly beneficial. The current mechanism for obtaining this assistance
is an ad hoc system of individual contacts with occasional seminars,
training courses and conference by EPA.
The problem is not unique to state and local government. Business
and industry (particularly small and medium sized) also need a better
mechanism for obtaining information about risk reduction technologies and
strategies. For reasons of competition and lack of expertise or other
resources, small and medium sized industries do not often have access to
.the latest information to reduce risks. An important example of this is
getting information to (and acceptance by) farmers on integrated pest
management to reduce risks from pesticide exposure. Similarly, the public
which is demanding and having a larger role in government and private
decision-making on environmental protection needs information on the
effectiveness and application of risk reduction strategies and technology.
Jtoreover, academic programs at universities and other institutions
must have access to information on innovative risk reduction strategies
to ensure that educational programs will be providing the personnel who
can implement risk reduction programs.
To date, EPA has not had a coordinated, comprehensive strategy for
_coranunication and education on risk reduction strategies. This is
especially true for the Office of Research and Development which has been
unable to budget resources for technical assistance, technology transfer
and communication, except in a few specialized cases.
EPA should develop a comprehensive, regular program for coranunication,
education and technology transfer across all environmental ;nedia. The
report of Che Administrator's Task Force on Technology Transfer and
Training is an important step forward for EPA; its reconmendations snoulc
be fully implemented.
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2.3.1 Education ana Training grogrars^ -- It is important for £?A, private
indus try"7~crade~^ana professional" associations, and universities to work
cooperatively to incorporate training in environmental issues into the
curricula of a number of disciplines relevant to environmental management.
It, is critical that much more integrated views of product, design, production
processes, waste generation, product handling and use, non-engineering
approaches, coat effectiveness, and polluCion control that relate to all
risk reduction strategies be developed in such fields as civil, environmental,
chemical process, mechanical, electrical and petroleum engineering;
business; public policy; economics; medicine; public health and law. As
an example, pollution control -- much less environmental protection ---
cannot continue to be thought of only as an "end-of-pipe" treatment of
wastes. A sound integrated curricula would not require separate courses
on topics such as source reduction and waste audits. Rather, the curricula
would teach the implications for pollution generation of actions not
traditionally associated with pollution. An example is to incorporate
waste elimination as a goal of a design problem on manufacturing computer
chips.
EPA should work actively with groups such as the National Research
Council, the National Science Foundation, the American Institute for
Chemical Engineers, the Association of Environmental Engineering Professors,
the Accreditation Board for Engineering and Technology, the American
Academy of Environmental Engineers, the American Medical Association, the
American Public Health Association and the American Bar Association to
advocate such changes.
In addition, EPA should support the developmait and implementation
of such education programs. Such programs could include education and
training materials, handbooks and other written and audiovisual materials
and also seminars and training courses. The success of the existing
regional asbestos training and information centers sponsored by EPA are
an excellent example of the value of such programs that should be replicated
for other risk reduction strategies.
Priorities for consideration should include
a. lead paint removal,
b. radon mitigation,
c. integrated pest management,
d. chemical accident risks,
e. hazardous waste management,
f. support of curriculum development at universities in
environmental management and risk reduction, and
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g. support of iriouace fellowships, traiiieeships anu research
assistantships -- EPA has an excellent program of environmental
policy research performed by graduate students at 25 universities
through its National Network for Environmental Policy Studies.
The current program should be expanded and to include risk
reduction strategies.
2.3.2 Technology Transfer — As stated in introduction to the "Report on
the Administrator s Task Force on Technology Transfer and Training," (14)
technology transfer is an essential element of the EPA mission:
"The evolution of environmental programs has changed the
climate and conditions under which EPA operates, challenging the
Agency to adapt to these new conditions and expand its role to meet
new needs. As the environmental programs of the 1980s develop and
mature, more of the work in environmental protection is being carried
out in the field by the EPA Regional Offices and State and local
government agencies. In addition, the Clean Air Act, Resources
Conservation and Recovery Act (RCRA), Superfund (CERCLA), Safe
Drinking Water Act, and Clean 'water Act all mandate more involvement
by State and local governments in implementing the statutes. This
evolution has a significant impact on EPA's approach to carrying out
its mission, prompting it to extend its role beyond its traditional
'focus"on enforcement and regulation to a renewed emphasis on technology
transfer and training as means of accomplishing environmental
protection goals. As EPA moves into, this new and expanded role,
the Agency has a unique opportunity-to redefine 'and forge new
relationships with States, local governments, industry, and
academia that are based on partnership and cooperation."
"Compliance with environmental regulations can be more
readily accomplished if monitoring and enforcement activities
are combined with a program of technical assistance and training.
Further, many areas of environmental concern, such as the radon
and nonpoint source water pollution problems, do not lend
themselves to the traditional regulatory and enforcement approach;
in these cases, technology transfer and training can provide a
mechanism for the_development of positive solutions that draw
on the unique strengths of all parties involved. EPA, working
in partnership with the States, must take action to legitimize the
importance and integral nature of technology transfer and training
to its mission. As the Agency continues to evolve and mature,
technology transfer and training must become core elements in
supporting the Agency's operations and interactions with the states
and local government, industry, and academia."
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"Further, the Task Force oelieves that failure to
incorporate such an arenas is throughout the Agency will
undermine the effeetiver.ess or the Agency's regulatorv
and enforcement efforts, and related activities at the
State and local level."
The Task Force is soc alone in its view that technology transfer and
training will be crucial components of EPA's future role. Congress
emphasized the importance of technology transfer by unanimously passing
the Technology Transfer Act of 1986. This incentive-oriented law was
further buttressed by Executive Order 12591, which encourages cooperative
consortia among government, acaderaia, and industry for the development
and commercialization of new technology.
The Administrator's Task Force report is correct. A strong technology
transfer program is essential to achieving risk reduction goals and
should be a component of the ORB program or risk reduction research.
Such a program should:
a. have an Office of Technology Transfer in the Office of Research
and Development — This office would coordinate activities with
similar entities in the Office of Regional Operations and-other
program offices,
b. establish technology transfer and training as legitimate core
elements of the Agency's approach to accornplishing its mission
and include them as part of the program budget,
c. develop cooperative partnerships among government, industry,
and acaderaia for technology transfer, and
d. explore innovative programs such as the use of retired
professionals, exchange of personnel among EPA headquarters,
laboratories, regional offices and states through the
Intergovernmental Personnnel Act or use of unemployed persons
for risk reduction work — These programs should be implemented
with the assistance of states and unversities to foster the
most effective outreach.
EPA should expand its current technology transfer program on waste
reduction to other risk reduction areas as an example of an increased
effort in technology transfer. The current program to develop and test
assessment procedures suitable for identifying potential waste reduction
opportunities for major hazardous waste generating sectors, Waste Reduction
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Audit Protocols (WRAP), is a good scare Due should be expanded to air and
water discharge sources. Similarly, the waste reduction evaluations at
federal sites, Waste Reduction Evaluations at Federal Sites (WREAFS), is an
excellent idea bur should be expanded to cover all environmental media
at government facilities, not just at DOE and DOD. A handbook on source
reduction and recycling such as that recommended by the July 1987 Waste
Minimization Policy forum conducted by Tufts University for EPA is a
mechanism of technology transfer which should be further developed. EPA
should also consider development of expert systems in source reduction
and recycling for use by states and industry.
In targeting technology transfer efforts, EPA should concentrate on
groups and institutions where the greatest risk reduction results are likely
to occur. In waste reduction, for example, efforts should be targeted
initially to industries that use chemicals, but have little expertise in
the chemistry of waste management. Such industries include the electronics,
aerospace, and metal fabrication industries. In addition, EPA may want to
consider the feasibility of implementing waste minimization practices in
selected companies or industries. By beginning in industries that are
most receptive, and on processes likely to generate positive results, it
can establish a solid foundation for its program. Moreover, small and
median sized hazardous waste generators (plants that generate 1,000 -
100,000 kilograms of hazardous waste per month) could benefit most from
source reduction technology-transfer efforts because they often are not
aware of source reduction and recycling options and because implementing
promising options could have a significant impact on waste generation
nationally. Among medium-sized waste generators, the emphasis of technology-
transfer efforts should be on users of chaaicals, as opposed to chemical
manufacturers, because users may lack the chemical engineering expertise
to develop waste minimization approaches. A specific suggestion for
source reduction opportunities that should be encouraged by EPA, other
than those suggested in the ORB Strategy, is the design of new products
that will minimize waste generation by customers or users of these products,
such as solvent or pesticide users.
In summary, technology transfer is an essential element of EPA's
risk reduction program. Technology transfer and training activities
should not be separated from die broader mission of the Agency. Technology
transfer and training are integral to the way EPA will do business in the
future. Technology transfer and training activities are also investments
in the future, whose true value may not become full realized in the short
term.
2.4 Implementation Strategies for Risk Reduction Research
2.4.1 An Orientation co Solving Problems -- In order to be successful in
bringing about environmental change, EPA needs to take a problem solving
approach in dealing with State and local governments and private industry.
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Rather Chan Hocusing only on the establishment of appropriate State and
Local laws and regulations, E?A needs co recognize the need to enhance
operational capabilities of environmental agencies as well. Rather than
looking at permit and enforcement actions as ends in themselves, the EPA
needs to step back and decide tne types of risk reduction techniques that
it wants to bring about in specific instances. This should include waste
reduction approaches as well as the more traditional control technology
approaches. The EPA should then consider all of the tools at its disposal
in order to make the desired changes. In some cases enforcement action
may be appropriate. In other cases a technology transfer program which
could include joint EPA-industry development and testing might be a
better approach. Technical assistance and training to State and local
agencies, who then in turn could work with particular industries, should
also be considered.- Public education may be necessary in order to obtain
approval for desired results (e.g. the siting of a new treatment technology).
The important point is that the Agency must assume a more proactive
leadership position in bringing about environmental change and that it
should constructively support State and local government and industry
through training, technical assistance and technology transfer as well as
conducting risk reduction research.
2.4.2 Establishing and Updating Priorities fgrJRl^^gductj.gn
Risk assessment is one tool for identifying and quan11fying_ risks.
Most current EPA risk assessment activity consists'bfcwo 'major parts.
The first part is exposure analysis. This is figuring out how many
people have been exposed to what chemical, for how long, and at what
levels. The second part is producing oose-response curves directly from
health data or, indirectly, by analogy with known effects of similar
chemicals.' The results of these two parts combine to compute what part
of the population may have a health effect at each level of severity as a
result of exposure. (See Figure 2, page 2). Although this currently
represents the main tool, it is severely limited by the paucity of relevant
exposure data, and is clearly not adequate for ecosystem degradation
modeling. We leave that discussion to others.
Each of the two technical parts mentioned above is only as accurate
as the means and dispersions of the exposure distributions and dose-response
curves, and the accuracy of techniques for projecting health effects from
one chemical to another. The technology and databases for all three are
constantly changing.
EPA should have a core research program to increase the reliability
of these methods. Often load limits for toxic chemicals are determined
using a "margin of safety" to make up for the lack of accuracy of the
curves. Developing more accurate curves by long-term basic research tray
mean more accurate load limits, as well as more focused and efficient
prevention and remediation. This is a legitimate risk reduction research
area.
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After technical risK assessment, sarety analysis cfien determines
whether the levels of risk incurred are acceptable or whether plans
should be made to reduce these levels in some way to an acceptable level.
Considerations of societal norms, laws, regulations, and politics enter
here. The mere publication of a safety analysis showing that practices
are not acceptable and entail perceived risks may itself be a control
technology. Such actions may result in reducing the risk due to public
pressure on those responsible for the risk.
The technical part of an EPA risk reduction strategy consists of
developing all feasible alternate control strategies for the sources,
translocation, and transformation of chemicals which result in exposure,
and evaluating these alternative control strategies for quantitative
effectiveness by the tecnnical risk assessment mentioned above. This
includes investigation and evaluation of not as yet developed control
technologies, used at control points in ways not previously investigated.
These strategies cover a much wider range of possibilities than is often
considered. Among these alternatives are waste minimization, multimedia
source reduction, recycling, treatment, and disposal in all media.
This also includes education, as the population affected may avoid
exposure by voluntary acts, such as moving or not buying products, or may
apply political pressure to the manufacturer. These strategies will
necessarily involve EPA, industry, internal and extramural research,
technology transfer assistance prograns, and educational programs.
Non-technological strategies may sometimes be ^ore effective in
reducing risk (and less costly) than very elaborate technologies applied
to the production and transformation of the chemicals.
In sunnary, risk assessment has four stages;
a. identification of risks,
b. evaluation of severity of risks,
c. identification of strategies to control risks, and
d. evaluation of the effectiveness of strategies to reducing__
risks.
Each of these stages requires constant updating and necessitates an
ongoing, core research program to update assessments.
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Various criteria can be used to categorize risks.
Newly Emerging Risk^: We may be presented at any time with
suggestive or anecdotal evidence that exposure to a previously
ignored chemical or biological, substance may have serious
consequent risks to man or the environment. Virtually
all current EPA resources currently are budgeted to known
problems. This should not result in putting off exploratory
investigation of new presumptive risks. If, after exploratory
analysis, the new risk is of so small a magnitude that
remediation would yield an insignificant risk reduction
relative to other known risks, the area of investigation
may be dropped. But how should one get to that
decision point?
Stratification of Populations and Areas by Risk Level: An
error that should be avoided is dismissing the risks of
exposure to a substance because the average exposure of a
large population is small. Within the large population
there may be identifiable high-risk groups and therefore
extremely inequitable risks. A high risk for a few is not
counter-balanced by a small average risk for the many. Such
an approach is contrary to the assertion of nany industrial
risk assessors who make meaningless comparisons of the risks of
exposure of employees to plant chemicals with everyday risks.
All risk assessments should be required to stratify exposed
populations and areas by risk level, obtaining the distribution
of risk. This often requires data gathering. For example,
for house radon exposure, one method of gathering data is
overflights which give a contour map of activity so that
the physical areas where many individuals have high radon
exposure can be pinpointed. In the non-pinpointed areas
where the average exposure can be expected to be low,
house-to-house radon variation is largely based on extremely
local geology, and remediation is needed in many houses
in these non-pinpointed areas. Getting the appropriate
stratification to estimate who is at high risk and where
they are requires care.
Recognizing the Vector Nature of Risk: A second error is
thinking of the effect of a control strategy in an univalent
way in terms of one effect. But getting the level of one
chemical down often shifts exposure to other pathways. In
the case of sludge, land spreading might cause heavy
metals to enter the human food chain. Burning sludge
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causes chose same mecals Co be emicced ana possibly respired,
and sea disposal may cause chose same raecals Co encer fish and
Che human food chain anocher way. 'tultipLe-ciedia, raulciple-chemical
exposure effeccs of each proposed concrol scracegy of reraediacion
have co be escabLished simulcaneously in order co gee a crue
picture of cotal healch risks. Every control scracegy proposed
should be evaluated according Co che veccor nature of che
resulting exposures.
This is currencly noc conmon practice, but ought to be atcempced
in evaluacing concrol scracegies.
Dose-Response Curves — A Problem Thac Won' c Go Away: A principal
cocponenc of risk assessmenc is dose-response curves. These
curves convert exposure inco healch effeccs, mortality and
morbidity. How co excrapolace fran short-Cerra, high-dosage
exposures in a laboratory on animals Co resulcs for long-term,
low-dosage exposures of peoplet in a natural environment is an
area of great controversy and much theology and debate.
Different modelst based on different detailed assessments of
biology and chemistry, give estimates orders of magnitude
apart, and often are used to rank problems for suitability for
mitigation or regulation. There is perhaps more dispersion of
estimates in this part of risk assessment than in any ocher.
This is an area where fundamental, theoretical and experimental
research is required, to evaluate these models according to EPA
as well as state and local (e.g., conmunicy righc-to-know)
needs.
Screening Chemicals for Risks: There are a myriad of unexplored
chemicals which may pose health hazards. Without availability
of dose-response curves, based on animal experiments, and
without waiting for complaints to pour in that new chemicals
are risky, it would be much better to develop predictive tools,
predicting health effects based on structure, using similarities
to chemicals that have been tested in a dose-response arena.
There is important EPA activity in this area, but its basic
scientific justification as applied is limited. A research
program should be jointly conducted with EPA, industrial, and
university chemists and dose-response experts. Industrial
chemists wish to avoid the use of, possible exposure to, and
liabilities of high-risk chemicals, and have every reason
to cooperate. Further, there is virtually no research on the
synergistic or antagonistic effects of chemical soups, such as
drinking water, with many different crace organoraetallic chemicals
in many urban areas. It is perfectly possible that rescriccing
each of these chemicals to a low level does noc eliminate dececcable
joinc healch effeccs, for which new joinc esciraacors are required.
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Administrative Obstacles: Exploratory investigation to discover
the Likely extent of ris*. is often not possible within one
office committed to one law or one medium. This points to the
necessity of separs.ce runding for exploratory analysis for
identification of new risks. Such exploratory research is
often interdisciplinary. One needs chemistry, physics, engineering,
as well as biological and health sciences. One needs a cross-media,
cross-exposure path and cross-chemical products approach.
One New Tool — Exploratory Data Analysis: An important new
discipline for looking for effects in data of uncertain origin
when the effects are not known or understood in advance is
Exploratory Data Analysis (EDA). This discipline is different
from conventional statistics, which deals with analysis of data
that'has been collected according to statistical practice. It
may be described as a collection of algorithms and concepts for
rearranging massive daca until one can see the effects and
develop appropriate estimators. This discipline has converted
the "art of" discovery of effects buried in data bases into
"close to a science;" A science utilized before conventional
statistics are used.
EDA is a very powerful new tool and should be taught to EPA
scientific staff as a tool like FORTRAN or physics. EDA. has
many possible uses in EPA. A premier one is in the identification
stage of risk assessment. It is especially effective whenever
one has to consult large data bases that are not the result of
designed experiments with controlled variables. EDA's effect-finding
algorithms have been implemented for graphics work stations, so
that the user needs only a surface knowledge of EDA and can use
the human eye to detect effects by rearranging and transforming
massive data bases in many different ways. EDA helps discover
new and reliable estimators. EPA needs estimators of risk in
all risk assessments. Such estimators are as diverse as BOD or
linear health effect models; they represent the quantities,
usually a compound result cf measurements of a number of physical
measurements, which represent a density or cumulative exposure,
or an effect in dose-effect, for example.
We all know many cases when estimators have been used to establish
toxic loads without adequate exploratory or confirmatory research
to determine that these estimators are robust estimators of the
intended risks. Systematizing the development of estimators is
a task for exploratory data analysis; validating or confirming
the choice is the domain of conventional science and ordinary
confirmatory statistics. EDA is an exploratory rather than
confirmatory tool. After the effects are discovered and gooc
estimators are developed by EDA, systematic data collection and
experiments can then be undertaKen. Such an approach is likely to
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supply the grisc for the Mill of ordinary confimatory scaciscics
to raore effectively validate the estimators.
h. Another New Tool: Expert Systems: Expert systems are extraordinarily
versatile tools for technology transfer. The elementary knowledge
and tools of the best workers in each area of risk assessment
can record their knowledge in one of these "automated handbooks"
for use by others in EPA, local, State and Federal Government,
and industry. As lon^ as one does not try to encapsulate
knowledge that does not exist (where there are no experts),
this is a viable tool for technology transfer, as long as the
methodology, databases and models for risk are updated.
One might think that establishing risk-reduction research priorities
would be merely a matter of applying the criteria to the identified risks.
However, complicating factors include:
a. the relative importance of each identified risk and e^ch
criterion is viewed differently by experts having different
perspectives,
b. essential support from EPA management and from those
responsible for the budget is dependent upon people
'having perspectives often different from those of the
experts, and
c. fruitful research requires a cadre of knowLedgeable, dedicated
people working in a given area over a period of at least a few
years.
The answer seems to lie in establishing a few "continuing core research
areas" and periodically convening persons representing a range of interests
to ascertain if these still are the right core areas , what new research
goals within these core areas are needed, and what funding is appropriate
given the magnitude of the risk and chances of research contributing to
reduction of that risk.
The core research areas would involve dedicated people at the ORD
laboratories supported by cooperative agreements and by competitive grants
to the scientific coinnunity. The latter is essential to get the best
thinking into the program. The core research areas would have short-term
regulatory deliverables within its continuing program aimed at addressing
the over-all risk-reduction opportunity.
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One mechanism tor establishing priorities is technical consensus.
A consensus prioritization of researcn opportunities could be established
by convening a group of persons associated with:
a. EPA. program offices, CRD, Regions, the states and SAB,
b. academia, research institutes,
c. regulated connunity,
d. pollution control industry, consulting engineers, and
e. public representatives.
Such a group would be organized and developed by allowing a period of
exchange of ideas and views on risk-reduction research and priorities.
Also, subpanels representing each interest group could be established
with the leaders represented on trie cencral group.
In addition to establishing priorities, the subpanels could be asked
to predict the future, especially in terns of new or escalating problems;
formal forecasting tools might be used.
2.4,3 Extramural and Intramural Research — A strong extramural research
program is essential to compLeaent EPA's intramural program. In addition
to the work being funded by EPA at existing university centers, EPA should'
utilize other university, and private organization capabilities through an
open competitive process.
This is critical for the continued development of innovative risk
reduction strategies and will help provide the trained personnel necessary
to implement risk reduction strategies.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
- WASHINGTON. D.C. 204SS
DEC I 0 1987 orricl or
MCSCAHCH AND OCVtLOCMENT
MEMORANDUM
SUBJECT: Economic Successes in Risk Reduction Research
HOI: John H. Skinner, Director
Office of Eiwircmental
and Technology Demonstration (RD-S81)
TO: Risk Reduction Work Group
As requested at the Novetfoer 24, 1987, meeting of the Risk Reduction
Work Group, attached are several examples of cost savings that have
resulted from EPA's research program en innovative treatment technologies
in tiie wastewater and hazardous waste areas. _ I am locking forward to
meeting with you again at the Deceafcer 17 meeting in Cambridge.
Attachments
cc: Kathleen Conway
Ton Devine
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EXAMPLES OF CCST SAVT3GS FRCM RESEARCH MO
CN H2CVMTVS
EPA has cccdvjctad considerable successful research in the area of
innovative treatment technologies. The application of these technolo-
gies can result in iuiproved treatment effectiveness. risk reduction.
and savings of energy and costs. Th« following are a few exatrples of
such savings in toe areas of wastei-ater and hazardous waste treatoent.
Secondary Clarif ication Igsrovgnents. In the previous two decades.
EPA and its predecessors funded research which developed improved
secondary clarifiers for wastewater treatment plants. Tfaes* secondary
clarifiers incorporated flccculator center wells. A mildly stirred
flocculation area was s«t up between the aeratioD basin and the secord-
ary clarifier. The first full-scale testing of this new flccculatian
concept was 'Conducted at the City of Gorvallis, Oregon, which succeeded
in producing an average effluent SS and 8Q3 of 5 mg/1, which was equal
to or better than that obtainable by using costly effluent filtration.
A $70,000 expenditure for basic research in flccculaticn has saved
millions of dollars in construction and operating coats. For one 50-
mgd plant, the original research has a boaefit-to-eoat ratio of 27 to 1.
The potential national coot savings are in th* order of S3 80 mill ion,
a benefit-to-coat ratio of 1400 to 1.
Improvements in Trickling, •Filter Design, ERA played a key role in
the development of the trickling filter/solids contact process. An
effluent SS and BCD of 10 mg/1 can b« achieved without using effluent
filtration. This provides a cost effective way of upgrading trickling
filters with solids contact units to meet the national secondary treat-
ment requirements. This process has been applied at over 50 locations
across the country. By FY 1986-,' 17 projects had been funded taader EPA's
Innovative/ Alternative progr*
.EPA's expeoiiture of $290,000 in conducting plant-scale testing of
this process could result in a national savings of $280 million, which
is equivalent to a bemf it-to-cost ratio of 1000 to 1.
Oxygen Aeration Systems, utilization of oxygen aeration for acti-
vated sludge treatment has received wide field acceptance. The R&O
program moved * 20-year old concept through the pilot stage to a fully
demonstrated capability by means of in-house effort, development con-
tract and demonstration grants in a period of 5 years. Several cost
effective systems for dissolving and utilizing oxygen gas have been
developed. Based on the original EPA demonstraticns, comparative costs
for air and oxygen systems shew average savings in total treatment costs
of about 20 percent. A Federal R&D investment of $3.2 million has
effected an annual savings of $14 million in treatment costs—a return
on investment of 330 percent.
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